Burden calculation tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Aluminum Reduction Plants (40 CFR Part 63, Subpart LL) (Renewal)
					$121.46	$148.45	$60.23
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person- hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarization with regulatory requirements c
New Sources	4	1	4	0	0	0	0	$0
Existing Sources	2	1	2	8	16	0.8	1.6	$2,158.49
B. Required activities
Acquisition, Installation, and Utilization of Technology and Systems	8	1	8	0	0	0	0	$0
Initial performance test d	100	1	100	0	0	0	0	$0
Annual performance tests d, e	100	13.09	1,309	8	10,472	523.6	1047.2	$1,412,730.40
Semiannual performance tests for TF and PM f, g	200	10	2,000	8	16,000	800	1,600	$2,158,488.00
Semiannual POM testing f, g	100	6.36	636	8	5,088	254.4	508.8	$686,399.18
Semiannual performance test (CEM or Alcan cassette) h, i	40	2.18	87.2	8	697.6	34.88	69.76	$94,110.08
Quarterly performance test j, k	200	16	3,200	0	0	0	0	$0
Daily Monitoring	2	730	1,460	8	11,680	584	1,168	$1,575,696.24
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report	See 3B
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/‌reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of performance test	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Design specifications for pitch storage tank controls l	46	1	46	0	0	0	0	$0
NESHAP waiver application	N/A
Report of performance test	See 3B
Report of monitoring exceedances m, n	16	2	32	0.8	25.6	1.28	2.56	$3,453.58
Report of no excess emissions m, o	8	2	16	7.2	115.2	5.76	11.52	$15,541.11
Malfunction report m, p	8	2	16	1	16	0.8	1.6	$2,158.49
Subtotal for Reporting Requirements					50,727			$5,950,736
4. Recordkeeping Requirements
A. Familiarization with regulatory requirements	See 3B
B. Plan activities	N/A
C. Implement activities (COS calculations)	1	11	11	8	88	4.4	8.8	$11,871.68
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards q	3	52	156	8	1,248	62.4	124.8	$168,362.06
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information m, r	1	2	2	8	16	0.8	1.6	$2,158.49
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					1,555			$182,392		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) s					52,300			$6,130,000		26	2012
TOTAL CAPITAL AND O&M COSTS (rounded) s								$310,000
GRAND TOTAL (rounded) s								$6,440,000
Assumptions:
a Assumes that there is an average of 8 respondents per year subject to the standards and that no additional respondents per year will become subject to the standards.
b This ICR uses the following labor rates for privately-owned sources: $148.45 for managerial, $121.46 for technical, and $60.23 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2020, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed all existing respondents will have to familiarize with the regulatory requirements each year.
d Assumes it takes 100 hours to complete each required TF, POM, PM, and Hg test for primary controls of potlines, bake furnaces and paste production plants.
e We assume an average of 13.09 tests per facility (primary control systems). This estimate is based on the Final Cost Impacts for the Primary Aluminum Production Source Category for the 2015 amendments which estimates: 35 potlines and 8 pitch storage tanks will require annual POM testing; 37 potlines, 12 anode bake furnaces, and 10 paste production plants will require annual PM testing; 12 anode bake furnaces will require annual Hg testing; and 30 potlines will require annual testing for TF (Note: there are a total of 37 potlines that require TF testing; however, 7 potlines are located in states that already required testing). (35+8+37+12+10+12+30 =144 tests at 11 facilities = 13.09 tests/facility).
f Assumes it takes 200 hours to test for secondary TF and PM emissions from potlines and 100 hours to test for secondary POM emissions from potlines.
g We assume an average of 10 tests per facility for PM and 6.36 tests per facility for POM secondary emissions from potlines. This estimate is based on the Final Cost Impacts for the Primary Aluminum Production Source Category for the 2015 amendments which estimates: 35 potlines will require semiannual POM testing; 37 potlines will require semiannual PM testing; and 18 potlines will require semiannual testing for TF (Note: there are a total of 37 potlines that require TF testing; however, 7 potlines are located in states that already required testing and 12 potlines do not have manifolds installed and will use the Method 14A Alcan Cassette test). [(37+18) x 2 tests/year = 110 TF and PM tests/year at 11 facilities = 10 tests/facility. 35 x 2 tests/yr = 70 POM tests/year at 11 facilities = 6.36 tests/facility].
h Assumes it takes 40 hours for testing of similar potlines (CEM or Alcan cassette).
i Assumes 2.18 tests per facility, based on estimates from the Final Cost Impacts for the Primary Aluminum Production Source Category for the 2015 amendments which estimates that 12 potlines will not have manifolds installed and will use Alcan Cassette tests. (12x2/11 = 2.18 tests/facility).
j Assumes it takes 200 hours for a Method 315 test for secondary emissions at Soderberg plants.
k Per the Final Cost Impacts for the Primary Aluminum Production Source Category for the 2015 amendments the only remaining Soderberg plant in the U.S. has announced permanent shutdown. Therefore, no Soderberg plants will require quarterly testing.
l Assumes that all existing sources have design specifications for pitch storage tank controls in place.
m This rule requires that all existing respondents submit semiannual reports. Performance test results will be submitted with the semiannual reports.
n Assumes that 10 percent of the 8 plants (0.1×8 = 0.8 will have excess emissions.
