Burden Calculations

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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 Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal)
					122.66	149.84	60.88
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical Person-hours per occurrence	No. of occurrences per respondent per year	Technical 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)	Total Cost per year ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c	1	1	1	16	16	0.8	1.6	$2,179.84
B. Required Activities	N/A
Initial performance emission tests d	80	1	80	0	0	0	0	$0
Repeat of performance emission tests d	80	0.2	16	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Application of construction or modification	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Source status report	2	1	2	0	0	0	0	$0
Notification of initial performance emission test	2	1	2	0	0	0	0	$0
Report of initial performance emission test	See 3B
Report results of continuous monitoring system (CMS) evaluation	See 3B
Report of arsenic emission estimates e	16	2	32	15	480	24	48	$65,395.20
Report of uncontrolled arsenic emission rates f	8	2	16	15	240	12	24	$32,697.60
Request approval of control device bypass g	6	1	6	1	6	0.3	0.6	$817.44
Semiannual excess emissions (opacity) h	16	2	32	1	32	1.6	3.2	$4,359.68
Subtotal for Reporting Requirements					890			$105,450
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information i	40	1	40	16	640	32	64	$87,193.60
Record continuous opacity and temperature of gas entering control device	See 4E
Records of emission test results	See 4E
Records of CMS performance evaluations	See 4E
Occurrence and duration of startup, shutdown, and malfunction of furnace	See 4E
Records of malfunction of control device	See 4E
Periods when monitors are inoperative	See 4E
Maintain and repair of control device, CMS, or monitors	See 4E
Records of approved control device bypass	See 4E
Semiannual records of uncontrolled arsenic emission rate j	40	2	80	16	1,280	64	128	$174,387.20
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,208			$261,581		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) k					3,100			$367,000		63	49.2063492063492
TOTAL CAPITAL AND O&M COST (rounded) k								$56,000
GRAND TOTAL (rounded) k								$423,000
Assumptions:
a We have assumed that there are 16 existing sources, and that no additional new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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% to account for the benefit packages available to those employed by private industry.
c We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take eighty hours to complete performance tests and 20% of sources will have to repeat performance tests.
e We have assumed that fifteen respondents will write a report of arsenic emission estimates on a semiannual basis.
f We have assumed that fifteen respondents will write a report of uncontrolled arsenic emission rates on a semiannual basis.
g We have assumed that one respondent will write a report requesting approval of control device bypass once a year.
h We have assumed that one respondent will write an excess emissions report semiannually.
i It will take each respondent forty hours to enter information.
j It will take each respondent forty hours twice a year to record uncontrolled arsenic emission rate.
k Totals have been rounded to 3 significant values. 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 Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal)
					51.23	69.04	27.73
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical Person-hours per occurrence	No. of occurrences per year	Technical Person-hours per Plant 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)	Total Cost per year b
Activities
New facility
Initial performance test c	24	1	24	0	0	0	0	$0
Repeat performance test d	24	0.2	4.8	0	0	0	0	$0
Review reports
New facility
Construction or modification application	0.5	1	0.5	0	0	0	0	$0
Notification of anticipated startup	0.5	1	0.5	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Source status report	0.5	1	0.5	0	0	0	0	$0
Notification of initial performance emissions test	0.5	1	0.5	0	0	0	0	$0
Report of initial performance emissions test results	8	1	8	0	0	0	0	$0
Notification of physical or operational change	0.5	1	0.5	0	0	0	0	$0
Notification of emissions test	0.5	1	0.5	0	0	0	0	$0
Report results of CMS evaluation	8	1	8	0	0	0	0	$0
Existing facility
Report of arsenic emission estimates rates e	4	1	4	15	60	3	6	$3,447.30
Reports of uncontrolled arsenic emission rates f	8	1	8	15	120	6	12	$6,894.60
Semiannual excess emissions g	6	2	12	1	12	0.6	1.2	$689.46
Request approval of control device bypass h	6	1	6	1	6	0.3	0.6	$344.73
TOTAL LABOR BURDEN AND COST (rounded) i					228			$11,400
Assumptions:
a We have assumed that there are 16 existing sources, and that no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 (GS-13, Step 5, $43.15 + 60%) for managerial, $51.23 (GS-12, Step 1, $32.02 + 60%) for Technical, and $27.73 (GS-6, Step 3, $17.33 + 60%) for Clerical. These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c We have assumed that it will take twenty four hours to perform initial performance test.
d We have assumed that 20% of sources will take twenty four hours to repeat performance test.
e We have assumed that reports submitted by the fifteen respondents will be reviewed once a year. These reports are submitted semiannually.
f We have assumed that it will take eight hours to review reports of uncontrolled arsenic emission rates once a year. These reports are submitted semiannually.
g It is required that excess emissions reports are reviewed on a semiannual basis.
h We have assumed that the report requesting approval of control device bypass will be reviewed once a year.
i Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.