Burden Calculations Table

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Overview

Industry
Agency

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Sheet 1: Industry

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per yeara	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with rule requirementsc	1	1	1	13	13	0.65	1.3	$1,771.12
B. Required activities
Performance tests d	194	1	194	0	0	0	0	$0
Repeat of performance test e	194	1	194	0	0	0	0	$0
Daily monitoring of emissions and operations	See 4E
C. Create information	See 3B and 4E
D. Gather existing information	See 3B and 4E
E. Write Report
Notification of reconstruction or modification	2	1	2	0	0	0	0	$0
Notification of performance test	2	1	2	0	0	0	0	$0
Performance test results	32	1	32	0	0	0	0	$0
Semiannual report of excess emissions f	10	2	20	13	260	13	26	$35,422.40
Subtotal for Reporting Requirements					314			$37,194
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of operating parameters
- Exhaust ventilation rate g	0.25	365	91.25	13	1,186.3	59.31	118.63	$161,614.70
-     Across the venture scrubber (i.e., pressure drop and water supply pressure) h	0.25	365	91.25	11	1,003.75	50.19	100.38	$136,750.90
Records of performance test	See 3B
Records of duration of each steel production cycle, and time and duration of any diversion of exhaust gases from the main stack serving the BOPF i	0.25	365	91.25	13	1,186.3	59.31	118.63	$161,614.70
Recalibrate and check monitoring devices j	8	1	8	13	104	5.2	10.4	$14,168.96
F. Time to train personnel
-          Certification of opacity observer k	8	2	16	13	208	10.4	20.8	$28,337.92
a We have assumed that there are approximately 13 respondents (i.e., BOPF shops) that are subject to the regulation, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
Subtotal for Recordkeeping Requirements					4,241			$502,487
TOTAL LABOR BURDEN AND COST (rounded)l					4,560			$540,000
TOTAL CAPITAL AND O&M COST (rounded)l								$21,600
GRAND TOTAL (rounded)l								$562,000
Assumptions:										175	hr per resp
a We have assumed that there are approximately 13 respondents (i.e., BOPF shops) that are subject to the regulation, with no additional new or reconstructed sources becoming 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 groups. 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 that it will take one hour for each respondent to familiarize with rule requirements.
d We have assumed that it will take 194 hours for each respondent to complete a performance test. This is a one time requirement.
e We have assumed that it will take 10 percent of respondents to repeat performance test due to failures. This is a one time requirement.
f We have assumed that it will take 10 hours twice per year for each respondent to write the semiannual reports if excess emission.
g We have assumed that it will take each of the 13 respondent 0.25 hours, 365 times per year, to record the exhaust ventilation rate.
h We have assumed eleven of the existing respondents will use venturi scrubbers as primary emission control systems. We have assumed that it will take each of the eleven respondent 0.25 hours, 365 times per year, will enter information on records of CMS operating parameters across the venturi scrubber.
i We have assumed that it will take each respondent 0.25 hours, 365 days per year, to record the duration of each steel production cycle.
j We have assumed that it will take each respondent eight hours once per year to recalibrate and check monitoring devices.
k We have assumed that it will take each respondent eight hours twice per year to train personnel on certification of opacity observer.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per yeara	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person-hours per year (E x 0.1)	(H) Cost, $b
New facility
Notification of performance test c	2	1	2	0	0	0	0	$0
Report of performance test results d	8	1	8	0	0	0	0	$0
Notification of reconstruction/modification e	2	1	2	0	0	0	0	$0
Review reports: Existing and new sources
Semiannual reports of excess emissions and monitoring systems performance f	5	2	10	13	130	6.5	13	$7,469.15
TOTAL ANNUAL BURDEN AND COST (rounded)g					150			$7,470
Assumptions:
a We have assumed that there are approximately 13 respondents (i.e., BOPF shops) that are subject to the regulation, with no additional new or reconstructed sources becoming 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 for Managerial, $51.23 for Technical and $27.73 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 two hours once per year for each respondent to perform the performance test. This is a one-time requirement.
d We have assumed that it will take eight hours once per year for each respondent to report the performance test results. This is a one-time requirement.
e We have assumed that it will take two hours once per year for each respondent to comply with the notification requirements of the rule. This is a one-time requirement.
f We have assumed that it will take five hours twice per year for each respondent to submit semiannual reports of excess emissions and monitoring systems with all measurements over any three hour period (e.g., of low pressure) that average more than 10 percent below the averages during the most recent performance test.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.