o Assumes that the remaining 90 percent of the 8 plants (0.9×8 = 7.2) will not have excess emissions.
p Assumes that 10 percent of plants per year (0.1×8 = 0.8, rounded to 1) will report a malfunction incident.
q Assumes it takes 3 hours per week per plant to enter monitoring data into records.
r Assumes it takes 1 hour to transmit recorded information.
s 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 Aluminum Reduction Plants (40 CFR Part 63, Subpart LL) (Renewal)
					50.72	68.37	27.46
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant-year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
New or reconstructed facilities c	2	1
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction and reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of compliance status	8	1	8	0	0	0	0	$0
Review design specifications for pitch storage tank controls d	10	1	10	0	0	0	0	$0
Existing facilities
Review of performance test report e	11	2	22	8	176	8.8	17.6	$10,011.67
Review of excess emissions report f	8	1	8	0.8	6.4	0.32	0.64	$364.06
Review of no excess emissions report g	2	2	4	7.2	28.8	1.44	2.88	$1,638.27
Review of NESHAP waiver application	N/A
Malfunction report h	2	1	2	1	2	0.1	0.2	$113.77
TOTAL (rounded) i					245			$12,100
Assumptions:
a Assumes that there is an average of 8 respondents per year subject to the standards and that no additional respondents per year will become subject to the standards.
b This ICR uses the following labor rates: $68.37 for managerial, $50.72 for technical, and $27.46 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Assumes that there are no new or reconstructed sources over the three-year period of this ICR.
d Assumes that all existing sources have design specifications for pitch storage tank controls in place.
e Assumes that it will take 11 hours twice per year to review summary of performance tests requirements to be submitted by all 11 existing plants.
f Assumes that 10 percent of the 8 plants (0.1×8 = 0.8 will have excess emissions.
g Assumes that the remaining 90 percent of the 8 plants (0.9×8 = 7.2) will not have excess emissions.
h Assumes that 10 percent of plants per year (0.1×8 = 0.8, rounded to 1) will report a malfunction incident.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

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	0	8	0	0	8
2	0	8	0	0	8
3	0	8	0	0	8
Average	0	8	0	0	8
1 New respondents include sources with constructed, reconstructed and modified affected facilities.
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&M	Total O&M, (E x F)
HF CEMs (similar potlines) a	$100,000	0	$0	$2,623	0	$0		CEPCI Index 1997:	386.5
Method 14 sampling manifolds at potlines b	$200,000	0	$0	$5,248	16	$83,972		CEPCI Index 2019:	607.5
Method 14A (alcan cassettes) sampling at potlines b	$92,000	0	$0	$2,414	11	$26,557
Install two manifold sampling systems at one facility c	$110,000	1	$110,000	$5,248	1	$5,248
Record storage d	$55	8	$440
PM testing on anode bake furnaces e				$5,625	8	$45,000
PM testing on paste production plants f				$5,625	7	$39,375
Totals (rounded) g			$110,000			$200,000	$310,000
a The previous ICR (1767.08) assumes that no respondents are using hydrogen fluoride CEMS for monitoring similar potlines.
b We assume 16 potlines will used Method 14 testing for TF and 11 potlines do not have manifolds installed and will use Method 14A Alcan Cassette testing. These values are based on adjustments to estimates from the Final Cost Impacts for the Primary Aluminum Production Source Category for the 2015 amendments, which estimated 30 potlines at 9 facilities will require TF testing, including 18 potlines with manifolds and 12 potlines without manifolds. We have adjusted these estimates to account for the lower number of facilities. O&M costs have been updated from 1997 dollars to 2019 dollars using the CEPCI CE Index.
c Per the revisions in the 2015 RTR, one facility is required to install two manifold sampling systems at a total cost of $1 million. Annualized at 7% for 15 years, the annual cost is $110,000 per year. Cost data is from "Final Cost Impacts for the Primary Aluminum Production Source Category", September 1, 2015, EPA-HQ-OAR-0797-0423.
d Per the revisions in the 2015 RTR, all eight facilities are required to install record storage systems at a total cost of $500 each, annualized at 7% for 15 years ($500 x capital recovery factor of 0.10979 = $55 annually).
e Per the revisions in the 2015 RTR, annual monitoring costs are estimated at $5,625/furnace/year. Cost data is from "Final Cost Impacts for the Primary Aluminum Production Source Category", September 1, 2015, EPA-HQ-OAR-0797-0423.
f Per the revisions in the 2015 RTR, annual monitoring costs are estimated at $5,625/plant/year. Cost data is from "Final Cost Impacts for the Primary Aluminum Production Source Category", September 1, 2015, EPA-HQ-OAR-0797-0423.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
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
Notification of applicability	0	1	N/A	0
Notification of construction/‌reconstruction	0	1	N/A	0
Notification of actual startup	0	1	N/A	0
Notification of initial performance test	0	1	N/A	0
Notification of compliance status/approach	0	1	N/A	0
Report of performance tests	8	1	N/A	8
Semiannual report of monitoring exceedances	0.8	2	N/A	1.6
Semiannual report of no excess emissions	7.2	2	N/A	14.4
Startup, shutdown, malfunction report	1	2	N/A	2
Submit a design specification for pitch storage tank controls	0	1	N/A	0
		Total (rounded)		26