Burden Calculation Tables

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Overview

1a_small
1b_large
1c_Summary
2_EPA
Responses

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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) (Renewal)
					122.66	149.84	60.88
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
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	0.5	1	0.5	315	158	7.9	15.8	$21,458
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	$343,325
Subtotal for Reporting Requirements					3,079			$364,783
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activitiesf	2	1	2	0	0	0	0	$0
C. Implement activities f	2	1	2	0	0	0	0	$0
D Develop record system f	1	1	1	0	0	0	0	$0
E. Time to enter informationg	0.1	52	5.2	315	1,638.0	81.90	163.80	$223,161.12
F. Time to transmit or disclose information	0.25	2	0.5	315	158	7.88	15.75	$21,457.80
G. Time to adjust existing ways f	1	1	1	0	0	0	0	$0
F. Time to train personnel f	2	1	2	0	0	0.0	0.0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,065			$244,619
TOTAL LABOR BURDEN AND COST (rounded)h					5,140			$609,000
TOTAL CAPITAL AND O&M COST (rounded)h								$0
GRAND TOTAL (rounded)h					5,140			$609,000
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: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 One-time only costs for new sources.
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 One-time activities from ICR No. 2267.07. We have assumed that all small foundries already reviewed record keeping systems, adjusted methods, and trained employees during the first year after the 2020 rule amendments (85 FR 56080). Subsequent years, these activities would not be needed.
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) (Renewal)
					122.66	149.84	60.88
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
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsa	1	1	1	75	75	3.8	7.5	$10,218
B. Required activities
On-going Performance Test for PMc	70	0.2	14	75	1050.0	52.50	105.00	$143,052
On-going Performance Test for Opacityd	3	2	6	75	450.0	22.50	45.00	$61,308
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	$245,232
Monthly emissions averaging calculations g	0.25	12	3	37.5	112.5	5.625	11.25	$15,327
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	$2,044
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	$16,349
Semiannual compliance reports i	8	2	16	75	1200	60.0	120.0	$163,488
Subtotal for Reporting Requirements					5,546			$657,017
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities j	4	1	4	0	0	0	0	0
C. Implement activities j	4	1	4	0	0	0	0	0
D Develop record system j	2	1	2	0	0	0	0	0
E. Time to enter information k	0.5	52	26	75	1,950	97.5	195.0	$265,668
F. Time to transmit or disclose information k	0.25	2	0.5	75	38	1.9	3.8	$5,109
G. Time to adjust existing waysj	2	1	2	0	0	0	0	$0
F. Time to train personnel j	4	1	4	0	0	0.0	0.0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,286			270,777
TOTAL LABOR BURDEN AND COST (rounded)l					7,830			928,000
TOTAL CAPITAL AND O&M COST (rounded)l								$0
GRAND TOTAL (rounded)l					7,830			$928,000
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: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 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 for new sources.
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 One-time activities from ICR No. 2267.07. We have assumed that all large foundries already reviewed record keeping systems, adjusted methods, and trained employees during the first year of the 2020 rule amendments (85 FR 56080). Subsequent years, these activities would not be needed.
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: 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 Responses
	Small Foundry	3,079	2,065	5,140	$609,000	630
	Large Foundry	5,546	2,286	7,830	$928,000	180
	Total	8,625	4,350	12,970	$1,540,000	810
				16	hr per resp

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Sheet 4: 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)
					$51.23	$69.04	$27.73
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 applicabilityc	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	$861.83
Performance test reportd	2	0.2	0.4	75	30.0	1.50	3.00	$1,723.65
Semiannual compliance report - smalla	1	2	2	315	630	31.5	63.0	$36,196.65
Semiannual compliance report - largea	2	2	4	75	300	15.0	30.0	$17,236.50
TOTAL BURDEN AND COST (rounded)e					1,120			$56,000
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 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.
c One-time only costs for new sources.
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.

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Sheet 5: 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)	75	0.2	0	15
Report of Performance Test for PM (large foundries)	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