Burden Calculations Table

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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 Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal)
Burden item	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (A x B)	(D) Respondents per yeara	(E) Technical person-hour per year (C x D)	(F) Management person-hour per year (E x 0.05)	(G) Clerical person-hour per year (E x 0.10)	(H) Total Cost per year
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$148.45
3. Acquisition, Installation, & Utilization of Tech. & Systemsb	40	1	40	0	0	0	0	$0		Technical	$121.46
4. Reporting Requirements										Clerical	$60.23
A. Familiarize with regulatory requirementsc	4	1	4	9	36	1.8	3.6	$4,856.60
B. Required Activities
One-time activity, Initial control device Method 22 Planning	N/A
One-time activity, Initial control device Method 22 Test	N/A
Periodic control device Method 22d	2	2	4	18	72	3.6	7.2	$9,713.20
Retest control deviced	2	1	2	1	2	0.1	0.2	$269.81
Weekly VE checkd	0.1	52	5.2	18	93.6	4.68	9.36	$12,627.15
One-time activity, initial building opacity Method 9e	N/A
Periodic (semi-annual) building VE Method 22d	2	2	4	9	36	1.8	3.6	$4,856.60
Retest building opacity Method 9e	N/A
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write Report	See 4B
Initial Notificationb	2	1	2	0	0	0	0	$0
Notification of Compliance Statusb	4	1	4	0	0	0	0	$0
Annual Compliance Certification f	4	1	4	9	36	1.8	3.6	$4,856.60
Report of Exceedancesg	2	1	2	2	4	0.2	0.4	$539.62
Subtotal for Reporting Requirements					322			$37,720
5. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information
Records of all info. required by standardsh	0.3	12	3.6	9	32.4	1.62	3.24	$4,370.94
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply w/ prev. appl. req.	N/A
H. Time to transmit or disclose informationi	0.3	1	0.3	9	2.7	0.135	0.27	$364.24
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					40			$4,735
Total Labor Burden and Costs (rounded) j					362			$42,500			Previous ICR:
Total Capital and O&M Cost (rounded) j								$0			391 hr
GRAND TOTAL (rounded) j								$42,500			$41,100
											33	hr/response
Assumptions:
a 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.
b This is a one-time activity and there are no new sources anticipated to become subject to the standard during this ICR renewal period.
c We have assumed that there are approximately 9 existing sources that are subject to the standard, with no new facilities per year. We assume that each respondent will have to familiarize with the regulatory requirements each year.
d We have estimated 18 control devices requiring Method 22 testing and visual emission inspection at the 9 existing sources. It is also assumed that one of these control devices will require a re-test. On building-wide testing, it is assumed that each of the 9 existing sources has one building per source and that all buildings will require a re-test.
e One-time activity. Assume the facilities hire a contractor.
f The 9 existing plants would be required to submit an Annual Compliance Certification each year.
g Assumes that 2 facilities per year would have to submit a report of exceedance.
h Recordkeeping requirements cover all existing plants.
i Transmittals would include Annual Compliance Certifications for 9 plants.
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: Annual Agency Burden and Cost -NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal)
Activity	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (A x B)	(D) Respondents per year	(E) Technical person-hours (C x D)	(F) Managerial person-hours (E x 0.05)	(G) Clerical person-hours (E x 0.10)	(H) Cost, $a
Report Review:										Labor Rates
Initial Notification of applicabilityb	1	1	1	0	0	0	0	$0		Management	$68.37
Notification of Compliance Statusc	2	1	2	0	0	0	0	$0		Technical	$50.72
Annual Compliance Certificationd	2	1	2	9	18	1	1.8	$1,023.92		Clerical	$27.46
Annual Report of Deviationse	2	1	2	2	4	0.2	0.4	$227.54
TOTAL (rounded) f					25			$1,250
Assumptions:
a 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.
b This is a one-time requirement. All 9 plants have already submitted initial notification during the initial compliance period.
c This is a one-time requirement. All 9 plants have submitted the notification of compliance status during the initial compliance period.
d All 10 plants will submit an annual compliance certification each year.
e  Assumes that 2 facilities per year would have to submit an exceedance report per year.
f 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
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	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	9	0	0	9
2	0	9	0	0	9
3	0	9	0	0	9
Average	0	9	0	0	9
a New respondents include sources with constructed, reconstructed and modified affected facilities.
(ii) Estimating Capital/Startup and Operation and Maintenance Costs
The only costs to the regulated industry resulting from information collection activities required by the subject standards are labor costs. There are no capital/startup or operation and maintenance costs.
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
One-time initial notification	0	1	0	0
One-time notifications of compliance status	0	1	0	0
Annual compliance certifications	9	1	0	9
Annual reports of exceedances	2	1	0	2
TOTAL				11