1850t10.xlsx

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Copper Smelting (40 CFR Part 63, Subpart QQQ) (Proposed Amendments)
					$119.71	$146.43	$59.28	Labor Cost Per Hour
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)				Proposal
	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 c				New	Continured Compliance
1. Applications	N/A												$0
2. Survey and Studies	N/A												$0
3. Reporting Requirements													$0
A. Familiarization with rule requirements													$0
i. Current equirements d	16	1	16	2	32	1.6	3.2	$4,255					$4,255
ii. Proposed requirements	2	2	4	2	8	0.4	0.8	$1,064				$1,064
B. Required activities													$0
i. Conduct PM performance teste (current)	120	4.5	540	2	1080	54	108	$143,596					$143,596
ii. Conduct copper converter building performance test f (current)	240	1	240	2	480	24	48	$63,821					$63,821
iii. PM performance test, anode refining point source proposed) g	-	1	-	1.0	-	-	-	$18,000				$18,000
iv. PM perfornance test, roof vents for converter operations, smelting furnaces, anode refining (new) h	-	3	-	1.0	-	-	-	$31,667				$31,667
v. Whole facility mercury test i	-	1	-	2.0	-	-	-	$58,800				$58,800
C. Create information	N/A
D. Gather existing information	N/A
E. Write report										No. of responses
i. Initial Notifications j	2	1	2	0	0	0	0	$0		0
ii. Notification of performance test (current + proposed) k	2	5.5	11	2	22	1.1	2.2	$2,925		11			$2,925
iii. Initial compliance determination (current + proposed) j	40	1	40	0	0			$0		0
iv. Report of performance test (through CEDRI using ERT) l	8	1	8	2	16	1	2	$2,127		2		$2,127
v. Semiannual compliance reports	40	2	80	2	160	8	16	$21,274		4			$21,274
										17
Subtotal for Reporting Requirements					2,068			$347,528
4. Recordkeeping Requirements
A. Familiarization with rule requirements (current) d	40	1	40	2	80	4	8	$10,637					$10,637
B. Plan activities j	3	1	3	0	0	0	0	$0
C. Implement Activities	16	1	16	0	0	0	0	$0
i. Copper concentrate dryer
Monitor control device parameters m (current)	0.5	365	182.5	2	365	18	37	$48,530					$48,530
ii. Smelting vessel
Inspect tapping hood system n (current)	4	12	48	2	96	5	10	$12,764					$12,764
Monitor control device parameters m (current)	0.5	365	182.5	2	365	18	37	$48,530					$48,530
iii. Slag cleaning vessel
Inspect tapping hood system n, o	4	12	48	1	48	2	5	$6,382					$6,382
Monitor control device parameters m, o	0.5	365	182.5	1	183	9	18	$24,265					$24,265
iv. Batch copper converters
Inspect converter hood system n	4	12	48	2	96	5	10	$12,764					$12,764
Monitor hood system ventilation parameters m	0.5	365	182.5	2	365	18	37	$48,530					$48,530
Monitor control device parameters m	0.5	365	182.5	2	365	18.25	36.5	$48,530					$48,530
v. Prepare fugitive dust control plan	100	1	100	0	0	0	0	$0					$0
vi. Monitor roof vents - CPMS on converter operations, smelting furnaces, anode refining p													$0
Daily for first 30 days	0.5	30	15	2	30	1.5	3	$3,989				$3,989
Weekly for remaining 48 weeks	0.5	48	24	2	48	2.4	4.8	$6,382				$6,382
vii. Monitoring processes and control devices for mercury compliance q	1	12	12	2	24	1.2	2.4	$3,191				$3,191
D. Develop record system j (current)	100	1	100	0	0	0	0	$0
E. Time to enter information r (current)	1	365	365	2	730	36.5	73	$97,060					$97,060
F. Time to train personnel s (current)	100	1	100	2	200	10	20	$26,592					$26,592
Subtotal for Recordkeeping Requirements					3,444			$398,147
TOTAL LABOR BURDEN AND COST (unrounded)								$745,675		Hours per response		125,220	620,456
TOTAL LABOR BURDEN AND COST (rounded) t					5,500			$750,000				$130,000	$620,000
										324
Assumptions:
a There are 2 existing sources currently subject to this rule. We estimate there will be no additional new source that will become subject to the rule over the 3-year period of this ICR.
b This ICR uses the following labor rates: $146.43 per hour for Executive, Administrative, and Managerial labor; $119.71 per hour for Technical labor, and $59.285 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2018, “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 The burden associated with the existing NESHAP for primary copper smelting is from the Information Collection Request Submitted to OMB for Review and Aproval; Comment Request; NESHAP for Primary Copper Smlters (Renewal). A Notice by the Environmental Protection Agency on 10/11/2018 (https://www.federalregister.gov/documents/2018/10/11/2018-22069/information-collection-request-submitted-to-omb-for-review-and-approval-comment-request-neshap-for). In some cases, it was necessary to modify the existing burden estimates due to changes in the affected respondents. At the time of the renewal burden estimate there were 3 facilities affected by the rule. At the time of this rulemaking, there are only 2 operating facilities. Therefore, the existing burden estimates were revised to reflect the changes in the number of affected facilities.
