Burden Cost Tables

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Overview

1a_small
1b_large
OpCosts
1c_Summary
2_EPA
Responses
Working Respondent
1a_increment
1b_increment

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Sheet 1: 1a_small

Table 1a: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Proposed Amendments)												Salaries taken for NAICS 331500: Foundries
												May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
					81.33	123.71	42.8
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b	ERG comment on changes	RTI Comment		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									Don't use full compensation rates and then add burden. Either use straight rates and add burden or use full compensation rates.		11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A											17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A											43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	0.5	1	0.5	315	158	7.9	15.8	$14,458	added respondent burden and referenced footnote a, but decreased this burden from 4 to 1 hr for ongoing burden	Estimate only 0.5 hours for small foundries - not much there for them.
B. Required activities
Repeat performance tests for opacity	N/A									Applicable for large foundries only.
Scrap specificationsc	4	1	4	0	0	0	0	$0
Monthly emission averaging calculation	N/A								do not see rolling average in rule, just emission averaging; monthly basis	Applicable for large foundries only.
No methanol binder formulation d	0	0	0	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityc	2	1	2	0	0	0	0	$0
Notification of compliance statusc	4	1	4	0	0	0	0	$0
Notification of construction/reconstructionc	N/A								added footnote g since this is one-time
Notification of actual startupc	N/A								added footnote g since this is one-time
Notification of foundry reclassificatione	1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A								added footnote g since this is one-time
Notification of repeat performance test	N/A								this was the line item for footnote E which talks about opacity and lack of need for separate notification
Site specific test plan	N/A								added footnote g since this is one-time
Notification of performance evaluation	N/A								added footnote g since this is one-time
Quality assurance plan for CEMS/COMS	N/A								added footnote g since this is one-time
NESHAP waiver requestc	N/A								added footnote g since this is one-time
Startup, shutdown, and malfunction plan/reports	N/A								new footnote H since we did not assume any small sources would have to write this report
Report of performance test (through CEDRI using ERT) c	N/A
Semiannual compliance reports	4	2	8	315	2520	126	252	$231,325	new footnote H since we did not assume any small sources would have to write this report	Deleted deviations report - just do semiannual report. Adding here.
Subtotal for Reporting Requirements					3,079			$245,782
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activitiesf	2	1	2	105	210	11	21	$19,277
C. Implement activities f	2	1	2	105	210	11	21	$19,277
D Develop record system f	1	1	1	105	105	5	11	$9,639	added footnote g since this is one-time	Assigning these for initial cost of rule revisions
E. Time to enter informationg	0.1	52	5.2	315	1,638.0	81.90	163.80	$150,361.03
F. Time to transmit or disclose information	0.25	2	0.5	315	158	7.88	15.75	$14,457.79
G. Time to adjust existing ways f	1	1	1	105	105	5	11	$9,639		Assigning these for initial cost of rule revisions
F. Time to train personnel f	2	1	2	105	210	10.5	21.0	$19,277	added training time	Assigning these for initial cost of rule revisions
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,031			$241,927
TOTAL LABOR BURDEN AND COST (rounded)h					6,110			$488,000
TOTAL CAPITAL AND O&M COST (rounded)h								$0
GRAND TOTAL (rounded)h					6,110			$488,000
Assumptions:
a This table is specific to area source foundries classified as small iron and steel foundries. A total of 315 of the 390 area source foundries are small foundries and 75 are large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c One-time only costs
d We have assumed that no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.
e We have assumed that no small foundries will be reclassified as large foundries.
f We have assumed that all small foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (315+0+0)/3 = 105.
g We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Small foundries are not assumed to incur any capital or O&M costs.

