Burden Calculation Tables

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Overview

1a_small
1b_large
OpCosts
1c_Summary
2_EPA
Responses
Working Respondent
1a_increment
1b_increment

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Sheet 1: 1a_small

Table 1a: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Proposed Amendments)										Salaries taken for NAICS 331500: Foundries
										May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
					81.33	123.71	42.8
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		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A									17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	0.5	1	0.5	315	158	7.9	15.8	$14,458
B. Required activities
Repeat performance tests for opacity	N/A
Scrap specificationsc	4	1	4	0	0	0	0	$0
Monthly emission averaging calculation	N/A
No methanol binder formulation d	0	0	0	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityc	2	1	2	0	0	0	0	$0
Notification of compliance statusc	4	1	4	0	0	0	0	$0
Notification of construction/reconstructionc	N/A
Notification of actual startupc	N/A
Notification of foundry reclassificatione	1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A
Notification of repeat performance test	N/A
Site specific test plan	N/A
Notification of performance evaluation	N/A
Quality assurance plan for CEMS/COMS	N/A
NESHAP waiver requestc	N/A
Startup, shutdown, and malfunction plan/reports	N/A
Report of performance test (through CEDRI using ERT) c	N/A
Semiannual compliance reports	4	2	8	315	2520	126	252	$231,325
Subtotal for Reporting Requirements					3,079			$245,782
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activitiesf	2	1	2	105	210	11	21	$19,277
C. Implement activities f	2	1	2	105	210	11	21	$19,277
D Develop record system f	1	1	1	105	105	5	11	$9,639
E. Time to enter informationg	0.1	52	5.2	315	1,638.0	81.90	163.80	$150,361.03
F. Time to transmit or disclose information	0.25	2	0.5	315	158	7.88	15.75	$14,457.79
G. Time to adjust existing ways f	1	1	1	105	105	5	11	$9,639
F. Time to train personnel f	2	1	2	105	210	10.5	21.0	$19,277
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,031			$241,927
TOTAL LABOR BURDEN AND COST (rounded)h					6,110			$488,000
TOTAL CAPITAL AND O&M COST (rounded)h								$0
GRAND TOTAL (rounded)h					6,110			$488,000
Assumptions:
a This table is specific to area source foundries classified as small iron and steel foundries. A total of 315 of the 390 area source foundries are small foundries and 75 are large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c One-time only costs
d We have assumed that no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.
e We have assumed that no small foundries will be reclassified as large foundries.
f We have assumed that all small foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (315+0+0)/3 = 105.
g We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Small foundries are not assumed to incur any capital or O&M costs.

