Burden Calculations 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 Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences 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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Annual costs ($) b
1. Reporting requirements										Labor Rates:
a. Familiarize with regulatory requirements	4	1	4	1	4	0.2	0.4	$544.11		Management	$153.55
b. Process/review information	4	4	16	1	16	0.8	1.6	$2,176.46		Technical	$122.20
c. Write reports										Clerical	$61.51
i. Initial notification	2	1	2	0	0	0	0	$0
ii. Notification of compliance status c	2	1	2	1	2	0.10	0.20	$272.06
iii. Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
iv. Notification of actual startup	2	1	2	0	0	0	0	$0
v. Notification of performance test c	2	2	4	1	4	0.20	0.40	$544.11
vi. Report of performance test c, d	180	2	360	1	360	18	36	$48,970.26
vii. Semiannual report e	20	2	40	1	40	2	4	$5,441.14
viii. Startup, shutdown, malfunction report	4	1	4	1	4	0.2	0.4	$544.11
Subtotal for Reporting Requirements					495			$58,492
2. Recordkeeping requirements
a. Familiarize with regulatory requirements	4	1	4	1	4	0.2	0.4	$544.11
b. Plan activities	12	1	12	1	12	0.6	1.2	$1,632.34
c. Implement activities	12	1	12	1	12	0.6	1.2	$1,632.34
d. Time to train personnel	10	1	10	1	10	0.5	1	$1,360.29
e. Time to enter information	-	-	-	-	-	-	-	-
f. Store, file, and maintain records f	1	365	365	1	365	18.25	36.5	$49,650.40
g. Retrieve records/reports g	1	12	12	1	12	0.6	1.2	$1,632.34
Subtotal for Recordkeeping Requirements					477			$56,452
Total Labor Burden and Costs (rounded) h					972			$114,900
Total Capital and O&M Costs (rounded) h								$1,200		8	responses
Grand Total (rounded) h								$116,000	<--round to 3 sig figs	121	hr/response
Assumptions:
a There is one respondent subject to the rule, with no new sources expected over the next three years of this ICR.
b 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.
c 40 CFR 63.9912 requires performance testing no less frequently than twice (at mid-term and renewal) of each term of the Title V permit, or every 2.5 years, for each emission point. For the U.S. Magnesium facility subject to this rule, we have assumed that 4 emission units must be tested twice during the permit term, and that performance tests are conducted for approximately two emission units in each year in the three year period of this ICR. We assume that 20% of tests will need to be repeated. (4 units x 2 tests / 5 years = 1.6 units per year, 1.6 units x 0.20 = 0.32 units with repeat testing, 1.6 + 0.32 = 1.92 or 2 units per year.) This estimate is consistent with an estimate of $49,000 provided by the U.S. Magnesium facility.
d We assume that this includes Method 23 test.
e We assumed that it will take the respondent 20 hours two times per year to complete semiannual reports.
f This includes inspection of unpaved areas.
g We assume that it will take 1 hour once per month to retrieve records/reports.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Note that U.S. Magnesium provided a slightly higher total burden estimate of $130,000, but did not provide additional specific costs to explain this difference.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences 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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Annual costs ($) b
1. Initial performance test c	24	1.6	38.4	0	0	0.00	0.00	$0.00		Labor Rates:
2. Repeat performance test c	24	0.32	7.68	0	0.00	0.00	0.00	$0.00		Management	$69.04
3. Report review					0	0	0	$0		Technical	$51.23
a. Initial notification	8	1	8	0	0	0	0	$0		Clerical	$37.73
b. Notification of performance test c	8	2	16	1	16.00	0.80	1.60	$935.28
c. Notification of compliance status c	8	1	8	1	8	0.40	0.80	$467.64
d. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
e. Notification of actual startup	8	1	8	0	0	0	0	$0
f. Report of performance test c	8	2	16	1	16.00	0.80	1.60	$935.28
g. Semiannual report d	16	2	32	1	32	1.6	3.2	$1,870.56
h. Startup, shutdown, malfunction report e	8	1	8	1	8	0.4	0.8	$467.64
Total (rounded) f					92			$4,680
Assumptions:
a There is one respondent subject to this rule, with no new sources expected over the next three years 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, $32.02 + 60%), and Clerical rate of $37.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2020 General Schedule” which excludes locality rates of pay.
c 40 CFR 63.9912 requires a performance testing no less frequently than twice (at mid-term and renewal) of each term of the Title V permit, or every 2.5 years, for each emission point. For the U.S. Magnesium facility subject to this rule, we have assumed that 4 emission units must be tested twice during the permit term, and that performance tests are conducted for approximately two emission units in each year in the three year period of this ICR. We assume that 20% of tests will need to be repeated. (4 units x 2 tests / 5 years = 1.6 units per year, 1.6 units x 0.20 = 0.32 units with repeat testing, 1.6 + 0.32 = 1.92 or 2 units per year.) We assume that Agency personnel only attend initial and repeat of initial performance tests.
d We have assumed that it would take 16 hours two times per year to review semiannual reports.
e We have assumed that it will take eight hours once per year to review the startup, shutdown, malfunction report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.