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Sheet 2: 1b_large

Table 1b: Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Proposed Amendments)												Salaries taken for NAICS 331500: Foundries
												May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
					81.33	123.71	42.8
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b	ERG comment on changes	RTI Comment		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									Don't use full compensation rates and then add burden. Either use straight rates and add burden or use full compensation rates.		11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A											17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A											43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	1	1	1	75	75	3.8	7.5	$6,885	Added this as an ongoing burden per OMB requirement, but decreased hours from 8 to 1 for re-familiarization of rule	OK
B. Required activities
On-going Performance Test for PMc	70	0.2	14	75	1050.0	52.50	105.00	$96,385		Increased the hours to do test, consistent with 40 CFR 63 subpart EEEEE
On-going Performance Test for Opacityd	3	2	6	75	450.0	22.50	45.00	$41,308		Increased the hours to do test, one observation spot
Scrap material specificationse	4	1	4	0	0	0	0	$0
Prepare operation & maintenance plane	8	1	8	0	0	0	0	$0
No methanol binder formulation e	4	1	4	0	0	0	0	$0		This essentially a one time requirement. Once change system, no real on-going burden.
Initial performance tests e	70	0	0	0	0	0	0	$0
Initial and periodic inspections of PM control devices, monthly inspection of capture systems f	2	12	24	75	1800	90	180	$165,232
Monthly emissions averaging calculations g	0.25	12	3	37.5	112.5	5.625	11.25	$10,327
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilitye	4	1	4	0	0	0	0	$0
Notification of compliance statuse	8	1	8	0	0	0	0	$0
Notification of construction/reconstructione	N/A
Notification of actual startupe	N/A
Notification of foundry reclassificationh	1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A								added footnote h, one-time
Notification of repeat PM performance test c	1	0.2	0.2	75	15.0	0.75	1.50	$1,377
Site specific test plan e	0	0	0	0	0	0	0	$0	added footnote h, one-time
Notification of performance evaluatione	N/A								added footnote h, one-time
Quality assurance plan for CEMS/COMSe	N/A								added footnote h, one-time
NESHAP waiver requeste	N/A								added footnote h, one-time
Startup, shutdown, and malfunction plan/reports	N/A								added footnote j	no longer required
Report of performance test (through CEDRI using ERT) c	8	0.2	1.6	75	120.0	6.00	12.00	$11,015
Semiannual compliance reports i	8	2	16	75	1200	60.0	120.0	$110,155	added footnote j
Subtotal for Reporting Requirements					5,546			$442,684
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities j	4	1	4	25	100	5	10	9180
C. Implement activities j	4	1	4	25	100	5	10	9180
D Develop record system j	2	1	2	25	50	3	5	4590
E. Time to enter information k	0.5	52	26	75	1,950	97.5	195.0	$179,001
F. Time to transmit or disclose information k	0.25	2	0.5	75	38	1.9	3.8	$3,442
G. Time to adjust existing waysj	2	1	2	25	50	3	5	$4,590
F. Time to train personnel j	4	1	4	25	100	5.0	10.0	$9,180
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,746			219,162
TOTAL LABOR BURDEN AND COST (rounded)l					8,290			662,000
TOTAL CAPITAL AND O&M COST (rounded)l								$0
GRAND TOTAL (rounded)l					8,290			$662,000
Assumptions:
a This table is specific to area source foundries classified as large iron and steel foundries. There are an estimated 390 area source foundries, 75 of which are expected to be classified as large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to a change to an operating limit or a process change likely to increase HAP emissions over the period of this ICR. A notification is required.
d We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity performance tests should be conducted over 3-hour period as specified in §63.6(h)(5)(ii). Assume one observation location can be used per foundry. No separate notification required.
e One-time only costs
f We have assumed that all large foundries must conduct inspection of control device and capture system.
g We assumed half of the large area source foundries (75/2 = 37.5) would use the emissions averaging provisions.
h We have assumed that no foundries will be reclassified as small foundries.
i We have assumed all large foundries will have to submit semi-annual compliance reports.
j We have assumed that all large foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (75+0+0)/3 = 25.										new footnote i
k We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations and information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of the General Provisions (40 CFR part 63, subpart A). In addition, record to record information to demonstrate compliance with the PM and opacity standards.										added footnote j
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Large foundries are not assumed to incur any capital or O&M costs.										relabeled to k

