Burden Calculation Tables

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Overview

Respondent Burden
Agency Burden

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Sheet 1: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal)
Burden item	(A) Person-hours per occurrence	(B) No. of occurrences per respondent	(C) Person-hours per respondent (C=A*B)	(D) Respondents per year b	(E) Technical person-hours per year (E=C*D)	(F) Management person-hours per year (F=E*0.05)	(G) Clerical person-hours per year (G=E*0.1)	(H) Costa, $
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									Labor Rates
4. Reporting Requirements										Management	153.55
A. Familiarize with Regulatory Requirements	4	1	4	318	1,272	63.6	127.2	$173,028.25		Technical	122.2
B. Required activities										Clerical	61.51
Prepare management practices plan c	4	1	4	0	0	0	0	$0
Initial performance tests c	40	1	40	0	0	0	0	$0
Daily VE (30 days) then weekly VE d, e	0.1	78	7.8	23	179.4	8.97	17.94	$24,403.51		186	hr/response
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicability c	4	1	4	0	0	0	0	$0
Notification of compliance status c	4	1	4	0	0	0	0	$0
Notification of construction/reconstruction	N/A
Notification of anticipated startup	N/A
Notification of actual startup	N/A
Notification of special compliance requirements	N/A
Request for compliance extension	N/A
Notification of performance test c	1	1	1	0	0	0	0	$0
Site specific test plan c	4	1	4	0	0	0	0	$0
Notification of performance evaluation	N/A
Quality assurance plan for CEMS/COMS	N/A
NESHAP waiver request	N/A
Startup, shutdown, and malfunction plan/reports c	4	1	4	0	0	0	0	$0
Semiannual compliance reports f	8	2	16	31.8	508.8	25.44	50.88	$69,211.30
Subtotal for Reporting Requirements					2,254			$266,643
5. Recordkeeping Requirements
A. Familiarize with Regulatory Requirements	See 4A
B. Plan activities	See 4A
C. Implement activities	See 4A
D Develop record system c	4	1	4	0	0	0	0	$0
E. Time to enter information	0.5	52	26	318	8,268	413.4	826.8	$1,124,683.64
F. Time to transmit or disclose information	0.25	2	0.5	318	159	7.95	15.9	$21,628.53
G. Time to train personnel c	4	1	4	0	0	0	0	$0
H. Time for audits	N/A
Subtotal for Recordkeeping Requirements					9,691			$1,146,312
TOTAL LABOR BURDEN AND COSTS (rounded)g					11,900			$1,410,000
TOTAL CAPITAL AND O&M COSTS (rounded)g								$0
GRAND TOTAL (rounded)g								$1,410,000
Assumptions:
a This ICR uses the following labor rates: $153.55 per hour for Executive, Administrative, and 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.
b We have assumed that 318 foundries will be subject to the rule and will perform these activities over the 3-year term of the ICR.
c This activity applies only to new respondents. There are no new respondents anticipated over the three-year period of this ICR.
d We have assumed that all of the 23 foundries subject to the PM emission limit must perform the visible emissions observations over the 3-year term of the ICR.
e This activity is based on daily VE for 30 days and weekly thereafter (30 + 335/7 = 78).
f Semiannual compliance reports are required when deviations occur. We estimate that 10 percent of the foundries will experience deviations.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent	(C) Plants per year	(D) Technical person-hours per year (D=A*B*C)	(E) Management person-hours per year (F=E*0.05)	(F) Clerical person-hours per year (G=E*0.1)	(G) Costa, $
Report Review:									Labor Rates
Initial notification of applicability	1	1	0	0	0	0	$0		Technical	69.04
Startup, shutdown, malfunction plan/report	2	1	0	0	0	0	$0		Management	51.23
Notification of compliance status	2	1	0	0	0	0	$0		Clerical	27.73
Semiannual excess emissions reportb	4	2	31.8	254.4	12.72	25.44	$14,616.55
TOTAL ANNUAL BURDEN AND COST (rounded)c				293			$14,600
Assumptions:
a 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, $32.02 + 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.
b Semiannual compliance reports are required when deviations occur. We estimate that 10 percent of the foundries will experience deviations.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.