Burden Calculation Tables

---

Overview

Burden
Increment
OpCosts
2_EPA
Responses

---

Sheet 1: Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Proposed Amendments)											Salaries taken for NAICS 331500: Foundries
					81.33	123.71	42.8				May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
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	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost per year, ($) b			Occupation Code	Title	Mean Hourly Rate	110% OH and benefits	Estimated Total Pay with Benefits
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)				11-0000	Mgmt Occup	58.91	64.80	123.71
1. Applications	N/A										17-2081	Envir Engr	38.73	42.60	81.33
2. Surveys and studies	N/A										43-0000	Office and Admin Support	20.38	22.42	42.8
3. Reporting requirements
a. Familiarize with regulatory requirements c	2	1	2	45	90	4.5	9	$8,262
b. Required activities d
i. Initial performance tests d, e	70	2	140	0	0	0	0	$0
ii. On-going performance tests e	70	0.4	28	45	1260	63	126	$115,662
iii. On-going opacity observations f	6	2	12	45	540	27	54	$49,570
iv. Operation and maintenance plan d	72	1	72	0	0	0	0	$0
v. Scrap selection/inspection plan d	10	1	10	0	0	0	0	$0
vi. Scrap inspection g	0.5	350	175	45	7875	393.75	787.5	$722,890
vii. Monthly inspections of capture systems, maintenance of control devices and monitoring systems, and mould vent ignition plan	2	12	24	25	600	30	60	$55,077
c. Create information	See 3B
d. Gather existing information	See 3B
e. Write report
i. Notification of applicability d	2	1	2	0	0	0	0	$0
ii. Notification of construction/reconstruction d	2	1	2	0	0	0	0	$0
iii. Notification of actual startup d	2	1	2	0	0	0	0	$0
iv. Notification of special compliance requirements d	N/A
v. Compliance extension request d	2	1	2	0	0	0	0	$0
vi. Notification of performance test e	1	0.4	0.4	45	18	0.9	1.8	$1,652
vii. Site-specific test plan d	20	3.8	76	0	0	0	0	$0
viii. Notification of CEMS performance evaluation d	60	1	60	0	0	0	0	$0
ix. CEMS QA plan d	40	1	40	0	0	0	0	$0
x. Notification of compliance status d	8	1	8	0	0	0	0	$0
xi. NESHAP waiver application	N/A
xii. Report of performance test (through CEDRI using ERT) e	8	0.4	3.2	45	144	7.2	14.4	$13,219
xiii. Semiannual compliance reports h	12	2	24	45	1080	54	108	$99,139
Subtotal for Reporting Requirements					13,348			$1,065,470
4. Recordkeeping requirements
a. Familiarize with regulatory requirements c	See 3A
b. Plan activities i	3	1	3	15	45	2.25	4.5	$4,131
c. Implement activities i	6	1	6	15	90	4.5	9	$8,262
d. Develop record system i, j	1	1	1	15	15	0.75	1.5	$1,377
e. Time to enter information
i. Cupola VOHAP work practice information k	0.5	52	26	15	390	19.5	39	$35,800
ii. Other recordkeeping requirements l	0.5	52	26	45	1170	58.5	117	$107,401
f. Time to train personnel i	2	1	2	15	30	1.5	3	$2,754
g. Time to adjust existing ways to comply with previously applicable requirements i	2	1	2	15	30	1.5	3	$2,754
h. Time to transmit information m	0.25	2	0.5	45	22.5	1.125	2.25	$2,065
i. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,061			$164,543
TOTAL LABOR BURDEN AND COST (rounded) n					15,400			$1,230,000
CAPITAL AND O&M COST (rounded) n								$206,000
GRAND TOTAL (rounded) n								$1,440,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 45. We have assumed that there will be no new foundries projected during the next three years of this ICR.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c We have assumed that all respondents will have to familiarize with regulatory requirements each year.
d We have assumed that existing respondents are in compliance with the initial rule requirements. New respondents would have to comply with the initial rule requirements including notification and performance test for add-on control devices.
e Performance tests are required for particulate matter by Method 5 or total metal HAP by Method 29, for triethylamine by Method 18, and VOHAP by Method 18 or 25A, depending on the emission source. Performance tests must be repeated once every 5 years. Assumed each foundry has two controls requiring a performance test. Therefore, retest occurence rate is 2 tests/5 years = 0.4 test/years.
f Opacity performance tests should be conducted over 3-hour period as specified in §63.6(h)(5)(ii). Assumed average major source foundry would have two separate building openings to observe, so total duration is 6 hours. Tests must be repeated every 6 months for all foundries.
g Assumed it would talk 0.5 hours each operating day (assumed 350 operating days per year) to inspect scrap piles, scrap shipments, or scrap suppliers, as appropriate, according the the scrap selection and inspection plan.
h We have assumed it will take 12 hours for each respondents to all the required information concerning deviations from any emissions limitation or operation and maintenance requirements under the NESHAP rule into the electronic form template for each semiannual report.
i Assume each foundry will review new electronic reporting forms and will plan, train, and implement recordkeeping activities during the first year. These activities will not be necessary in the second and third year of the ICR, so on average, there will be 15 respondents per year [(45 + 0 + 0)/3 = 15] for these activities during the 3-year period covered by the ICR.
j We have assumed that new respondents would of already have the technology and recordkeeping systems in place to monitor its daily operations and to comply with existing regulations.
k We have assumed that it will take each respondent 0.5 hours 52 times per year to enter information for cupola off blast periods. We have ssumed that there are 15 respondents that have cupola melting furnaces.
l We have assumed that it will take each respondent 0.5 hours 52 times per year to enter other recordkeeping information.
m We have assumed that it will take each of the respondents 15 minutes two times per year to transmit information.
n Totals burden and costs have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

