Burden Calculation 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 Primary Lead Smelting (40 CFR Part 63, Subpart TTT) (Renewal)
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 year a	(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									Labor Costs
2. Survey and Studies	N/A									Managerial	$149.84
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									Technical	$122.66
4. Reporting Requirements										Clerical	$60.88
A. Familiarization with Regulatory Requirements	2	1	2	1	2	0.1	0.2	$272.48
B. Required activities:
i. Initial Performance tests: c	8	1	8	0	0	0	0	$0
ii. Monitoring of operations and equipment: d
- Implement baghouses SOP	13.4	365	4,891	1	4,891	245	489	$666,349.84
- Quarterly compliance stack tests for lead compounds
Main stack	8	4	32	1	32	1.6	3.2	$4,359.68
Furnace area stack	8	4	32	1	32	1.6	3.2	$4,359.68
Refining building stack	8	4	32	1	32	1.6	3.2	$4,359.68
D. Gather Existing Information	See 4B and 5E
E. Write report c
i. Notification of compliance status c	2	1	2	0	0	0	0	$0
ii. Notification of actual startup c	2	1	2	0	0	0	0	$0
iii. Notification of construction/ reconstruction c	2	1	2	0	0	0	0	$0
iv. Notification of Performance Test c	2	1	2	0	0	0	0	$0
v. Notification of actual startup c	2	1	2	0	0	0	0	$0
vi. Reports of performance test results	4	1	4	0	0	0	0	$0
vii. Operation and maintenance reports	10	1	10	0	0	0	0	$0
viii. Semi-annual reports e	16	2	32	1	32	1.6	3.2	$4,359.68
ix. Notification of physical/operational changes f	2	1	2	0	0	0	0	$0
x. Submit quarterly reports	16	4	64	1	64	3.2	6.4	$8,719.36
Subtotal for Reporting Requirements					5,848			$692,780
5. Recordkeeping Requirements
A. Familiarize with Regulatory Requirements	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system	N/A
E. Time to enter and transmit information:	1	365	365	1	365	18.3	36.5	$49,727.60
- Records of operating parameters
- Records of compliance inspections
- Records of performance tests
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					420			$49,728
Total Labor Burden and Costs (rounded) g					6,270			$743,000
Total Capital and O&M Cost (rounded) g								$169,000
GRAND TOTAL (rounded) g								$912,000		1045	hrs/response
Assumptions:
a While no sources are currently subject to the standard, for the purposes of this ICR, we have assumed that there is an estimated average one existing respondent which is subject to NSPS Subpart TTT since it is still in effect. We have assumed that there will be no new net growth for this industry over the three-year period of this ICR.
b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c Since there are no new sources, the initial rule requirements do not apply (e.g. initial performance test using Method 12 for lead emissions and initial sinter building in-draft compliance demonstration).
d Monitoring of operations includes: 1) implementation of Standard Operating Procedures (SOP) for operation and maintenance of baghouses on a daily basis such that its bag leak detection system does not alarm more than five percent of the time in any 6-month period, which we have assumed takes about 13.4 labor hours per 24 hour day to implement the monitoring and recordkeeping requirements; 2) a quarterly compliance tests for lead compounds; 3) and the monitoring of sinter building in-draft for which the operators are given three options to comply including: daily checks for in-draft at all doorway openings using an anemometer or equivalent device; establish and maintain the ventilation exhaust rate and damper positions at settings that result in an in-draft at each open doorway; or an alternative monitoring method.
e We have assumed that sources will continue to submit semiannual reports.
f We are assuming that sources will not be changing operating parameters even when sources may purchase new equipment.
g 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 Lead Smelting (40 CFR Part 63, Subpart TTT) (Renewal)
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 year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Initial notification c	2	1	2	0	0	0	0	$0		Labor Rates
Notification of performance test c	0.5	4	2	0	0	0	0	$0		Managerial	$69.04
Notification of physical or Operational changes c	4	1	4	0	0	0	0	$0		Technical	$51.23
Semi-annual reports	10	2	20	1	20	1	2	$1,149.10		Clerical	$27.73
Review quarterly test results	8	4	32	1	32	1.6	3.2	$1,838.56
TOTAL (rounded)d:					60			$2,990
Assumptions:
a While no sources are currently subject to the standard, for the purposes of this ICR, we have assumed that there is an average of one existing respondent currently operating in the United States since the NSPS Subpart TTT rule is still in effect. It is estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector.
b This ICR uses the following labor rates: $51.23 (technical), $69.04 (managerial), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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 While no sources are currently subject to the standard, for the purposes of this ICR burden, we have not included an estimate for any of the initial rule requirements.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

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)
Bag Leak detection system - continuous particulate matter sensor a	$10,500	0	$0	$6,500	1	$6,500
Flow monitors with high/low alarms a	$6,500	0	$0	$6,500	1	$6,500
Method 12 Performance Tests b	N/A		N/A	$156,000	1	$156,000
TOTAL c			$0			$169,000
a Assumption: $500 per year per monitoring system per baghouse; we assume the respondent has 13 baghouses.
b Assumption: $13,000 per test per stack, 12 tests per year across 3 stacks.
c 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
Quarterly Reports	1	4	0	4
Semiannual Reports	1	2	0	2
			Total	6
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	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	1	0	0	1
2	0	1	0	0	1
3	0	1	0	0	1
Average	0	1	0	0	1