Burden Calculation Tables

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Overview

Industry
Agency
Number of Respondents
Capital and O&M

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Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal)
					March 2020 Labor Rates
					121.46	148.45	60.23
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per yeara	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per yearb
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Familiarization with Regulatory Requirements	8	1	8	81.2	649.6	32.48	64.96	$87,634.61
B. Required activities
Initial performance tests c
Prepare scrap plan and scrap specificationsd	4	1	4	1.6	6.4	0.32	0.64	$863
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityd	2	1	2	1.6	3.2	0.16	0.32	$432
Notification of compliance statusd	2	1	2	1.6	3.2	0.16	0.32	$432
Request for compliance extension	N/A
Notification of performance test c
Startup, shutdown, and malfunction plan/reportse	4	1	4	81.2	324.8	16.24	32.48	$43,817.31
Semiannual excess emissions reportse	2	2	4	81.2	324.8	16.24	32.48	$43,817.31
Subtotal for Reporting Requirements					1,509			$176,996			Total Responses	250
5. Recordkeeping Requirements											Hours per response	16.0
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system d	4	1	4	1.6	6.4	0.32	0.64	$863.40
E. Time to enter information f	0.5	52	26	81.2	2,111	105.56	211.12	$284,812.49
F. Time to transmit or disclose informationf	0.25	2	0.5	81.2	40.6	2.03	4.06	$5,477.16
G. Time to adjust existing waysd	2	1	2	0	0	0	0	$0
F. Time to train personneld	4	1	4	1.6	6.4	0.32	0.64	$863.40
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,489			$292,016
TOTAL LABOR BURDEN AND COST (rounded)g					4,000			$469,000
TOTAL CAPITAL AND O&M COST (rounded)g								$15,500
GRAND TOTAL (rounded)g								$485,000
Assumptions:
a There are 78 existing EAF steelmaking facilities and we expect that there will be an average of 1.6 new facilities per year, for an annual average of 81.2 respondents per year. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates: $148.45 for managerial labor, $121.46 for technical labor, and $60.23 for clerical labor. These rates are from the U.S. Department of Labor, Bureau of Labor Statistics, March 2020. The rates have been increased by 110 percent to account for overhead.
c All plants have conducted performance tests during the implementation period of the rule.
d After full implementation, existing facilities are not expected to experience any burden from these activities and 1.6 new facilities per year are expected to become subject to the rule over the 3-year period.
e Sources are required include in their semiannual reports the number of mercury switches removed or the weight of mercury recovered from the switches and properly managed, the estimated number of vehicles processed, an estimate of the percent of mercury switches recovered, and a certification that the recovered mercury switches were recycled at RCRA-permitted facilities, if they are subject to a site-specific plan for mercury. In addition all sources must submit semiannual reports for the control of contaminants from scrap according to the requirements in §63.10(e). For start-up, shutdown, and malfunction, these semi-annual reports are only required if a startup or shutdown caused the source to exceed any applicable emission limitation in the relevant emission standards, or if a malfunction occurred during the reporting period. This ICR assumes each source had one six-month period during each year that required a report.
f Assumed that each facility will update records weekly. The only transmission is the semi-annual report and the annual SSM report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

					2020 Schedule
					50.72	68.37	27.46
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (A x B)	(D) Plants per yeara	(E) Technical person- hours per year (C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person-hours per year (E x 0.1)	(H) Cost, $b
Report Review
Initial notification of applicability c	1	1	1	1.6	1.6	0.08	0.16	$91
Startup, shutdown, malfunction plan/reportd	2	1	2	81.2	162.4	8.12	16.24	$9,238.04
Notification of compliance statusc	1	1	1	1.6	1.6	0.08	0.16	$91
Semiannual excess emissions report	0.5	2	1	81.2	81.2	4.06	8.12	$4,619.02
TOTAL ANNUAL BURDEN AND COST (rounded)e					284			$14,000
a There are 78 existing EAF steelmaking facilities and we expect that there will be an average of 1.6 new facilities per year, for an annual average of 81.2 respondents per year.
b This ICR uses the following average hourly labor rates: $68.37 for managerial (GS-13, Step 5, $42.73 × 1.6), $50.72 (GS-12, Step 1, $31.70 × 1.6) for technical and $27.46 (GS-6, Step 3, $17.16 × 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) “2020 General Schedule” which excludes locality rates of pay.
c After full implementation, the agency is not expected to experience any burden from these activities because existing facilities are no longer expected to submit Initial notifications of applicability or Notifications of compliance status. 1.6 new facilities per year are expected to become subject to the rule over the 3-year period.
d This ICR assumes each source had one six-month period during each year that required a report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Number of Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents  (E=A+B+C-D)
1	1.6	78	0	0	79.6
2	1.6	79.6	0	0	81.2
3	1.6	81.2	0	0	82.8
Average	1.6	79.6	0	0	81.2
1 This ICR assumes there are 78 existing respondents, and approximately 5 new respondents over the next three years (or approximately 1.6 new respondents per year.)
Total Annual 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
Prepare scrap plan and scrap specifications	1.6	1	N/A	1.6
Initial performance tests	1.6	1	N/A	1.6
Notification of compliance status	1.6	1	N/A	1.6
Request for compliance extension	0	1	N/A	0
Notification of performance test	1.6	1	N/A	1.6
SSM report	81.2	1	N/A	81.2
Semiannual excess emissions reports	81.2	2	N/A	162.4
TOTAL (rounded)				250

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Sheet 4: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Performance Testing1	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&M	Total O&M, (E X F)
Method 5 Testing	$8,150	1.6	$13,040	$0	0	$0
Method 9 Testing	$1,510	1.6	$2,416	$0	0	$0
Total			$15,500			$0
1 We assume all new respondents will be required to conduct initial Method 5 and Method 9 testing. Both Method 5 and Method 9 testing are usually conducted by a contractor.
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.