---

Sheet 2: Increment

Table 1: Annual Respondent Burden and Cost – NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)																									Salaries taken for NAICS 331500: Foundries
	First Year				81.33	123.71	42.8			Subsequent Years				81.33	123.71	42.8									May 2018	https://www.bls.gov/oes/current/naics4_331500.htm
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)		(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	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost per year, ($) b		Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost per year, ($) b								Occupation Code	Title	Mean Hourly Rate	Estimated Total Pay with Benefits
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)					(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)									11-0000	Mgmt Occup	58.91	123.71
1. Applications	N/A									N/A															17-2081	Envir Engr	38.73	81.33
2. Surveys and studies	N/A									N/A															43-0000	Office and Admin Support	20.38	42.8
3. Reporting requirements
a. Familiarize with regulatory requirements c	2	1	2		0	0	0	$0		2	1	2		0	0	0	$0
b. Required activities d
i. Initial performance tests d, e	70	2	140		0	0	0	$0		70	2	140		0	0	0	$0
ii. On-going performance tests e	70	2	140		0	0	0	$0		70	2	140		0	0	0	$0
ii. On-going opacity observations f	6	2	12		0	0	0	$0		6	2	12		0	0	0	$0
iii. Operation and maintenance plan d	72	1	72		0	0	0	$0		72	1	72		0	0	0	$0
iv. Scrap selection/inspection plan d	10	1	10		0	0	0	$0		10	1	10		0	0	0	$0
v. Scrap inspection g	0.5	350	175		0	0	0	$0		0.5	350	175		0	0	0	$0
vi. Monthly inspections of capture systems, maintenance of control devices and monitoring systems, and mould vent ignition plan	2	12	24		0	0	0	$0		2	12	24		0	0	0	$0
c. Create information	See 3B									See 3B
d. Gather existing information	See 3B									See 3B
e. Write report
i. Notification of applicability d	2	1	2	0	0	0	0	$0		2	1	2	0	0	0	0	$0
ii. Notification of construction/reconstruction d	2	1	2	0	0	0	0	$0		2	1	2	0	0	0	0	$0
iii. Notification of actual startup d	2	1	2	0	0	0	0	$0		2	1	2	0	0	0	0	$0
iv. Notification of special compliance requirements d	N/A									N/A
v. Compliance extension request d	2	1	2	0	0	0	0	$0		2	1	2	0	0	0	0	$0
vi. Notification of performance test d	2	3.8	7.6	0	0	0	0	$0		2	3.8	7.6	0	0	0	0	$0
vii. Site-specific test plan d	20	3.8	76	0	0	0	0	$0		20	3.8	76	0	0	0	0	$0
viii. Notification of CEMS performance evaluation d	60	1	60	0	0	0	0	$0		60	1	60	0	0	0	0	$0
ix. CEMS QA plan d	40	1	40	0	0	0	0	$0		40	1	40	0	0	0	0	$0
x. Notification of compliance status d	8	1	8	0	0	0	0	$0		8	1	8	0	0	0	0	$0
xi. NESHAP waiver application	N/A									N/A
xii. Report of performance test	8	0.4	3.2	45	144	7.2	14.4	$13,219		8	0.4	3.2	45	144	7.2	14.4	$13,219
xiii. Semiannual compliance reports h	1.635	2	3.27		0	0	0	$0		-2	2	-4	45	-180	-9	-18	($16,523)
Subtotal for Reporting Requirements					166			$13,219						-41			($3,305)
4. Recordkeeping requirements
a. Familiarize with regulatory requirements c	See 3A									See 3A
b. Plan activities i	3	1	3	45	135	6.75	13.5	$12,392		0	1	0	15	0	0	0	$0
c. Implement activities i	6	1	6	45	270	13.5	27	$24,785		0	1	0	15	0	0	0	$0
d. Develop record system i, j	1	1	1	45	45	2.25	4.5	$4,131		0	1	0	15	0	0	0	$0
e. Time to enter information
i. Cupola VOHAP work practice information k	0.5	52	26	15	390	19.5	39	$35,800		0.5	52	26	15	390	19.5	39	$35,800
ii. Other recordkeeping requirements l	0	52	0		0	0	0	$0		0	52	0		0	0	0	$0
f. Time to train personnel i	2	1	2	45	90	4.5	9	$8,262		0	1	0	15	0	0	0	$0