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Sheet 2: 1b_large

Table 1b: Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Proposed Amendments)										Salaries taken for NAICS 331500: Foundries
										May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
					81.33	123.71	42.8
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		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A									17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	1	1	1	75	75	3.8	7.5	$6,885
B. Required activities
On-going Performance Test for PMc	70	0.2	14	75	1050.0	52.50	105.00	$96,385
On-going Performance Test for Opacityd	3	2	6	75	450.0	22.50	45.00	$41,308
Scrap material specificationse	4	1	4	0	0	0	0	$0
Prepare operation & maintenance plane	8	1	8	0	0	0	0	$0
No methanol binder formulation e	4	1	4	0	0	0	0	$0
Initial performance tests e	70	0	0	0	0	0	0	$0
Initial and periodic inspections of PM control devices, monthly inspection of capture systems f	2	12	24	75	1800	90	180	$165,232
Monthly emissions averaging calculations g	0.25	12	3	37.5	112.5	5.625	11.25	$10,327
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilitye	4	1	4	0	0	0	0	$0
Notification of compliance statuse	8	1	8	0	0	0	0	$0
Notification of construction/reconstructione	N/A
Notification of actual startupe	N/A
Notification of foundry reclassificationh	1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A
Notification of repeat PM performance test c	1	0.2	0.2	75	15.0	0.75	1.50	$1,377
Site specific test plan e	0	0	0	0	0	0	0	$0
Notification of performance evaluatione	N/A
Quality assurance plan for CEMS/COMSe	N/A
NESHAP waiver requeste	N/A
Startup, shutdown, and malfunction plan/reports	N/A
Report of performance test (through CEDRI using ERT) c	8	0.2	1.6	75	120.0	6.00	12.00	$11,015
Semiannual compliance reports i	8	2	16	75	1200	60.0	120.0	$110,155
Subtotal for Reporting Requirements					5,546			$442,684
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities j	4	1	4	25	100	5	10	9180
C. Implement activities j	4	1	4	25	100	5	10	9180
D Develop record system j	2	1	2	25	50	3	5	4590
E. Time to enter information k	0.5	52	26	75	1,950	97.5	195.0	$179,001
F. Time to transmit or disclose information k	0.25	2	0.5	75	38	1.9	3.8	$3,442
G. Time to adjust existing waysj	2	1	2	25	50	3	5	$4,590
F. Time to train personnel j	4	1	4	25	100	5.0	10.0	$9,180
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,746			219,162
TOTAL LABOR BURDEN AND COST (rounded)l					8,290			662,000
TOTAL CAPITAL AND O&M COST (rounded)l								$0
GRAND TOTAL (rounded)l					8,290			$662,000
Assumptions:
a This table is specific to area source foundries classified as large iron and steel foundries. There are an estimated 390 area source foundries, 75 of which are expected to be classified as large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to a change to an operating limit or a process change likely to increase HAP emissions over the period of this ICR. A notification is required.
d We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity performance tests should be conducted over 3-hour period as specified in §63.6(h)(5)(ii). Assume one observation location can be used per foundry. No separate notification required.
e One-time only costs
f We have assumed that all large foundries must conduct inspection of control device and capture system.
g We assumed half of the large area source foundries (75/2 = 37.5) would use the emissions averaging provisions.
h We have assumed that no foundries will be reclassified as small foundries.
i We have assumed all large foundries will have to submit semi-annual compliance reports.
j We have assumed that all large foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (75+0+0)/3 = 25.
k We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations and information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of the General Provisions (40 CFR part 63, subpart A). In addition, record to record information to demonstrate compliance with the PM and opacity standards.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Large foundries are not assumed to incur any capital or O&M costs.

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Sheet 3: OpCosts

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&Ma	Total O&M, (E x F)
Leak detectors	$9,000	0	$0	$1,470	0	$0
Flow rate monitors	$7,500	0	$0	$2,000	0	$0
Pressure drop	$7,500	0	$0	$2,000	0	$0
Total b			$0			$0
a PM control system O&M cost are only applicable to large iron and steel foundries, of which there are 75. Assumes 20 foundries use a wet scrubber and the remainder use a baghouse.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: 1c_Summary

Table 1c: Annual Respondent Burden and Cost for All Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
	Category	Reporting Hours	Recordkeeping Hours	Total Labor Hours	Labor Cost	Number of Response
	Small Foundry	3,079	3,031	6,110	$488,000	630
	Large Foundry	5,546	2,746	8,290	$662,000	180
	Total	8,625	5,776	14,400	$1,150,000	810
				18	hr per resp

