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 Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal)
Burden item	A	B	C	D	E	F	G	H	Footnotes
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Reporting Requirements
A. Familiarize with Regulatory Requirements	4	1	4	2	8	0.4	0.8	$1,088.23
B. Required activities											Labor Rates
a. Initial performance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace, capture systems - Fabric Filter	15	3	45	0	0	0	0	$0	c		Management	$153.55
b. Initial performance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace, capture systems - Scrubber	15	2	30	0	0	0	0	$0	c		Technical	$122.20
c. Initial performance test (PM) - Local ventilation, Metal Oxygen Refining (MOR) process, crushing and screening	20	4	80	0	0	0	0	$0	d		Clerical	$61.51
d. Periodic performance tests for submerged arc furnace control devices
i. Annual wet scrubber PM tests (furnace)	15	2.5	37.5	2	75	3.8	7.5	$10,202.14	e
ii. Annual Hg tests for wet scrubber, fabric filter, and vent stacks (furnace)									e
iii. Annual PAH tests for wet scrubber, fabric filter, and vent stacks (ferromanganese furnaces)									e, f
iv. PM tests for fabric filters every five years (furnace)	15	0.5	7.5	2	15.0	0.75	1.50	$2,040.43	g
v. HCl test every five years (furnace)
vi. Formaldehyde test every five years (furnace)
vii. Capture system test every five years (furnace)
viii. Local ventilation test every five years	20	0.5	10	2	20	1.0	2.0	$2,720.57	g
ix. MOR process test every five years
x. Crushing and screening equipment test every five years
e. Non-furnace baghouse observations and inspections									h
i. Daily visible emissions observations	0.5	350	175	2	350	18	35	$47,609.98
ii. Weekly confirmation of dust removal	0.1	50	5	2	10	0.5	1.0	$1,360.29
iii. Monthly check of bag cleaning mechanisms	0.1	12	1.2	2	2	0.1	0.2	$326.47
iv. Quarterly baghouse integrity checks	0.1	4	0.4	2	1	0.0	0.1	$108.82
v. Semiannual baghouse inspections	0.1	2	0.2	2	0	0.0	0.0	$54.41
f. Furnace baghouse bag leak detection system (annual O&M)	4	2	8	2	16	0.8	1.6	$2,176.46	i
g. Pressure drop/liquid flow rate CPMS-scrubber (annual O&M)	2	1	2	1	2	0.1	0.2	$272.06	j
h. Weekly Method 9 (Opacity)	2	156	312	2	624	31	62	$84,881.78	k
i. Ductwork flowrate monitoring (annual O&M)	2	1	2	2	4	0.2	0.4	$544.11	l
j. Furnace capture system inspection (Quarterly)	2	4	8	2	16	1	2	$2,176.46	m
C. Create information	See 1B
D. Gather information	See 1B
E. Report preparation
a. Initial Notifications	N/A
b. Notification of construction/reconstruction	N/A
c. Notification of compliance status	4	1	4	0	0	0	0	$0
d. Notification of performance test	2	1	2	2	4	0.2	0.4	$544.11
e. Notification of opacity observations	2	1	2	2	4	0.2	0.4	$544.11
f. Notification of change in information already provided	2	0.33	0.66	2	1	0.1	0.1	$179.56	n
g. Report of performance tests, opacity observations	5	1	5	2	10	0.5	1.0	$1,360.29
h. Process fugitive emissions ventilation plan
i. Develop and submit plan	80	1	80	0	0	0	0	$0	o
ii. Report deviations from plan	See 1.E.o								p
iii. Update plan	See 1.E.o								q
i. Outdoor fugitive dust control plan
i. Develop and submit plan	10	1	10	0	0	0	0	$0	o
ii. Report deviations from plan	See 1.E.o								p
j. Bag leak detection system
i. Develop plan	20	1	20	0	0	0	0	$0	o
ii. Report alarms and actions taken in response	See 1.E.o								p
k. Monitoring SOP manual for baghouses controlling process vents, process fugitive, or outdoor fugitive dust
i. Develop and submit manual	10	1	10	0	0	0	0	$0	o
ii. Report deviations from plan	See 1.E.o								p
l. Report deviations from established parameters for pressure drop and flow rate in scrubbers controlling PM	See 1.E.o
m. Report shop building capture system monitoring and deviations	See 1.E.o								p
n. Reports of the results of quarterly inspections of the furnace capture system	4	4	16	2	32	1.6	3.2	$4,352.91
o. Reports of deviations, alarms, actions taken, malfunctions, and exceedances	10	1	10	2	20	1.0	2.0	$2,720.57	p, r
p. Annual compliance certification	10	1	10	2	20	1.0	2.0	$2,720.57	s
Subtotal for Reporting Requirements					1,420			$167,984
2. Recordkeeping Requirements
A. Familiarize with Regulatory Requirements	See 1A
B. Implement activities	See 1B
C. Develop record system	NA
E. Records of information required by standards
a. Bag leak detection system: output, alarms, corrective actions	1	1	1	2	2	0.1	0	$272.06