g. Time to adjust existing ways to comply with previously applicable requirements i	2	1	2	45	90	4.5	9	$8,262		0	1	0	15	0	0	0	$0
h. Time to transmit information m	0.25	2	0.5		0	0	0	$0		0	2	0		0	0	0	$0
i. Time for audits	N/A									N/A
Subtotal for Recordkeeping Requirements					1,173			$93,631						449			$35,800
TOTAL LABOR BURDEN AND COST (rounded) n					1,300			$106,800						400			$32,500
CAPITAL AND O&M COST (rounded) n								$0									$0
GRAND TOTAL (rounded) n								$107,000									$32,500
Assumptions:								$2,377.78									$722.22
a We have assumed that the average number of respondents that will be subject to this rule will be 45. We have assumed that there will be no new foundries projected during the next three years of this ICR.
b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2018, mean labor rates for Foundries (NAICS 331500) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $123.71 for management; $81.33 for technical; and $42.80 for clerical.
c We have assumed that all respondents will have to familiarize with regulatory requirements each year.
d We have assumed that existing respondents are in compliance with the initial rule requirements. New respondents would have to comply with the initial rule requirements including notification and performance test for add-on control devices.
e Performance tests are required for particulate matter by Method 5 or total metal HAP by Method 29, for triethylamine by Method 18, and VOHAP by Method 18 or 25A, depending on the emission source. Performance tests must be repeated once every 5 years. Assumed each foundry has two controls requiring a performance test. Assumed 20% of foundries (45*0.2 = 9 foundries) would conduct on-going performance tests each year.
f Assumed it would take 6 hours to conduct opacity performance tests of building openings for typical foundry; tests must be repeated every 6 months for all foundries.
g Assumed it would talk 0.5 hours each operating day (assumed 350 operating days per year) to inspect scrap piles, scrap shipments, or scrap suppliers, as appropriate, according the the scrap selection and inspection plan.
h We have assumed it will take 12 hours for each respondents to all the required information concerning deviations from any emissions limitation or operation and maintenance requirements under the NESHAP rule into the electronic form template for each semiannual report.
i Assume each foundry will review new electronic reporting forms and will plan, train, and implement recordkeeping activities during the first year. These activities will not be necessary in the second and third year of the ICR, so on average, there will be 15 respondents per year [(45 + 0 + 0)/3 = 15] for these activities during the 3-year period covered by the ICR.
j We have assumed that new respondents would of already have the technology and recordkeeping systems in place to monitor its daily operations and to comply with existing regulations.
k We have assumed that it will take each respondent 0.5 hours 52 times per year to enter information for cupola off blast periods. We have ssumed that there are 15 respondents that have cupola melting furnaces.
l We have assumed that it will take each respondent 0.5 hours 52 times per year to enter other recordkeeping information.
m We have assumed that it will take each of the respondents 15 minutes two times per year to transmit information.
n Totals burden and costs have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