d We have assumed that all respondents will have to familliarize themselves with the regulatory requirements each year.
e We have assumed that each of the two respondents will take 120 hours, 4.5 times per year to conduct performance tests for PM as required under 40 CFR 63.1453.
f We have assumed that each of the three respondents will take 240 hours to conduct copper converter building performance test once per year.
g PM testing - Contractor cost based on the following: Testing anode refining point source at Asarco only. Includes initial performance test 1 year after promulgation of rule and test annually thereafter for a total of 2 tests during 3-yr period. Annual average cost = (1 test/yr x 2yr x $27000/test)/3 = $18,000/yr.
h PM testing - Contractor cost based on the following: 3 tests, 1 test each on the roof vents for the converter operations, smelting furnaces, and anode refining at Asarco. Includes the 3 initial performance tests 2 years after promulgation of rule for a total of one test during the 3-year period. Testing costs is estimated to be $95,000 and includes associated recordkeeping and reporting. Annual average cost = $95,000/3 = 31,667.
i Mercury testing - Contractor cost based on the following: 3 Method 29 tests to be conducted on smelting furnaces, converters, and anode refining at both of the 2 copper smelting facilities. The initial tests are required 1 year after rule is promulgation and annually thereafter for a total of 2 tests per facility over the 3 year period of this ICR. At a cost of $44,100 per facility per year,total cost for the 3-year period = ($44,100/test/facility/yr x 2 facilities x 2 test over the 3-yr ICR period)/3 = $58,800/yr.
j These requirements are one-time requirements that apply to new respondents. There are no new respondents estimated over the 3-year period of this ICR.
k It is assumed that the number of notices given for the performance testsunder the existing rule will include notices given for the new testing required.
l Submittal of performance test data through the EPA's CEDRI in ERT format is estimated to require 8 hours annually, includes keeping records of failures to meet the standards and the actions taken to minimize emissions. Electronic reporting replaces the manual reporting of performance testing.
m Recordkeeping requirements are required daily on all monitor control device parameters.
n We have assumed that inspections on all hood systems are done on a monthly basis.
o We have assumed that one of the two existing sources will be equipped with a slag cleaning vessel.
p We assumed each roof vent would be monitored daily for visible emissions using Method 22. After monitoring for 30 days with no visible emissions, the facility can reduce monitoring to once per week. The person hours per occurrence includes time to take the reading and to record the information.
q We assumed that each facility would monitor the operating parameters established during their performance test for mercury from the smelting furnace, converter, and anode refining. Monitoring would consist of checking the parameters once per month at each facility. It is estimated that 1 hour per month would be required at each facility.
r Each respondent is required to record information on a daily basis.
s We have assumed that it will take each of the respondent 100 hours to train personnel once a year
t Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Proposed Amendments)
					49.44	66.62	26.75
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 (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost, ($) b
Activity	N/A
Review reports
a. Initial notifications	2	1	2	0	0	0	0	$0
b. Notification of performance test c	2	5.5	11	2	22	1.1	2.2	$1,219.81
c. Performance test reports d	16	7.5	120	2	240	12	24	$13,307.04
d. Performance test reports (Asarco only) e	16	1.7	27.2	1	27.2	1.36	2.72	$1,508.13
e. Semiannual compliance reports f	8	2	16	2	32	1.6	3.2	$1,774.27
f. Initial compliance determination h	8	1	8	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded) g					369			$17,800
Assumptions:
a We have assumed that there are two sources that are subject to the standard, with no new additional sources expected over the next three years.
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 $66.62 (GS-13, Step 5, $41.07 + 60%), Technical rate of $49.44 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.75 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “Salary Table 2019-GS” which excludes locality rates of pay.
c We have assumed that EPA will take two hours to review each notification of performance test.
d We have assumed that EPA will take 16 hours to review each performance test report. Number of occurrences/yr (i.e., number of test reports to review each year) = 5.5 (current inventory) + 2 (Mercury tests for smelter, converter, and anode refining at each facility. 3 tests/facility/yr for 2 of the 3-yr ICR period = 3 test/yr/facility x 2 yr = 6 test/3 yr/ICR period/facility = 2 test/yr/facility) = 7.5 tests/yr/facility
e We have assumed that EPA will take 16 hours to review each performance test report. Number of occurrences/yr (i.e., number of test reports to review each year) = 0.67 (test for anode refining point source at Asarco only: 2 tests/3 yr period = 0.67 test/yr) + 1 (test roof vents from smelting, converter, anode refining at Asarco only 2 yrs after promulgation for 1 series of test for the 3 yr period: 3 tests/3-yr period = 1 test/yr) = 1.67 test/yr/facility
f We have assumed that EPA will take eight hours to review each semiannual compliance report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
h These requirements are one-time requirements that apply to new respondents. There are no new respondents estimated over the 3-year period of this ICR.