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	308
Number of Respondents	90
Total Estimated Burden Hours	56,700
Total Estimated Costs	$7,000,000
Annualized Capital O&M	$198,000
Total Annual Responses	184
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR Part 60, Subparts AA and AAa) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent Hours per Occurrence	Number of Occurrences per Respondent per Year	Hours per Respondent per Year (A x B)	Number of Respondents per Year a	Technical Hours per Year (C x D)	Management Hours per Year (E x 0.05)	Clerical Hours per Year (Ex0.1)	Total Labor Costs per Year, $ b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	$157.61
3. Reporting Requirements										Technical	$123.94
A. Read and understand rule requirements	1	1	1	90	90	4.5	9	$12,426.53		Clerical	$62.52
B. Required activities
Initial Performance tests c	364	1.64	596.96	1	596.96	29.848	59.696	82,423.76
Repeat Performance tests c	364	0.082	29.848	1	29.848	1	3	4,121.19
Monitoring of operations and emissions d, e	------------------------See 4E----------------------------
D. Gather Existing Information	-------------------See 3B and 4E-----------------------
E. Write report
Notification of construction/modification	2	1	2	1	2	0.1	0.2	276.15
Notification of actual startup	2	1	2	1	2	0.1	0.2	276.15
Notification of initial performance test	2	1	2	1	2	0.1	0.2	276.15
Reports of performance test results	------------------------See 3B----------------------------
Semiannual reports f	16	2	32	90	2,880	144	288	$397,648.80
Subtotal for Reporting Requirements					4,143			$497,449
4. Recording Requirements
A. Read and understand rule requirements	------------------------See 3A----------------------------
B. Plan activities	------------------------See 3B----------------------------
C. Implement activities	------------------------See 3B----------------------------
D. Develop record system	N/A
E. Time to enter and transmit information:
Records of daily monitoring of operations d	0.75	350	262.5	90	23,625	1,181.25	2,362.50	$3,261,962.81
Records of daily emissions monitoring by a certified observer e, h	0.5	350	175	43.47	7,607.25	380.36	760.73	$1,050,352.03
Records of COMS g, i	0.5	350	175	23.98	4,195.8	209.79	419.58	$579,324.60
Records of BLDS h, i	0.5	350	175	12.02	2,104.2	105.21	210.42	$290,532.15
Records of static pressure on furnace h	0.5	350	175	46.53	8,142.75	407.14	814.28	$1,124,289.85
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					52,526			$6,306,461		184	responses
Total Labor Burden and Cost (rounded) j					56,700			$6,800,000		308	hr/response
Total Capital and O&M Cost (rounded) j								$198,000
Grand Total (rounded) j								$7,000,000
Assumptions:
a We have assumed that there are an annual average of 89 sources currently subject to the NSPS, subparts AA and AAa. We have further assumed that 3 new sources will become subject to these subparts over the three-year period covered by this ICR renewal (1 new source per year). Therefore, the average number of respondents per year is estimated to be 90.
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, Sept 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 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 existing sources will not perform initial rule requirements including the initial performance test and notification requirements. We have assumed that 5 percent of new sources would repeat performance tests due to failure. We have assumed 1.64 baghouses per new facility based on collected information from existing sources (1.64 = 54 baghouses / 33 EAF facilities).
d Daily monitoring of operations includes time and duration of each charge, time and duration of each tap, flow rate data and pressure data. In addition, sources are required to conduct monthly operational status checks of the equipment (e.g., physical appearance, pressure sensors, dampers, damper switches).
e Daily emissions monitoring includes stack emissions monitoring using a continuous opacity monitor if the source has an EAF equipped with a direct shell evacuation system (DEC) and uses a negative pressure baghouse and has not elected the alternative option. In addition, the source is required to conduct fugitive emissions monitoring using a furnace static pressure monitoring device or by electing to perform shop opacity observations using a certified visible emissions observer, it the source has an EAF equipped with a DEC.
f Sources are required to provide semiannual reports of opacity observations and operational values (i.e., furnace static pressure, fan motor amperes) that exceed or are below (i.e, flow rates) those established during the performance test, and of all shop opacity observations in excess of the emission limit.