---

Sheet 3: OpCosts

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)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E x F)
Leak detectors	$9,000	0	$0	$1,470	45	$66,150
Flow rate monitors	$7,500	0	$0	$2,000	30	$60,000
pH monitor	$7,500	0	$0	$2,000	23	$46,000
Pressure drop	$7,500	0	$0	$2,000	7	$14,000
VOC CEM	$100,000	0	$0	$10,000	2	$20,000
Total b			$0			$206,000
a Assumes all 45 major source foundries use baghouse to meet melting PM limits. Estimated that 23 foundries use TEA scrubber. Estimated that 7 foundries use wet scrubber for other PM control. Estimated that two foundries may use VOC CEMS.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 4: 2_EPA

Table 2: Average Annual EPA Burden and Cost – NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Proposed Amendments)
				2019:	$49.44	$66.62	$26.75
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
Attend performance test c	40	1	40	0	0	0	0	$0
Report review					0	0	0	$0
Notification of special compliance requirements	N/A
Notification of applicability d	2	1	2	0	0	0	0	$0
Notification of performance test or CEMS performance evaluation e	1	0.4	0.4	45	18	1	2	$998
CEMS QA plan d	2	1	2	0	0	0	0	$0
Notification of compliance status d	4	1	4	0	0	0	0	$0
Site-specific test plan d	2	1	2	0	0	0	0	$0
Scrap selection/inspection plan d	4	1	4	0	0	0	0	$0
Performance test report e	2	0.4	0.8	45	36	2	4	$1,996
Semiannual compliance reports f	2	2	4	45	180	9	18	$9,980
NESHAP waiver application d	4	1	4	0	0	0	0	$0
Compliance extension request d	4	1	4	0	0	0.0	0.0	$0.00
TOTAL BURDEN AND COST (rounded)e					269			$13,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 45. There will be no new foundries projected during the next three years of this ICR.
b This cost is based on the following 2019 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $66.62 Managerial rate (GS-13, Step 5), $49.44 Technical rate (GS-12, Step 1), and $26.75 Clerical rate (GS-6, Step 3). These rates are calculated from the hourly rates included in the Office of Personnel Management (OPM) 2019 General Schedule which excludes locality rates of pay; the rates have been increased by 60 percent to account for benefit packages available to government employees.
c We have assumed that EPA personnel would not attend any ongoing performance tests.
d We have assumed that existing respondents are in compliance with the initial rule requirements. New respondents would have to comply with the initial rule requirements including notification and performance test for add-on control devices.
e Performance tests are required for particulate matter by Method 5 or total metal HAP by Method 29, for triethylamine by Method 18, and VOHAP by Method 18 or 25A, depending on the emission source. Performance tests must be repeated once every 5 years. We assumed each foundry has two controls requiring a performance test. Therefore, retest occurrence rate is 2 tests/5 years = 0.4 test/years.
f We have assumed that all respondents are required to submit semiannual compliance reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Agency Worker Rates	Labor Rates, $/hr a	60% Overhead	Total, $/hr
Managerial (GS-13, step 5)	$41.64	$24.98	$66.62
Technical (GS-12, step 1)	$30.90	$18.54	$49.44
Clerical (GS-6, step 3)	$16.72	$10.03	$26.75
a https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf
Effective January 2019

---

Sheet 5: Responses

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 a	45	0.4	0	18
Report of performance test (through CEDRI using ERT)	45	0.4	1	18
Semiannual compliance reports	45	2	0	90
			Total	126
			Averge response burden	122.22