Burden Calculations Table

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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	21
Number of Respondents	3
Total Estimated Burden Hours	41
Total Estimated Costs	$4,970
Annualized Capital O&M	$0
Total Annual Responses	2
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals-Zinc, Cadmium, and Beryllium (Renewal)
					123.94	157.61	62.52
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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost per Year, $b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
a. Familiarize with regulatory requirements d	8	1	8	3	24	1.2	2.4	$3,313.74
b. Required activities
Monitor per Title V permit c	2	1	2	0	0	0	0	$0
Initial/repeat performance tests e	4	1	4	0	0	0	0	$0
Initial notification of applicability	4	1	4	1	4	0.2	0.4	$552.29
Initial notification of compliance status f	8	1	8	1	8	0.4	0.8	$1,104.58
Reports per Title V permit c	2	1	2	0	0	0	0	$0
c. Create information	See 3B
d. Gather existing information	See 3B
e. Write report	See 3B
Subtotal for Reporting Requirements					41			$4,971		41.4
4 Recordkeeping requirements
a. Familiarize with regulatory requirements	See 3A
b. Plan activities	See 3A
c. Implement activities	See 3A
d. Record all data required by Title V permit c	0.25	1	0.25	0	0	0	0	$0
e. Time to transmit or disclose information c	0.25	1	0.25	0	0	0	0	$0
f. Time to train personnel	4	1	4	0	0	0	0	$0
g. Time for audits	N/A
Subtotal for Recordkeeping Requirements					0			$0
TOTAL LABOR BURDEN AND COST (rounded)g					41			$4,970		21	hr/response
CAPITAL AND O&M COST (rounded)g								$0
GRAND TOTAL (rounded)g								$4,970
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is three. Each year one respondent is anticipated to effect process changes requiring notification to the Agency regarding applicability and compliance status. They are all area sources. There will be no additional new 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 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed that no hours or costs are associated with this burden item because existing plants comply with the requirement as part of their Title V operating permit.
d We have assumed that it will take eight hours for each respondent to familiarize with regulatory requirements.
e We have assumed that an existing facility may certify initial compliance based on previous PM test; no new test is required.
f We have assumed that it will take eight hours for each respondent to complete the initial notification of compliance status report.
g 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 Area Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals-Zinc, Cadmium, and Beryllium (Renewal)
					52.37	70.56	28.34
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant 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) Total Cost per Year, $b
1. Report review
a. Initial notification of applicability c	2	1	2	1	2	0.1	0.2	$117.46
b. Initial notification of compliance status d	4	1	4	1	4	0.2	0.4	$234.93
TOTAL ANNUAL BURDEN AND COST (rounded)e					7			$352
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule will be three. Each year one respondent is anticipated to effect process changes requiring notification to the Agency regarding applicability and compliance status. They are all area sources. There will be no additional new sources over the three-year period of this ICR.
b This cost is based on the following labor rates: $70.56 Managerial rate (GS-13, Step 5, $44.10 + 60%), $52.37 Technical rate (GS-12, Step 1, $32.73 + 60%), and $28.34 Clerical rate (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. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that it will take 2 hours to review the initial notification of applicability report.
d We have assumed that it will take 4 hours to review the initial notification of compliance status report.
e 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

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

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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
Write reports
Monitor per Title V permit	3	0	0	0
Notification of initial applicability	1	1	0	1
Initial/repeat performance tests	0	1	0	0
Notification of initial compliance status	1	1	0	1
Reports per Title V permit	0	1	0	0
			Total	2
a We have assumed that the average number of respondents potentially subject to this rule is three. Each year one respondent is anticipated to effect process changes requiring notification to the Agency regarding applicability and compliance status. They are all area sources. There will be no additional new sources over the three-year period of this ICR.

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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	1	3	0	1	3
2	1	3	0	1	3
3	1	3	0	1	3
Average	1	3	0	1	3
a New respondents include sources with constructed, reconstructed, and modified affected facilities.