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 the Secondary Lead Smelter Industry (40 CFR Part 63, Subpart X) (Renewal)
Burden item	(A) Person-hours per occurrence	(B) Annual occurrences per respondent	(C) Person-hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical hours per year (C x D)	(F) Management hours per year (E x 0.05)	(G) Clerical hours per year (E x 0.10)	(H) Annual cost ($) b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Managerial	$149.84
3. Reporting requirements										Technical	$122.66
A. Familiarization with the regulatory requirements a	1	1	1	12	12	0.6	1.2	$1,634.88		Clerical	$60.88
B. Required activitiesc
Annual performance test	330	1	330	12	3,960	198	396	$539,510.40
THC testing	10	1	10	12	120	6	12	$16,348.80
Dioxin/furan testing	10	1	10	2	20	1	2	$2,724.80
Lead testing	10	0.5	5	6	30	1.5	3	$4,087.20
Continuous particulate monitor	1	52	52	12	624	31.2	62.4	$85,013.76
Differential pressure monitor	2	1	2	24	48	2.4	4.8	$6,539.52
Inspect capture hoods	8	12	96	12	1,152	57.6	115.2	$156,948.48	Monthly requirement per 63.544(d)
Inspect and repair enclosures	20	12	240	12	2,880	144	288	$392,371.20	Monthly requirement per 63.544(d)
Inspect battery storage areas	8	52	416	12	4,992	249.6	499.2	$680,110.08	Weekly requirement per 63.545(c)(4)
Revise SOP manual d	20	1	20	1	20	1	2	$2,724.80	Requirement to report any time SOP Manual is changed in §63.545(b)
C. Create information	See 3B
D. Gather information	See 3E
E. Report preparation
Notification of performance test e	2	2	4	12	48	2.4	4.8	$6,539.52
Semiannual compliance report	16	2	32	12	384	19.2	38.4	$52,316.16
Annual (performance test) report e	10	2	20	12	240	12	24	$32,697.60
Differential pressure monitoring report f	10	1	10	12	120	6	12	$16,348.80
Reporting Subtotal					16,848			$1,995,916
1. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 3A
B. Implement activities	N/A
C. Develop record system	N/A
D. Record information
Fugitives	1	12	12	12	144	7.2	14.4	$19,618.56
Flow weighted averages for lead	1	1	1	12	12	0.6	1.2	$1,634.88
Continuous particulate monitor	1	52	52	12	624	31.2	62.4	$85,013.76
Differential pressure monitors	1	12	12	24	288	14.4	28.8	$39,237.12
Power outages	1	12	12	12	144	7.2	14.4	$19,618.56
Facility enclosure inspections	1	12	12	12	144	7.2	14.4	$19,618.56
Startup and shutdown periods	1	12	12	12	144	7.2	14.4	$19,618.56
Malfunctions	2	6	12	12	144	7.2	14.4	$19,618.56
Actions taken during malfunctions	1	6	6	12	72	3.6	7.2	$9,809.28
Bag Leak Detection System	1	12	12	12	144	7.2	14.4	$19,618.56
Furnace inspections	1	12	12	12	144	7.2	14.4	$19,618.56
Plastic battery casing material recovery	1	6	6	12	72	3.6	7.2	$9,809.28
Monitoring parameters, performance tests, and periodic inspections	3.5	52	182	12	2,184	109.2	218.4	$297,548.16
E. Personnel training	8	1	8	0	0	0	0	$0
F. Time for audits	N/A
Recordkeeping Subtotal					4,899			$580,382
Total Labor Burden and Costs (rounded) g					21,700			$2,580,000		255	hours per response
Total Capital and O&M Cost (rounded) g								$251,000
GRAND TOTAL (rounded) g								$2,830,000
Assumptions:
a EPA estimates an average of 12 existing facilities and no new or modified facilities per year will be subject to the NESHAP over the next 3 years. In addition to the 12 active facilities there is one inactive facility that has been idled since 2013. We assume that each source subject to the standard will have to familiarize with the regulatory requirements each year. Since there are no new or modified/reconstructed facilities expected the notifications for startup, intention to construct/reconstruct, notification of applicability and notification of initial compliance will not occur during this three-year ICR period.
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 Testing frequency was assumed as follows, based on rule requirements and experience with the affected source actual testing schedule. THC testing is conducted annually. Dioxin/Furan tests are required every 6 years, and this ICR assumes 2 of the 12 sources conduct dioxin/furan tests each year. Lead testing is required annually but many sources requests extensions for this test and the tests occur every two years. This ICR assumes 6 of the 12 sources conduct lead tests each year. The ICR estimates that all sources have continuous particulate monitors and that two differential pressure monitors exist per source. Since all sources have continuous particulate monitors, the visible emission observation requirement in the rule is not accounted for in the burden estimate. In addition, each facility must conduct monthly inspections of capture hoods and enclosures, and weekly inspections of battery storage areas that are not in enclosures.
d EPA assumes each facility will make one major adjustment per year. In each instance, the SOP must be revised.
e Performance test data and performance evaluation data must be developed using EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI). EPA assumes one notification and one test report for each test conducted will be submitted. There are 20 tests for the 12 sources, 20/12 = 1.67, or 2 responses per respondent for each of these activities.
f EPA assumes that one report will be submitted for all differential pressure monitors at the facility.