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Sheet 3: OpCosts

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B x C)	Annual O&M Costs for One Respondent	Number of Respondents with O&Ma	Total O&M, (E x F)
Leak detectors	$9,000	0	$0	$1,470	0	$0
Flow rate monitors	$7,500	0	$0	$2,000	0	$0
Pressure drop	$7,500	0	$0	$2,000	0	$0
Total b			$0			$0
a PM control system O&M cost are only applicable to large iron and steel foundries, of which there are 75. Assumes 20 foundries use a wet scrubber and the remainder use a baghouse.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: 1c_Summary

Table 1c: Annual Respondent Burden and Cost for All Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
	Category	Reporting Hours	Recordkeeping Hours	Total Labor Hours	Labor Cost	Number of Response
	Small Foundry	3,079	3,031	6,110	$488,000	630
	Large Foundry	5,546	2,746	8,290	$662,000	180
	Total	8,625	5,776	14,400	$1,150,000	810
				18	hr per resp

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Sheet 5: 2_EPA

Table 2: Average Annual EPA Burden and Cost – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
				2019:	$49.44	$66.62	$26.75
Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Report Review:
Initial notification of applicability c	1	1	1	0	0	0	0	0
Notification of compliance statusc	2	1	2	0	0	0	0	$0
Notification of performance testd	1	0.2	0.2	75	15.0	0.75	1.50	$831.70
Performance test reportd	2	0.2	0.4	75	30.0	1.50	3.00	$1,663.39
Semiannual compliance report - smalla	1	2	2	315	630	31.5	63.0	$34,931.23
Semiannual compliance report - largea	2	2	4	75	300	15.0	30.0	$16,633.92
TOTAL BURDEN AND COST (rounded)e					1,121			$54,100
Assumptions:
a Taking into account shutdown data for foundries, we have assumed that there are 390 existing iron and steel foundries that are area sources. No new sources are projected during the 3-year term of this ICR. A total of 315 of the 390 facilities are small foundries and 75 are large foundries. All foundries have to submit semiannual compliance reports.
b This cost is based on the following 2019 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $66.62 Managerial rate (GS-13, Step 5), $49.44 Technical rate (GS-12, Step 1), and $26.75 Clerical rate (GS-6, Step 3). These rates are calculated from the hourly rates included in the Office of Personnel Management (OPM) 2019 General Schedule which excludes locality rates of pay; the rates have been increased by 60 percent to account for benefit packages available to government employees.
c One-time only costs
d We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to change to an operating limit or a process change likely to increase HAP emissions.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Agency Worker Rates	Labor Rates, $/hr a	60% Overhead	Total, $/hr
Managerial (GS-13, step 5)	$41.64	$24.98	$66.62
Technical (GS-12, step 1)	$30.90	$18.54	$49.44
Clerical (GS-6, step 3)	$16.72	$10.03	$26.75
a https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf
Effective January 2019

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Sheet 6: Responses

(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
				E=(BxC)+D
Initial Notification	0	0	0	0
Notification of Compliance Status	0	0	0	0
Notification of Foundry Reclassification	0	0	0	0
Notification of Performance Test for PM (large foundries)a	75	0.2	0	15
Report of Performance Test for PM (large foundries)a	75	0.2	1	15
Semiannual compliance reports (small foundries)	315	2	0	630
Semiannual compliance reports (large foundries)	75	2	0	150
			Total	810

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Sheet 7: Working Respondent

	Current ICR (2267.05)				Revised ICR (2267.06)
	Number of Sources	Distribution	Number of Small Entity	Basis	Number of Sources	Basis	Number of Small Entity	Basis
Total	392	1.00	303		390	Total count gone down consistently, assumed two more drop. One small and one large
small	316	0.81	269	85% of small foundries are small entities	315	revised small count	268	85% of small foundries are small entities
large	76	0.19	34	45% of large foundries are small entities	75	revised large count	34	45% of large foundries are small entities