b. Baghouses without leak detection systems: inspection and maintenance records	2	20	40	2	80	4	8	$10,882.28
c. Wet scrubbers: pressure drop, water flow rate, deviations, corrective actions	2	1	2	1	2	0.10	0.2	$272.06
d. Shop building capture system: monitoring, deviations, corrective actions	2	1	2	2	4	0.20	0.4	$544.11
e. Inspections of the furnace capture system (quarterly)	2	4	8	2	16.0	0.80	1.60	$2,176.46
f. Records of startup and/or shutdown.	1	1	1	2	2.0	0.10	0.20	$272.06
g. Records of malfunctions and exceedances	2	1	2	2	4.0	0.20	0.40	$544.11
h. Deviations from process fugitive emissions ventilation plan	1	1	1	2	2	0.10	0.2	$272.06
i. Deviations from outdoor fugitive dust control plan	1	1	1	2	2	0.1	0.2	$272.06
j. Deviations from monitoring SOP manual for baghouses	1	1	1	2	2	0.1	0.2	$272.06
k. Records of performance tests	2	2.5	5	2	10	1	1	$1,360.29
F. Personnel training	20	1	20	2	40	2.0	4.0	$5,441.14
G. Time for audits	NA
Subtotal for Recordkeeping Requirements					191			$17,140			responses	hr/response
Total Labor Burden and Cost (rounded) t					1,610			$185,000			19	86
Total Capital and O&M Costs (rounded) t								$424,000
GRAND TOTAL (rounded) t								$609,000			1831.07
											20	59
Assumptions:											2448.02
a There are two ferroalloy production facilities currently subject to the standard. We assume no additional respondents will become subject to this regulation in the three-year period of this ICR.											11	36
b This ICR uses the following labor rates: $153.55 per hour for Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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 There are a total of six operating furnaces at these two sources. Four furnaces are controlled with fabric filters and two furnaces are controlled with a single venturi scrubber. The fabric filter baghouses controlling the arc furnaces are required to have bag leak detection systems.
d There are a total of seven local ventilation, MOR process, and crushing/screening operations controlled by baghouses at these two sources.
e There are six operating furnaces at these two sources controlled by five control devices (four fabric filters and one scrubber (5/2=2.5)). Each furnace is tested annually.
f We assume that all six ferromanganese furnaces have demonstrated compliance with the PAH standard in four consecutive tests and have petitioned the operating authority to reduce testing frequency to an annual basis.
g This testing is done every five years. We assume these tests will be done simultaneously with the annual test. This row calculates the average cost per year over five years (five furnace control systems will be tested at two sources every five years). At these two sources, there are a total of three shop buildings (local ventilation), one MOR process, and three crushing/screening operations, each controlled by baghouses.
h Each source has non-furnace operations (crushing and screening, MOR process, building ventilation) that are controlled by baghouses. These observations, inspections, and maintenance get performed on the schedule shown.
i At the two sources, there are a total of four arc furnaces each controlled by a single baghouse. These baghouses use bag leak detection systems.
j One source operates a scrubber controlling two arc furnaces.
k We assume each respondent will perform weekly opacity readings on three non-furnace facilities. (3 x 52 = 156)
l The ductwork flowrate monitoring is for determining compliance with the shop building opacity standard at 40 CFR 63.1623 and 63.1626(h).
m The capture systems collecting emissions from the six arc furnaces are inspected for proper functioning annually.
n We assume sources will make changes to information previously reported once every three years.
o These plans and manuals were developed and submitted during the first year after the most recent amendments were promulgated.
p We assume that both respondents will report deviations from these plans and parameters each year during the three-year period of this ICR.
q Respondents are required to update the process fugitive emissions ventilation plan every 5 years.
r We assume that 2 respondents per year will need to submit a Report of Exceedance.
s Each respondent is required to submit an Annual Compliance Certification each year.
