Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	29
Number of Respondents	161
Total Estimated Burden Hours	12,400
Total Estimated Costs	$5,590,000
Annualized Capital O&M	$4,110,000
Total Annual Responses	425

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart RRR) (Renewal)
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 (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year b
1. Applications	N/A
2. Surveys and studies	N/A
3. Acquisition, installation, and utilization of technology and systems c	54	1	54	0	0	0	0	$0
4. Reporting requirements										Labor Rates:
a. Familiarization with Regulatory Requirements d	1	1	1	161	161	8.05	16.1	$22,229.67		Management	$157.61
b. Required activities										Technical	$123.94
Initial performance test e, f	24	1	24	0	0	0	0	$0		Clerical	$62.52
Repeat performance test e, f	24	0.2	4.8	0	0	0	0	$0
Operating, maintenance and monitoring plan e, f	32	1	32	0	0	0	0	$0
Startup, shutdown, malfunction (SSM) plan g	N/A
c. Create information	See 4B
d. Gather existing information	See 4B
e. Write report
Notification of applicability e, f	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	N/A
Notification/report of actual startup	N/A
Notification of special compliance requirements	N/A
Notification of performance test e	2	1	2	0	0	0	0	$0
Notification of compliance status e	4	1	4	53	212	10.6	21.2	$29,271.37
Waiver application g	2	1	2	0	0	0	0	$0
Report of performance test	See 4B
Semiannual reports h	8	2	16	161	2,576	128.8	257.6	$355,674.76
Changing furnace classification i	2	1	2	50	100	5	10	$13,807.25
Subtotal for Reporting Requirements					3,506			$420,983
5. Recordkeeping requirements
a. Familarization with Regulatory Requirements	See 4A
b. Plan activities	See 4E
c. Implement activities	See 4B
Verify lime injection rate	0.1	36	3.6	161	579.6	28.98	57.96	$80,026.82
Changing furnace classification i	2	1	2	50	100	5	10	$13,807.25
d. Develop record system	N/A
e. Time to enter/transmit information
Records of all information required by the standards	N/A
Major sources j	1.5	52	78	53	4,134	206.7	413.4	$570,791.72
Area sources k	0.5	52	26	108	2,808	140.4	280.8	$387,707.58
f. Time to train personnel l	4	1	4	0	0	0	0	$0
g. Time to adjust existing ways to comply with previous applicable requirements	N/A
h. Time to disclose information
New sources m	0.25	2	0.5	0	0	0	0	$0
All sources n	0.25	2	0.5	161	81	4.03	8.05	$11,114.84
Sources that changed furnace classification i	1	1	1	50	50	2.5	5	$6,903.63
i. Time for audits	N/A
Subtotal for Recordkeeping Requirements					8,857			$1,063,448
TOTAL LABOR BURDEN AND COST (rounded)o					12,400			$1,480,000
Total Capital/O&M Costs (rounded)o								$4,110,000
Grand Total (Labor and Capital/O&M Costs)(rounded)o								$5,590,000
Assumptions:									29	hr/response
a We have assumed that the average number of respondents that will be subject to this rule will be 161, of which 53 are major sources. There will be no additional new major or area sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 We have assumed that it will take each new respondent 54 hours to complete the task. This burden cost is associated with the monitoring of all control equipment ensuring that respondents of new respondents meet the required specifications of this subpart. No additional new major or areas sources are anticipated over the three-year period of this ICR.
d We have assumed that it will take each respondent one hour to read and understand the reporting requirements.
e It is assumed that new area sources will comply by meeting the equipment specifications rather than by conducting performance tests. Respondents that are major sources are required to demonstrate initial compliance with the applicable emission limit, equipment, work practice, or operational standard for affected source or emission unit and report results in the notification of compliance status report. Since there are no new respondents estimated, the inital requirements do not apply.
f Since we have assumed that there will be no new sources over the next three-year period of this ICR, there will be no new sources conducting initial performance tests. We have determined that respondents of new area sources will not be required to conduct emissions testing to show compliance with the emission limit, since it was determined that sweat furnaces sold in the United States now have an afterburner installed and meet the design residence time of 0.8 seconds or greater and an operating temperature of 1600 oF or greater. All new respondents are required to submit for approval an operation, maintenance and monitoring plan for affected sources.
g It is assumed that there will be no new sources requiring a waiver from the performance test requirements.
h It is assumed that each respondent will take 8 hours to write semiannual report of excess emissions or no excess emissions.
i An estimated 50 facilities would change furnace classifications once per year.
j It is assumed that it will take 1.5 hours for major source respondents to enter and transmit records.
k It is assumed that it will take 0.5 hours for existing area source respondents to enter and transmit records.
l We have assumed that it will take 4 hours to train new employees.
m We have assumed that it will take 0.25 hours to each new respondent to disclose information.
n We have assumed that it will take 0.25 hours for each respondent to disclose information.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost - NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart RRR) (Renewal)
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 (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
Initial performance tests	40	1.4	56	0	0	0	0	$0		Labor Rates:
Report performance test including retesting c	48	1	48	0	0	0	0	$0		Management	$70.56
Notification of applicability	0.5	1	0.5	0	0	0	0	$0		Technical	$52.37
Notification of construction/reconstruction	N/A									Clerical	$28.34
Notification of actual startup	N/A
Notification of special compliance requirements	N/A
Notification of performance test	2	1	2	0	0	0	0	$0
Notification of compliance status d	2	1	2	0	0	0	0	$0
Report of performance test c	40	1	40	0	0	0	0	$0
Repeat of performance test report c	40	1	40	0	0	0	0	$0
Semiannual reports e	4	2	8	161	1288	64.4	128.8	$75,646.82
Review performance test reports and reports from facilities changing furnace classification f	4	1	4	59	236	11.8	23.6	$13,860.75
TOTAL ANNUAL BURDEN AND COST (rounded)g					1,750			$89,500
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 161, of which 53 are major sources. There will be no additional new major or area sources over 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 $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $26.34 (GS-6, Step 3, $17.17 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c We have assumed that all existing respondents are in compliance with the initial rule requirements. It is further assumed that new sweat furnaces will comply by meeting the equipment specification than by conducting performance test.
d We have assumed that it will take 2 hours for each respondent to complete notification of compliance status.
e We have assumed that each existing respondent will take 4 hours two times per year to complete the semiannual reports.
f Assumes Agency will review all annual reports, including 4 HF tests/yr, 5 tests/yr for uncontrolled furnaces, and 50 reports/yr for changing furnace classification.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

