Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Proposed Amendments)
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences 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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Annual costs ($) b
1. Reporting requirements										Labor Rates:
a. Familiarize with regulatory requirements	4	1	4	1	4	0.2	0.4	$529		Management	$139.63
b. Process/review information	4	4	16	1	16	0.8	1.6	$2,116		Technical	$119.47
c. Write reports										Clerical	$58.15
i. Initial notification	2	1	2	0	0	0	0	$0
ii. Notification of compliance status c	2	1	2	0.33	0.66	0.03	0.07	$87
iii. Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
iv. Notification of actual startup	2	1	2	0	0	0	0	$0
v. Notification of performance test c	2	1.2	2.4	0.33	0.79	0.04	0.08	$105
vi. Report of performance test c, d	180	1.2	216	0.33	71.28	3.56	7.13	$9,428
vii. Semiannual report e	10	2	20	1	20	1	2	$2,645
viii. Report of performance test (through CEDRI using ERT) f	8	1	8	1	8	0.4	0.8	$1,058
Subtotal for Reporting Requirements					139			$15,969
2. Recordkeeping requirements
a. Familiarize with regulatory requirements	4	1	4	1	4	0.2	0.4	$529
b. Plan activities	12	1	12	1	12	0.6	1.2	$1,587
c. Implement activities	12	1	12	1	12	0.6	1.2	$1,587
d. Time to train personnel	10	1	10	1	10	0.5	1	$1,323
e. Record CRB Malfunction corrective measures g	0.5	3	1.5	1	1.5	0.075	0.15	$198
f. Record control device pH, liquid flow and pressure drop on an on-going basis.	0.5	12	6	1	6	0.3	0.6	$794
g. Store, file, and maintain records h	1	365	365	1	365	18.25	36.5	$48,277
h. Retrieve records/reports i	1	12	12	1	12	0.6	1.2	$1,587
Subtotal for Recordkeeping Requirements					486			$55,883
Total Labor Burden and Costs (rounded) j					625			$71,900
Total Capital and O&M Costs (rounded) j								$1,200		3.73	responses
Grand Total (rounded) j								$73,100		167	hr/response
Assumptions:
a We have assumed that there are approximately one respondents subject to the rule, with no new sources expected over the next three-years of this ICR.
b This ICR uses the following labor rates: $139.63 per hour for Executive, Administrative, and Managerial labor; $119.47 per hour for Technical labor, and $58.15 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
c We have assumed that performance tests will be repeated once in three years. We assume that 20% of tests will need to be repeated.
d We assume that this includes Method 23 test.
e We assumed that it will take each respondent ten hours two times per year to complete semiannual reports.
f Submittal of performance test data through the EPA's CEDRI in ERT format is estimated to require 8 hours annually, includes keeping records of failures to meet the standards and the actions taken to minimize emissions.
g It is estimated that three CRB malfunctions would occur per year based on chlorine emission reports submitted by the facility (2018 through Sept 2019) available from the Utah Department of Environmental Quality’s (DEQ) Electronic Document Management System (EDMS) http://eqedocs.utah.gov/.
h This includes inspection of unpaved areas.
i We assume that it will take 1 hour once per month to retrieve records/reports.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Proposed Amendments)
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences 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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Annual costs ($) b
1. Initial performance test c	24	1	24	0.33	7.92	0.40	0.79	$433		Labor Rates:
2. Repeat performance test c	24	0.2	4.8	0.33	1.58	0.08	0.16	$87		Management	$65.71
3. Report review					0	0	0	$0		Technical	$48.75
a. Initial notification	8	1	8	0	0	0	0	$0		Clerical	$26.38
b. Notification of performance test c	8	1.2	9.6	0.33	3.17	0.16	0.32	$173
c. Notification of compliance status c	8	1	8	0.33	2.64	0.13	0.26	$144
d. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
e. Notification of actual startup	8	1	8	0	0	0	0	$0
f. Report of performance test c	8	1.2	9.6	0.33	3.17	0.16	0.32	$173
g. Semiannual report d	16	2	32	1	32	1.6	3.2	$1,750
Total (rounded) e					58			$2,760
Assumption:
a We have assumed that there are approximately one respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2019 General Schedule” which excludes locality rates of pay.
c We have assumed that performance tests will be repeated once in three years. We assume that 20% of tests will need to be repeated.
d We have assumed that it would take 16 hours two times per year to review semiannual reports.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.