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 the Secondary Lead Smelter Industry (40 CFR Part 63, Subpart X) (Renewal)
Burden item	(A) EPA person-hours per occurrence	(B) Annual occurrences per respondent	(C) EPA person-hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical hours per year (C x D)	(F) Management hours per year (E x 0.05)	(G) Clerical hours per year (E x 0.10)	(H) Annual cost ($) b
1. Applications	N/A									Labor Rates
2. Required activities										Managerial	$69.04
A. Observe stack tests c	48	1	48	4	192	9.6	19.2	$11,031.36		Technical	$51.23
B. Excess emissions - enforcement activities d	24	1	24	1	96	4.8	9.6	$5,515.68		Clerical	$27.73
C. Create information	N/A
D. Gather information	N/A
E. Report reviews
Notification of performance test	3	2	6	12	72	3.6	7.2	$4,136.76
Semiannual report	10	2	20	12	240	12	24	$13,789.20
Annual report	10	2	20	12	240	12	24	$13,789.20
Differential pressure monitoring report	3	1	3	12	36	1.8	3.6	$2,068.38
F. Prepare annual summary report e	4	12	48	1	48	2.4	4.8	$2,757.84
TOTAL (rounded) f					1,063			$53,100
Assumptions:
a EPA estimates an average of 12 existing facilities and no new facilities per year will be subject to the NESHAP over the next 3 years.
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 EPA assumes Agency personnel will attend 20% of facility stack tests (0.2 x 20 tests on average across the 12 facilities = 4, after rounding).
d EPA assumes 10% of facilities will have excess emissions (0.1 x 12 = 1, after rounding).
e EPA assumes state and EPA personnel will require 4 technical hours per respondent when preparing the annual summary report (12 x 4 = 48).
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

Capital/Startup and O&M Costs (taken directly from prev ICR burden tables, columns B, C, and K)
Burden item	Stack Testing Cost Per Occurrence*	Other Non-Labor Costs Per Occurrence*	Annual occurrences per respondent	Respondents per year a
THC testing	$4,700		1	12
Dioxin/furan testing	$19,300		1	2	test occurs every 6 years so assume 2 respondents per year
Lead testing	$10,000		1	6	lead testing is every year with the option for requesting an extension to every 24 months, or 6 sources per year
Differential pressure monitor (initial capital)		$2,300	1	0
Differential pressure monitor (annual O&M)		$230	1	12
HEPA filter monitor (initial capital)		$32,759	1	0
HEPA filter monitor (annual O&M)		$4,665	1	0
*Costs in red were tallied as O&M in prev ICR (1686.11).
Rows highlighted in blue denote new items added to burden calculations.
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)
THC testing	$0	0	$0	$4,700	12	$56,400		changed to match latest facility inventory
Dioxin/furan testing a	$0	0	$0	$19,300	2	$38,600		required every 6 years, so 12 sources/6 years = 2. This should not have been zero previously.
Lead testing b	$0	0	$0	$10,000	6	$60,000		changed to match latest facility inventory, divided by 2 per note about extension
Continuous particulate monitor c	$0	0	$0	$7,500	12	$90,000		changed to match latest facility inventory
Differential pressure monitor d	$2,300	0	$0	$230	24	$5,520		change this to 24, assuming two differential pressure monitors per facility.
HEPA filter monitor	$32,759	0	$0	$4,665	0	$0
Total e	$35,059		$0	$46,395		$251,000
a Dioxin/Furan testing occurs every 6 years, or 12 facilities/6 years = 2 facilities per year.
b Lead testing is required annually, but there are provisions by which facilities can apply for an extension. This ICR assumes all facilities will apply for an extension to test once every 24 months. 12 facilities/2 years = 6 facilities per year conducting lead testing.
c EPA has assumed that all facilities will have CPMs.
d EPA has assumed that each facility will have two differential pressure monitors.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	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	12	0	0	12
2	0	12	0	0	12
3	0	12	0	0	12
Average	0	12	0	0	12
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.
Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of Performance Test	12	2	0	24
Semiannual compliance report	12	2	0	24
Annual (performance test) report	12	2	0	24
Differential pressure monitoring report	12	1	0	12
Revised Standard Operating Procedures Manual	1	1	0	1
			Total	85