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Sheet 8: 1a_increment

Table 1a: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)												Salaries taken for NAICS 331500: Foundries
												May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
					81.33	123.71	42.8
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b	ERG comment on changes	RTI Comment		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									Don't use full compensation rates and then add burden. Either use straight rates and add burden or use full compensation rates.		11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A											17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A											43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	0.5	1	0.5	0	0	0.0	0.0	$0.00	added respondent burden and referenced footnote a, but decreased this burden from 4 to 1 hr for ongoing burden	Estimate only 0.5 hours for small foundries - not much there for them.
B. Required activities
Repeat performance tests for opacity	N/A									Applicable for large foundries only.
Scrap specificationsc	4	1	4	0	0	0	0	$0
Monthly emission averaging calculation	N/A								do not see rolling average in rule, just emission averaging; monthly basis	Applicable for large foundries only.
No methanol binder formulation d	0	0	0	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityc	2	1	2	0	0	0	0	$0
Notification of compliance statusc	4	1	4	0	0	0	0	$0
Notification of construction/reconstructionc	N/A								added footnote g since this is one-time
Notification of actual startupc	N/A								added footnote g since this is one-time
Notification of foundry reclassificatione	1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A								added footnote g since this is one-time
Notification of repeat performance test	N/A								this was the line item for footnote E which talks about opacity and lack of need for separate notification
Site specific test plan	N/A								added footnote g since this is one-time
Notification of performance evaluation	N/A								added footnote g since this is one-time
Quality assurance plan for CEMS/COMS	N/A								added footnote g since this is one-time
NESHAP waiver requestc	N/A								added footnote g since this is one-time
Startup, shutdown, and malfunction plan/reports	N/A								new footnote H since we did not assume any small sources would have to write this report
Report of performance test (through CEDRI using ERT) c	N/A
Semiannual compliance reports	4	2	8	0	0	0	0	$0	new footnote H since we did not assume any small sources would have to write this report	Deleted deviations report - just do semiannual report. Adding here.
Subtotal for Reporting Requirements					0			$0
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activitiesf	2	1	2	105	210	11	21	$19,277
C. Implement activities f	2	1	2	105	210	11	21	$19,277
D Develop record system f	1	1	1	105	105	5	11	$9,639	added footnote g since this is one-time	Assigning these for initial cost of rule revisions
E. Time to enter informationg	0.1	52	5.2	0	0.0	0.00	0.00	$0.00
F. Time to transmit or disclose information	0.25	2	0.5	0	0	0.00	0.00	$0.00
G. Time to adjust existing ways f	1	1	1	105	105	5	11	$9,639		Assigning these for initial cost of rule revisions
F. Time to train personnel f	2	1	2	105	210	10.5	21.0	$19,277	added training time	Assigning these for initial cost of rule revisions
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					966			$77,108
TOTAL LABOR BURDEN AND COST (rounded)h					970			$77,000
TOTAL CAPITAL AND O&M COST (rounded)h								$0
GRAND TOTAL (rounded)h					970			$77,000
Assumptions:
a This table is specific to area source foundres classified as small iron and steel foundries. A total of 315 of the 390 area source foundries are small foundries and 75 are large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c One-time only costs
d We have assumed that no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.
e We have assumed that no small foundries will be reclassified as large foundries.
f We have assumed that all small foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (315+0+0)/3 = 105.
g We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Small foundries are not assumed to incur any capital or O&M costs.

