Burden Calculations

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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 Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal)
					106.45	138.43	52.77
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent	Person-hours per respondent per year (C=AxB)	Respondents 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)	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. Familiarize with regulatory requirements c	8	1	8	21	168	8.4	16.8	$19,932.95
B. Required activities d	N/A
Operating CEMS e	0.25	365	91.25	4	365	18.25	36.5	$43,306.70
Weekly and monthly sampling	1	52	52	17	884	44.2	88.4	$104,885.27
Annual Method 29 Performace Test h	15	1	15	17	255	12.75	25.5	$30,255.37
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicability f	2	1	2	0	0	0	0	$0
Notification of compliance status f	2	1	2	0	0	0	0	$0
Request for compliance extension	N/A
Site-specific test plan f	4	1	4	0	0	0	0	$0
Quality assurance plan for CEMS e	8	1	8	0	0	0	0	$0
Notification of performance test f	2	1	2	0	0	0	0	$0
Startup, shutdown, malfunction plan f	4	1	4	0	0	0	0	$0
Annual performance test for Hg emissions	8	1	8	17	136	6.8	13.6	$16,136.20
Semiannual report of excess emissions g	8	2	16	4.2	67.2	3.36	6.72	$7,973.18
Subtotal for Reporting Requirements					2,156			$222,490
5. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 4A
B. Plan activities	See 4A
C. Implement activities	See 4A
D. Develop record system	4	1	4	0	0	0	0	$0
E. Time to enter information	0.5	52	26	21	546	27.3	54.6	$64,782.08
F. Time to transmit or disclose information	0.25	2	0.5	21	10.5	0.53	1.05	$1,245.81
G. Time to adjust existing ways	2	1	2	21	42	2.1	4.2	$4,983.24
H. Time to train personnel	4	1	4	0	0	0	0	$0
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					688			$71,011		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) i					2,840			$294,000		25	114
CAPITAL AND O&M COST (rounded) i								$227,000
GRAND TOTAL (rounded) i								$521,000
Assumptions:
a We assume there are 21 existing facilities subject to the rule and no additional sources will become subjet to the rule during the three year period of this ICR.
b This ICR uses the following labor rates based on Department of Labor, Bureau of Labor Statistics (BLS) data “Table 2 Civilian Workers, by Occupational and Industry group. --$138.43 per hour for Executive, Administrative, and Managerial labor; $106.45 per hour for Technical labor, and $52.77 per hour for Clerical labor. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c This ICR assumes all existing sources will have to familiarize with the regulatory requirements each year.
d Rule will require operating CEMS, weekly sampling, and monthly sampling.
e Assumes 4 roaster stacks will be equipped with mercury CEMS, and that QA plan has already been developed during initial rule compliance.
f Assumes existing gold mine ore processing facilities have already complied with initial rule requirements.
g Assumes 20% of existing facilities (21 x 20% = 4.2 facilities) will need to submit excess emissions reports.
h Based on comments from the Nevada Mining Association, we assume it will take 5 hours to test each stack and that each test will require 3 technicians to complete. 5 hour x 3 technicians = 15 hours/stack. This ICR only calculates burden for Method 29 testing for 17 process units located outside of Nevada. Facilities in Nevada already perform annual sampling and analysis for mercury to comply with the Nevada Division of Environmental Protection. Consequently, those facilities will not incur any additional stack testing burden under this rule.
i 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 Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal)
					47.62	64.16	25.76
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Person hours per occurrence	Occurrences per respondent	EPA Person-hours per plant (C=AxB)	Plants per year a	Technical hours/year (E=CxD)	Management hours/year (F=Ex0.05)	Clerical-hours/year (G=Ex0.1)	Total Cost per year b, $
Observe performance test c	16	1	16	1	16	0.8	1.6	$854.46
Report Review:
Initial notification of applicability d	1	1	1	0	0	0	0	$0
Notification of compliance status d	2	1	2	0	0	0	0	$0
Notification of performance test d	2	1	2	0	0	0	0	$0
Deviation reports	N/A
Startup, shutdown, malfunction plan d	2	1	2	0	0	0	0	$0
Semiannual excess emissions report e	1	2	2	4.2	8.4	0.42	0.84	$448.59
Annual performance test report for Hg emission	1	1	1	17	17	0.85	1.7	$907.87
TOTAL ANNUAL BURDEN AND COST (rounded) f					48			$2,210
Assumptions:
a We assume there are 21 existing facilities subject to the rule and no additional sources will become subjet to the rule during the three year period of this ICR.
b This ICR uses the following labor rates: $47.63 for technical, $64.16 for managerial, and $25.76 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2016 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 Assumes Agency staff will observe the performance test of one affected plant per year.
d Assumes existing gold mine ore processing facilities have already complied with initial rule requirements.
e Assumes 20% of existing facilities (21 x 20% = 4.2 facilities) will need to submit excess emissions reports.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.