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Sheet 5: 2_EPA

Table 2: Average Annual EPA Burden and Cost – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
				2019:	$49.44	$66.62	$26.75
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
Report Review:
Initial notification of applicability c	1	1	1	0	0	0	0	0
Notification of compliance statusc	2	1	2	0	0	0	0	$0
Notification of performance testd	1	0.2	0.2	75	15.0	0.75	1.50	$831.70
Performance test reportd	2	0.2	0.4	75	30.0	1.50	3.00	$1,663.39
Semiannual compliance report - smalla	1	2	2	315	630	31.5	63.0	$34,931.23
Semiannual compliance report - largea	2	2	4	75	300	15.0	30.0	$16,633.92
TOTAL BURDEN AND COST (rounded)e					1,121			$54,100
Assumptions:
a Taking into account shutdown data for foundries, we have assumed that there are 390 existing iron and steel foundries that are area sources. No new sources are projected during the 3-year term of this ICR. A total of 315 of the 390 facilities are small foundries and 75 are large foundries. All foundries have to submit semiannual compliance reports.
b This cost is based on the following 2019 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $66.62 Managerial rate (GS-13, Step 5), $49.44 Technical rate (GS-12, Step 1), and $26.75 Clerical rate (GS-6, Step 3). These rates are calculated from the hourly rates included in the Office of Personnel Management (OPM) 2019 General Schedule which excludes locality rates of pay; the rates have been increased by 60 percent to account for benefit packages available to government employees.
c One-time only costs
d We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to change to an operating limit or a process change likely to increase HAP emissions.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Agency Worker Rates	Labor Rates, $/hr a	60% Overhead	Total, $/hr
Managerial (GS-13, step 5)	$41.64	$24.98	$66.62
Technical (GS-12, step 1)	$30.90	$18.54	$49.44
Clerical (GS-6, step 3)	$16.72	$10.03	$26.75
a https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf
Effective January 2019

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Sheet 6: 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
Initial Notification	0	0	0	0
Notification of Compliance Status	0	0	0	0
Notification of Foundry Reclassification	0	0	0	0
Notification of Performance Test for PM (large foundries)a	75	0.2	0	15
Report of Performance Test for PM (large foundries)a	75	0.2	1	15
Semiannual compliance reports (small foundries)	315	2	0	630
Semiannual compliance reports (large foundries)	75	2	0	150
			Total	810

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Sheet 7: Working Respondent

	Current ICR (2267.05)				Revised ICR (2267.06)
	Number of Sources	Distribution	Number of Small Entity	Basis	Number of Sources	Basis	Number of Small Entity	Basis
Total	392	1.00	303		390	Total count gone down consistently, assumed two more drop. One small and one large
small	316	0.81	269	85% of small foundries are small entities	315	revised small count	268	85% of small foundries are small entities
large	76	0.19	34	45% of large foundries are small entities	75	revised large count	34	45% of large foundries are small entities