t 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 Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
Report reviews										Labor Rates
Notification of performance test	1	1	1	2	2	0.1	0.2	$114.91		Management	$69.04
Notification of opacity observations	1	1	1	2	2	0.1	0.2	$114.91		Technical	$51.23
Notification of change in information already provided	1	0.33	0.3	2	1	0.03	0.1	$37.92		Clerical	$27.73
Report of performance tests, opacity observations	5	1	5	2	10	0.5	1	$574.55
Reports of the results of quarterly inspections of the furnace capture system	2	4	8	2	16	0.8	1.6	$919.28
Reports of deviations, alarms, actions taken, malfunctions, and exceedances	14	1	14	2	28	1.4	2.8	$1,608.74
Annual compliance certification	2	1	2	2	4	0.2	0.4	$229.82
TOTALS (rounded) c					72			$3,600
Assumptions:
a There are two ferroalloy production facilities currently subject to the standard. We assume no additional respondents will become subject to this regulation in the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.03 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 3: O&M

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
Initial Notifications	0	0	0	0
Notification of construction/reconstruction	0	0	0	0
Notification of compliance status	0	1	0	0
Notification of performance test	2	1	0	2
Notification of opacity observations	2	1	0	2
Notification of change in information already provided	2	0.33	0	0.66
Report of performance tests, opacity observations	2	1	0	2
Reports of the results of quarterly inspections of the furnace capture system	2	4	0	8
Report of deviations, alarms, actions taken, malfunctions, and exceedances	2	1	0	2
Annual compliance certification	2	1	0	2
			Total	19
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	2	0	0	2
2	0	2	0	0	2
3	0	2	0	0	2
Average	0	2	0	0	2
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Performance Testing/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)
Initial Compliance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace PP FF	$200,000	0	$0
Initial Compliance test (PM, HCl, Hg, PAH, Formaldehyde) - Furnace NP FF/Scrubber	$52,000	0	$0
Initial Compliance test (PM) Building Ventilation/#12 casting/misc. sources NP/FF	$5,000	0	$0
Pressure Drop/Liquid Flow Rate CPMS - Scrubber a	$50,000	0	$0	$18,000	1	$18,000
Bag Leak Detection System b	$269,148	0	$0	$109,539	2	$219,078
Ductwork Flow Rate Monitoring c	$41,400	0	$0	$2,070	2	$4,140
Annual furnace control device tests: PM, Hg, PAH d				$5,000	5	$25,000
Five-year furnace control device tests: HCl, formaldehyde, capture system e				$126,000	1.2	$151,200
Five-year local ventilation test f				$5,000	0.6	$3,000
Five-year crushing and screening equipment test g				$5,000	0.6	$3,000
Five-year metal oxygen refining (MOR) process test h				$5,000	0.2	$1,000
Totals (rounded) i			$0			$424,000
a One respondent uses a single venturi scrubber to control emissions from two furnaces.
b Four furnaces are each controlled with fabric filters and are equipped with bag leak detection systems (BLDS).
c There are five furnace capture systems that require quarterly examinations of the ductwork to insure proper operation.
d The control devices on furnaces are tested annually. A wet scrubber is tested for PM, Hg, and PAH, while fabric filters are tested for Hg and PAH. We assume that respondents operating ferromanganese furnaces have applied for and received permission to test for PAH on a yearly basis.
e The control devices on furnaces are required to be tested for HCl, formaldehyde, and their capture system every five years. This is a repeat of the initial performance testing that cost a total of $756,000 for 6 furnace tests, or an average of $126,000 per test. (See Table 2 of ICR 2448.02.) The cost shown is the five-year average. (6 furnaces/5 years = 1.2 per year)
f The shop building ventilation systems controlled by baghouses require testing every five years. There are a total of three shop buildings that require testing. Testing costs are taken from Table 2 Year 2 of ICR 2448.02 for initial testing for 'Initial Compliance test (PM) - Bldg. Vent./#12 casting/misc. sources NP FF'. The cost shown is the five-year average. (3 systems/5 years = 0.6/year)
g The crushing/screening operations controlled by baghouses require testing every five years. There are a total of three crushing/screening operations that require testing. Testing costs are taken from Table 2 Year 2 of ICR 2448.02 for initial testing for 'Initial Compliance test (PM) - Bldg. Vent./#12 casting/misc. sources NP FF'. The cost shown is the five-year average. (3 operations/5 years = 0.6/year)
h Only one respondent has a metal oxygen refining (MOR) process. This will be tested every five years. Testing costs are taken from Table 2 Year 2 of ICR 2448.02 for initial testing for 'Initial Compliance test (PM) - Bldg. Vent./#12 casting/misc. sources NP FF'. The cost shown is the five-year average. (1 MOR process/5 years = 0.2/year)
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.