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)7	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)8
Bag leak detectors1	$291,111	0	$0	$66,667	18	$1,200,000
Flow Meters2	$3,000	0	$0	$0	0	$0
Continuous opacity monitors3	$36,000	0	$0	$7,500	0	$0
Temporary hoods4	$21,650	107	$2,320,000	$0	0	0
HF testing5	$0	0	$0	$11,000	8	$88,000
Furnace testing6	$0	0	$0	$10,000	50	$500,000
Temperature monitors6	$1,200	0	$0	$0	0	$0
Totals (rounded)			$2,320,000			$1,790,000		$4,110,000
1            Assume that 34 percent of major sources (or 18 respondents) will use bag leak detectors on fabric filters with an average cost to industry at $291,111. The actual cost of the bag leak detectors depends on the number of probes on the unit, and O&M costs for bag leak detectors is approximately $66,667.
2            All chlorine injection systems already have chlorine flow meters and the operation and maintenance costs are negligible.
3            Sources with fabric filters will be complying with the monitoring requirements through the use of a bag leak detector or visible emissions observations and not continuous opacity monitors.
4            An estimated 107 furnaces and 27 facilities would need temporary hoods installed every 5 years and testing conducted for a total capital cost of $17.3 million and a total annualized capital cost of $2.3 million. Total annualized cost per furnace would average $21,650 per year.
5            An estimated 8 affected facilities would incur a total annual O&M cost of $11,000 for measurement of hydrogen fluoride (HF) emissions.
6            Switching furnace classifications would result in total annual O&M costs for testing of $500,000/yr or, for an estimated 50 furnaces, a cost of $10,000 per furnace.
7            Temperature monitors will be installed at new sweat furnaces at a cost of $1,200. The O&M costs for temperature monitors are negligible.
8            Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of applicability	0	1	0	0
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of performance test	0	1	0	0
Notification of compliance status	53	1	0	53
Waiver application	0	1	0	0
Semiannual reports	161	2	0	322
Changing furnace classification	50	1	0	50
			Total	425

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	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	161	0	0	161
2	0	161	0	0	161
3	0	161	0	0	161
Average	0	161	0	0	161
a New respondents include sources with constructed and reconstructed affected facilities.