Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	117
Number of Respondents	100
Total Estimated Burden Hours	35,000
Total Estimated Costs	$4,800,000
Annualized Capital O&M	$14,700
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal)
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 (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		Total Number of Respondents			Respondent Rates (Source: United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian Workers, by occupational and industry group.”)
1. Applications	N/A									Number of sources established in 2012 final rule amendments	100		Labor Type	Loaded Rate (Rate + 110%rate)
2. Survey and Studies	N/A												Mgmt.	$172.41
3. Reporting requirements													Tech.	$141.75
A. Familiarization with regulatory requirements	1	1	1	100	100	5	10	$15,751					Cler.	$71.36
B. Required activities
Initial performance test c	125	1	125	0	0	0	0	$0
Repeat initial performance test c	125	0.2	25	0	0	0	0	$0
Periodic performance tests d, e	125	1	125	100	12,500	625	1,250	$1,968,831.25
Operation and maintenance plan	40	1	40	0	0	0	0	$0
Operation and maintenance plan revision f	20	1	20	10	200	10	20	$31,501.30
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Report
Notification of applicability g	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction g	2	1	2	0	0	0	0	$0
Notification of anticipated startup g	2	1	2	0	0	0	0	$0
Notification of actual startup g	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test g	2	1	2	0	0	0	0	$0
Notification of compliance status g	4	1	4	0	0	0	0	$0
NESHAP waiver application h	N/A
Report of initial and periodic performance tests	See 3B
Report of monitoring exceedances, including malfunctions i	16	2	32	20	640	32	64	$100,804.16
Report of no excess emissions j	8	2	16	80	1,280	64	128	$201,608.32
Reporting Subtotal					16,928			$2,318,496
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards k	3	52	156	100	15,600	780	1,560	$2,457,101.40
F. Time to train personnel	4	1	4	0	0	0	0	$0
G. Time to transmit or disclose information l	0.25	3	0.75	100	75	3.75	7.5	$11,812.99
H. Time for audits	N/A
Recordkeeping Subtotal					18,026			$2,468,914
TOTAL LABOR BURDEN AND COST (rounded) m					35,000			$4,790,000
TOTAL CAPITAL and O&M COSTS (rounded) m								$14,700
GRAND TOTAL (rounded) m								$4,800,000
							total # Responses	300
							hr/response	117
Assumptions:
a We have assumed that there are approximately 100 respondents subject to the standard (95 steel pickling and 5 acid regeneration facilities). We have further assumed that no additional respondent per year will become subject to the regulation in the next three years. Since there are no new respondents estimated, initial performance tests, initial operation and maintenance plans, and initial notifications do not apply.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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 each new respondent will be required to conduct an initial performance test and 20 percent will have to repeat this test. Since there are no new respondents estimated, these requirements do not apply.
d Each respondent is required to conduct a periodic performance test to measure either: (1) the HCl mass flows at the control device inlet and outlet or (2) the concentration of HCl exiting the control device. The test results must be reported within 2 months of the test date. Periodic performance tests must be conducted either annually or according to an alternative schedule that is approved by the applicable permitting authority, but no less frequently than every 2.5 years or twice per title V permit term. We are assuming that all periodic performance tests are conducted annually.
e We have assumed that it will take 125 hours for each respondent to complete the periodic performance test and report.
f We have assumed that 10 percent of respondents must write a revised operation and maintenance plan for each emission control device.
g We have assumed that all new sources will be required to meet initial notification requirements. Since there are no new respondents estimated, these requirements do not apply.
h We have assumed that no respondent will request a NESHAP waiver application.
i We have assumed that 20 percent of respondents will report excess emissions on a semiannual basis.
j We have assumed that 80 percent of respondents will report no excess emissions on a semiannual basis.
k We have assumed that each respondent will take three hours each week to record all information required by the standard.
l We have assumed that each respondent will take 15 minutes three times per year to transmit or disclose information.
m Totals have been rounded to 3 significant values. 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 Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal)
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 (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b			With Fringe & Overhead	Agency Rates Source: Office of Personnel Management (OPM), 2024 General Schedule
Report Review										(GS- 12, step 1) - Tech.	$57.07
New Sources										(GS- 13, step 5) - Mgmt.	$76.91
Notification of applicability c	2	1	2	0	0	0	0	$0		(GS-6, step 3) - Cler.	$30.88
Notification of construction/ reconstruction c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Notification of compliance status c	2	1	2	0	0	0	0	$0
Review of initial performance test report d	4	1	4	0	0	0	0	$0
Review of repeat initial performance test report d, e	4	0.2	0.8	0	0	0	0	$0
Existing Sources
Review of excess emissions report f	4	2	8	20	160	8	16	$9,746.48
Review of no excess emissions report g	2	2	4	80	320	16	32	$20,481.12
Review of periodic performance test report h	4	1	4	100	400	20	40	$25,601.40
Review of waiver application i	2	1	2	0	0	0	0	$0
TOTAL (rounded) j					1,010			$55,800
Assumptions:
a We have assumed that there are approximately 100 respondents subject to the standard. We have further assumed that no additional respondent per year will become subject to the regulation in the next three years. Since there are no new respondents estimated, initial performance tests and initial notifications do not apply.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 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 all new sources will be required to meet initial notification requirements. Since there are no new respondents estimated, these requirements do not apply.
d We have assumed that the Agency will take 4 hours to participate in the performance tests. Since there are no new respondents estimated, these requirements do not apply.
e We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, these requirements do not apply.
f We have assumed that 20 percent of respondents will report excess emissions on a semiannual basis.
g We have assumed that 80 percent of respondents will report no excess emissions on a semiannual basis.
h Periodic performance tests are submitted at least twice every 5 years (title V permit term), but may be required by the permitting authority to be submitted as frequently as annually. We assume that all periodic performance tests are conducted annually.
i We have assumed that no waiver application is expected.
j Totals have been rounded to 3 significant values. 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 Costs (E X F)
Flow-meters with high/low alarms	$1,151	0	$0	$147	100	$14,700			CEPCI 2008:	575.4
Note: Costs have been adjusted to 2023 dollars using the CEPCI index. Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.									CEPCI 2023:	797.9

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Sheet 5: 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 1	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	0	100	0	0	100
2	0	100	0	0	100
3	0	100	0	0	100
Average	0	100	0	0	100
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

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Sheet 6: 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 applicability	0	1	0	0
Notification of construction/reconstruction	0	1	0	0
Notification of anticipated startup	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of initial performance test	0	1	0	0
Notification of compliance status	0	1	0	0
NESHAP waiver application	0	1	0	0
Report of initial performance test	0	1	0	0
Report of periodic performance test	100	1	0	100
Report of monitoring exceedances, including results of annual performance test	20	2	0	40
Report of no excess emissions, including results of annual performance test	80	2	0	160
			Total	300