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Sheet 9: 1b_increment

Table 1b: Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)												Salaries taken for NAICS 331500: Foundries
												May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
					81.33	123.71	42.8
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b	ERG comment on changes	RTI Comment		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									Don't use full compensation rates and then add burden. Either use straight rates and add burden or use full compensation rates.		11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A											17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A											43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	1	1	1		0	0.0	0.0	$0.00	Added this as an ongoing burden per OMB requirement, but decreased hours from 8 to 1 for re-familiarization of rule	OK
B. Required activities
On-going Performance Test for PMc	70	0.2	14		0.0	0.00	0.00	$0.00		Increased the hours to do test, consistent with 40 CFR 63 subpart EEEEE
On-going Performance Test for Opacityd	3	2	6		0.0	0.00	0.00	$0.00		Increased the hours to do test, one observation spot
Scrap material specificationse	4	1	4	0	0	0	0	$0
Prepare operation & maintenance plane	8	1	8	0	0	0	0	$0
No methanol binder formulation e	4	1	4	0	0	0	0	$0		This essentially a one time requirement. Once change system, no real on-going burden.
Initial performance tests e	70	0	0	0	0	0	0	$0
Initial and periodic inspections of PM control devices, monthly inspection of capture systems f	2	12	24		0	0	0	$0
Monthly emissions averaging calculations g	0.25	12	3		0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilitye	4	1	4	0	0	0	0	$0
Notification of compliance statuse	8	1	8	0	0	0	0	$0
Notification of construction/reconstructione	N/A
Notification of actual startupe	N/A
Notification of foundry reclassificationh	1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A								added footnote h, one-time
Notification of repeat PM performance test c	1	0.2	0.2		0.0	0.00	0.00	$0.00
Site specific test plan e	0	0	0	0	0	0	0	$0	added footnote h, one-time
Notification of performance evaluatione	N/A								added footnote h, one-time
Quality assurance plan for CEMS/COMSe	N/A								added footnote h, one-time
NESHAP waiver requeste	N/A								added footnote h, one-time
Startup, shutdown, and malfunction plan/reports	N/A								added footnote j	no longer required
Report of performance test (through CEDRI using ERT) c	8	0.2	1.6	75	120.0	6.00	12.00	$11,015.46
Semiannual compliance reports i	8	2	16	0	0	0.0	0.0	$0.00	added footnote j
Subtotal for Reporting Requirements					138			$11,015
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities j	4	1	4	25	100	5	10	9180
C. Implement activities j	4	1	4	25	100	5	10	9180
D Develop record system j	2	1	2	25	50	3	5	4590
E. Time to enter information k	0.5	52	26		0	0.0	0.0	$0.00
F. Time to transmit or disclose information k	0.25	2	0.5		0	0.0	0.0	$0.00
G. Time to adjust existing waysj	2	1	2	25	50	3	5	$4,590
F. Time to train personnel j	4	1	4	25	100	5.0	10.0	$9,179.55
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					460			36,718
TOTAL LABOR BURDEN AND COST (rounded)l					600			48,000
TOTAL CAPITAL AND O&M COST (rounded)l								$0
GRAND TOTAL (rounded)l					600			$48,000
Assumptions:
a This table is specific to area source foundries classified as large iron and steel foundries. There are an estimated 390 area souce foundries, 75 of which are expected to be classified as large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to a change to an operating limit or a process change likely to increase HAP emissions over the period of this ICR. A notification is required.
d We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity performance tests should be conducted over 3-hour period as specified in §63.6(h)(5)(ii). Assume one observation location can be used per foundry. No separate notification required.
e One-time only costs
f We have assumed that all large foundries must conduct inspection of control device and capture system.
g We assumed half of the large area source foundries (75/2 = 37.5) would use the emissions averaging provisions.
h We have assumed that no foundries will be reclassified as small foundries.
i We have assumed all large foundries will have to submit semi-annual compliance reports.
j We have assumed that all large foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (75+0+0)/3 = 25.										new footnote i
k We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations and information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of the General Provisions (40 CFR part 63, subpart A). In addition, record to record information to demonstrate compliance with the PM and opacity standards.										added footnote j
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Large foundries are not assumed to incur any capital or O&M costs.										relabeled to k