Burden Calculation Table

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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 Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)
					122.66	149.84	60.88
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	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	16	1	16	2	32	1.6	3.2	$4,359.68
B. Required activities
Conduct PM performance test d	120	4.5	540	2	1,080	54	108	$147,139.20
Conduct copper converter building performance test e	240	1	240	2	480	24	48	$65,395.20
C. Create information	See 3B & 4E
D. Gather existing information	See 3B & 4E
E. Write Report
Initial notification	8	1	8	0	0	0	0	$0
Notification of performance test	2	5.5	11	2	22	1.1	2.2	$2,997.28
Initial compliance determination	40	1	40	0	0	0	0	$0
Performance test reports f	80	5.5	440	2	880	44	88	$119,891.20
Semiannual compliance reports g	40	2	80	2	160	8	16	$21,798.40
Startup, shutdown, malfunction report h	8	1	8	0	0	0	0	$0
Subtotal for Reporting Requirements					3,052			$361,581
4. Recordkeeping requirements
A. Familiarize with regulatory requirements c	40	1	40	2	80	4	8	$10,899.20
B. Plan activities	100	1	100	0	0	0	0	$0
C. Implement Activities
i. Prepare startup, shutdown, malfunction plan	80	1	80	0	0	0	0	$0
ii. Copper concentrate dryer
Monitor control device parameters i	0.5	365	182.5	2	365	18.25	36.5	$49,727.60
iii. Smelting vessel
Inspect tapping hood system j	4	12	48	2	96	4.8	9.6	$13,079.04
Monitor control device parameters i	0.5	365	182.5	2	365	18.25	36.5	$49,727.60
iv. Slag cleaning vessel
Inspect tapping hood system j, k	4	12	48	1	48	2.4	4.8	$6,539.52
Monitor control device parameters i, k	0.5	365	182.5	1	182.5	9.13	18.25	$24,863.80
v. Batch copper converters
Inspect converter hood system j	4	12	48	2	96	4.8	9.6	$13,079.04
Monitor hood system ventilation parameters i	0.5	365	182.5	2	365	18.25	36.5	$49,727.60
Monitor control device parameters i	0.5	365	182.5	2	365	18.25	36.5	$49,727.60
vi. Prepare fugitive dust control plan	100	1	100	0	0	0	0	$0
D. Develop record system	100	1	100	0	0	0	0	$0
E. Time to enter information l	1	365	365	2	730	36.5	73	$99,455.20
F. Time to train personnel m	100	1	100	2	200	10	20	$27,248.00
Subtotal for Recordkeeping Requirements					3,326			$394,074		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) n					6,380			$756,000		26	245.384615384615
CAPITAL AND O&M COST (rounded) n								$5,480
GRAND TOTAL (rounded) n								$761,000
Assumptions:
a We have assumed that there are approximately two sources that are subject to the standard, with no new additional sources expected 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 percent to account for the benefit packages available to those employed by private industry.
c We have assume that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that both of the respondents will take 120 hours, 4.5 times per year to conduct performance tests for PM as required under 40 CFR 63.1453.
e We have assumed that both of the respondents will take 240 hours to conduct copper converter building performance test once per year.
f We have assumed that each respondents will take eighty hours, 5.5 times per year to complete a performance test report.
g We have assumed that it will take each respondent forty hours to write the semiannual compliance reports.
h We have assumed no respondents will have a startup, shutdown, or malfunction that is not consistent with the SSM plan.
i Recordkeeping requirements are required daily on all monitor control device parameters.
j We have assumed that inspections on all hood systems are done on a monthly basis.
k We have assumed that one of the two existing sources will be equipped with a slag cleaning vessel.
l Each respondent is required to record information on a daily basis.
m We have assumed that it will take each of the respondent 100 hours to train personnel once a year.
n 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 Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)
					51.23	69.04	27.73
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants 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)	Cost, ($) b
Activity	N/A
Review reports
a. Initial notifications	2	1	2	0	0	0	0	$0
b. Notification of performance test c	2	5.5	11	2	22	1.1	2.2	$1,264.01
c. Initial compliance determination	8	1	8	0	0	0	0	$0
d. Performance test reports d	16	5.5	88	2	176	8.8	17.6	$10,112.08
e. Semiannual compliance reports e	8	2	16	2	32	1.6	3.2	$1,838.56
f. Report of SSM f	8	1	8	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded) g					265			$13,200
Assumptions:
a We have assumed that there are approximately two sources that are subject to the standard, with no new additional sources expected over the next three years.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 Managerial rate (GS-13, Step 5, $43.15 x 1.6), $51.23 Technical rate (GS-12, Step 1, $32.02 x 1.6), and $27.73 Clerical rate (GS-6, Step 3, $17.33 x 1.6). These rates are from the Office of Personnel Management (OPM) 2021 General Schedule which excludes locality rates of pay.
c We have assumed that EPA will take two hours to review each notification of performance test.
d We have assumed that EPA will take 16 hours to review each performance test report.
e We have assumed that EPA will take eight hours to review each semiannual compliance report.
f We have assumed no respondents will have a startup, shutdown, or malfunction that is not consistent with the SSM plan.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.