g We have assumed that the new source will equip its EAFs with a DEC system and use a positive pressure baghouse, and therefore, will not be required to install a continuous opacity monitor (COMS).
h We have assumed that approximately 51.7 percent of the respondents (or 46.53 respondents) will choose to comply with the fugitive emissions monitoring requirements by measuring the furnace static pressure continuously and 48.3 percent (43.47 respondents) will choose the alternative option of daily opacity shop observations by a certified visible emission observer couple with the use of bag leak detection systems (BLDS).
i We have assumed that approximately 40 percent of respondents (36 respondents) use negative pressure baghouses. Of these, 66.6 percent (23.98 respondents) use COMS to measure stack emissions and 33.4 percent (12.02 respondents) have elected to use the alternative option of using BLDS monitoring couple with visible emissions observations instead of using COMS.
j 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 – NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR Part 60, Subparts AA and AAa) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences per Plant Per Year	EPA Hours per Year (AxB)	Plants per Year a	Technical Hours per Year (CxD)	Management Hours per Year (Ex0.05)	Clerical Hours per Year (Ex0.1)	Costs per Year, $ b
Notification of construction/modification	2	1	2	1	2	0.1	0.2	$117.46		Labor Rates:
Notification of actual startup	1	1	1	1	1	0.05	0.10	$58.73		Management	$70.56
Notification of performance test c	0.5	1	0.5	1	0.5	0.03	0.05	$29.37		Technical	$52.37
Initial performance test (observed) c	24	1.64	39.36	1	39.36	2	4	$2,311.69		Clerical	$28.34
Repeat Performance test (observed) c	24	0.082	1.968	1	1.968	0.10	0.20	$115.58
Review Performance Test results c	8	1.05	8.4	1	8.4	0	1	$493.35
Notification of COMS Demonstration	0.5	1	0.5	1	0.5	0.03	0.05	$29.37
Semiannual reports	8	2	16	90	1,440	72	144	$84,574.08
TOTAL (rounded) d					1,720			$87,700
Assumptions
a We have assumed that there are an annual average of 89 sources currently subject to the NSPS, subparts AA and AAa. We have further assumed that 3 new sources will become subject to these subparts over the three-year period covered by this ICR renewal (1 new source per year). Therefore, the average number of respondents per year is estimated to be 90.
b This cost is based on the following labor rates: 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 $28.34 (GS-6, Step 3, $17.71 + 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 existing sources will not perform initial rule requirements including the initial performance test and notification requirements. We have assumed that 5 percent of new sources would repeat performance tests due to failure. We have assumed 1.64 baghouses per new facility based on collected information from existing sources (1.64 = 54 baghouses / 33 EAF facilities).
d 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)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Continuous Opacity Monitors a	$25,000	0	$0	$7,500	23.98	$179,820
Furnace Static Pressure Monitors b	$300	1	$300	$0	46.53	$0
Volumetric Flow Rate Monitor c	$18,000	1	$18,000	$0	90	$0
Totals (rounded) d			$18,300			$180,000
a We have assumed that approximately 40 percent of respondents (36 respondents) use negative pressure baghouses. Of these, 66.6 percent (23.98 respondents) use COMS to measure stack emissions and 33.4 percent (12.02 respondents) have elected to use the alternative option of using BLDS monitoring couple with visible emissions observations instead of using COMS.
b We have assumed that approximately 51.7 percent of the respondents (or 46.53 respondents) will choose to comply with the fugitive emissions monitoring requirements by measuring the furnace static pressure continuously and 48.3 percent (43.47 respondents) will choose the alternative option of daily opacity shop observations by a certified visible emission observer couple with the use of bag leak detection systems (BLDS).
c All respondents (90) are required to install flow rate monitors as part of the monitoring of operations rule requirements. The operating and maintenance costs associated with the flow monitors are negligible.
d 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	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of actual startup	1	1	0	1
Notification of construction/ modification	1	1	0	1
Notification of performance test	1	1	0	1
Reports of performance test results	1	1.05	0	1.05
Semiannual reports	90	2	0	180
			Total	184

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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	88	0	0	89
2	1	89	0	0	90
3	1	90	0	0	91
Average	1	89	0	0	90
a New respondents include sources with constructed and reconstructed affected facilities.