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Sheet 8: 1a_increment

Table 1a: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)																			Salaries taken for NAICS 331500: Foundries
																			May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
	First Year				81.33	123.71	42.8			Subsequent Years				81.33	123.71	42.8
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		(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		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									N/A									11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A									N/A									17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									N/A									43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	0.5	1	0.5	0	0	0.0	0.0	$0.00		0.5	1	0.5	0	0	0.0	0.0	$0.00
B. Required activities
Repeat performance tests for opacity	N/A									N/A
Scrap specificationsc	4	1	4	0	0	0	0	$0		4	1	4	0	0	0	0	$0
Monthly emission averaging calculation	N/A									N/A
No methanol binder formulation d	0	0	0	0	0	0	0	$0		0	0	0	0	0	0	0	$0
C. Create information	See 4B									See 4B
D. Gather existing information	See 4B									See 4B
E. Write report	See 4B									See 4B
Initial notification of applicabilityc	2	1	2	0	0	0	0	$0		2	1	2	0	0	0	0	$0
Notification of compliance statusc	4	1	4	0	0	0	0	$0		4	1	4	0	0	0	0	$0
Notification of construction/reconstructionc	N/A									N/A
Notification of actual startupc	N/A									N/A
Notification of foundry reclassificatione	1	0	0	0	0	0	0	$0		1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A									N/A
Notification of repeat performance test	N/A									N/A
Site specific test plan	N/A									N/A
Notification of performance evaluation	N/A									N/A
Quality assurance plan for CEMS/COMS	N/A									N/A
NESHAP waiver requestc	N/A									N/A
Startup, shutdown, and malfunction plan/reports	N/A									N/A
Report of performance test (through CEDRI using ERT) c	N/A									N/A
Semiannual compliance reports	4	2	8	0	0	0	0	$0		-1	2	-2	315	-630	-32	-63	-$57,831
Subtotal for Reporting Requirements					0			$0						-725			-$57,831
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A									See 4A
B. Plan activitiesf	2	1	2	315	630	32	63	$57,831		2	1	2		0	0	0	$0
C. Implement activities f	2	1	2	315	630	32	63	$57,831		2	1	2		0	0	0	$0
D Develop record system f	1	1	1	315	315	16	32	$28,916		1	1	1		0	0	0	$0
E. Time to enter informationg	0.1	52	5.2	0	0.0	0.00	0.00	$0.00		0.1	52	5.2		0.0	0.00	0.00	$0.00
F. Time to transmit or disclose information	0.25	2	0.5	0	0	0.00	0.00	$0.00		0.25	2	0.5		0	0.00	0.00	$0.00
G. Time to adjust existing ways f	1	1	1	315	315	16	32	$28,916		1	1	1		0	0	0	$0
F. Time to train personnel f	2	1	2	315	630	31.5	63.0	$57,831		2	1	2		0	0.0	0.0	$0
G. Time for audits	N/A									N/A
Subtotal for Recordkeeping Requirements					2,898			$231,325						0			$0
TOTAL LABOR BURDEN AND COST (rounded)h					2,900			$231,000						-720			-$57,800
TOTAL CAPITAL AND O&M COST (rounded)h								$0									$0
GRAND TOTAL (rounded)h					2,900			$231,000						-720			-$57,800
							Combined	$352,000								Combined	-$67,400
							per foundry	$903								per foundry	-$173
Assumptions:
a This table is specific to area source foundres classified as small iron and steel foundries. A total of 315 of the 390 area source foundries are small foundries and 75 are large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c One-time only costs
d We have assumed that no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.
e We have assumed that no small foundries will be reclassified as large foundries.
f We have assumed that all small foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (315+0+0)/3 = 105.
g We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Small foundries are not assumed to incur any capital or O&M costs.

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Sheet 9: 1b_increment

Table 1b: Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)																			Salaries taken for NAICS 331500: Foundries
																			May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
	First Year				81.33	123.71	42.8			Subsequent Years				81.33	123.71	42.8
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		(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		Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
1. Applications	N/A									N/A									11-0000	Mgmt Occup	58.91	123.71
2. Surveys and Studies	N/A									N/A									17-2081	Envir Engr	38.73	81.33
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									N/A									43-0000	Office and Admin Support	20.38	42.8
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	1	1	1		0	0.0	0.0	$0.00		1	1	1		0	0.0	0.0	$0.00
B. Required activities
On-going Performance Test for PMc	70	0.2	14		0.0	0.00	0.00	$0.00		70	0.2	14		0.0	0.00	0.00	$0.00
On-going Performance Test for Opacityd	3	2	6		0.0	0.00	0.00	$0.00		3	2	6		0.0	0.00	0.00	$0.00
Scrap material specificationse	4	1	4	0	0	0	0	$0		4	1	4	0	0	0	0	$0
Prepare operation & maintenance plane	8	1	8	0	0	0	0	$0		8	1	8	0	0	0	0	$0
No methanol binder formulation e	4	1	4	0	0	0	0	$0		4	1	4	0	0	0	0	$0
Initial performance tests e	70	0	0	0	0	0	0	$0		70	0	0	0	0	0	0	$0
Initial and periodic inspections of PM control devices, monthly inspection of capture systems f	2	12	24		0	0	0	$0		2	12	24		0	0	0	$0
Monthly emissions averaging calculations g	0.25	12	3		0	0	0	$0		0.25	12	3		0	0	0	$0
C. Create information	See 4B									See 4B
D. Gather existing information	See 4B									See 4B
E. Write report	See 4B									See 4B
Initial notification of applicabilitye	4	1	4	0	0	0	0	$0		4	1	4	0	0	0	0	$0
Notification of compliance statuse	8	1	8	0	0	0	0	$0		8	1	8	0	0	0	0	$0
Notification of construction/reconstructione	N/A									N/A
Notification of actual startupe	N/A									N/A
Notification of foundry reclassificationh	1	0	0	0	0	0	0	$0		1	0	0	0	0	0	0	$0
Request for compliance extensionc	N/A									N/A
Notification of repeat PM performance test c	1	0.2	0.2		0.0	0.00	0.00	$0.00		1	0.2	0.2		0.0	0.00	0.00	$0.00
Site specific test plan e	0	0	0	0	0	0	0	$0		0	0	0	0	0	0	0	$0
Notification of performance evaluatione	N/A									N/A
Quality assurance plan for CEMS/COMSe	N/A									N/A
NESHAP waiver requeste	N/A									N/A
Startup, shutdown, and malfunction plan/reports	N/A									N/A
Report of performance test (through CEDRI using ERT) c	8	0.2	1.6	75	120.0	6.00	12.00	$11,015.46		8	0.2	1.6	75	120.0	6.00	12.00	$11,015.46
Semiannual compliance reports i	8	2	16	0	0	0.0	0.0	$0.00		-1.5	2	-3	75	-225	-11.3	-22.5	-$20,653.99
Subtotal for Reporting Requirements					138			$11,015						-121			-$9,639
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A									See 4A
B. Plan activities j	4	1	4	75	300	15	30	27539		4	1	4		0	0	0	0
C. Implement activities j	4	1	4	75	300	15	30	27539		4	1	4		0	0	0	0
D Develop record system j	2	1	2	75	150	8	15	13769		2	1	2		0	0	0	0
E. Time to enter information k	0.5	52	26		0	0.0	0.0	$0.00		0.5	52	26		0	0.0	0.0	$0.00
F. Time to transmit or disclose information k	0.25	2	0.5		0	0.0	0.0	$0.00		0.25	2	0.5		0	0.0	0.0	$0.00
G. Time to adjust existing waysj	2	1	2	75	150	8	15	$13,769		2	1	2		0	0	0	$0
F. Time to train personnel j	4	1	4	75	300	15.0	30.0	$27,538.65		4	1	4		0	0.0	0.0	$0.00
G. Time for audits	N/A									N/A
Subtotal for Recordkeeping Requirements					1,380			110,155						0			0
TOTAL LABOR BURDEN AND COST (rounded)l					1,520			121,000						-120			-9,600
TOTAL CAPITAL AND O&M COST (rounded)l								$0									$0
GRAND TOTAL (rounded)l					1,520			$121,000						-120			-$9,600
Assumptions:
a This table is specific to area source foundries classified as large iron and steel foundries. There are an estimated 390 area souce foundries, 75 of which are expected to be classified as large foundries. No new area source foundries are projected during the 3-year term of this ICR. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to a change to an operating limit or a process change likely to increase HAP emissions over the period of this ICR. A notification is required.
d We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity performance tests should be conducted over 3-hour period as specified in §63.6(h)(5)(ii). Assume one observation location can be used per foundry. No separate notification required.
e One-time only costs
f We have assumed that all large foundries must conduct inspection of control device and capture system.
g We assumed half of the large area source foundries (75/2 = 37.5) would use the emissions averaging provisions.
h We have assumed that no foundries will be reclassified as small foundries.
i We have assumed all large foundries will have to submit semi-annual compliance reports.
j We have assumed that all large foundries would review record keeping system, adjust methods and train employees during the first year of the rule amendments. Subsequent years, these activities would not be needed. Therefore, the average number of respondents per year is (75+0+0)/3 = 25.
k We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations and information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of the General Provisions (40 CFR part 63, subpart A). In addition, record to record information to demonstrate compliance with the PM and opacity standards.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Large foundries are not assumed to incur any capital or O&M costs.