| Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Primary Copper Smelters (40 CFR Part 61, Subpart O) (Renewal) |
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| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (AxB) |
(D) Respondents 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) Total Cost Per year b |
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New Labor Rates |
| 1. Applications |
N/A |
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Managerial |
157.61 |
| 2. Surveys and studies |
N/A |
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Technical |
123.94 |
3. Acquisition, Installation, and
Utilization of Technology and
Systems |
N/A |
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Clerical |
62.52 |
| 4. Reporting Requirements |
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| A. Familiarization with regulatory requirements |
1 |
1 |
1 |
3 |
3 |
0.15 |
0.3 |
$414.22 |
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| B. Required activities |
N/A |
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| C. Create information c |
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| i. Initial Method 5 performance testc |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| i. Grab Samples |
4 |
365 |
1460 |
3 |
4380 |
219 |
438 |
$604,757.55 |
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| ii. Method 108 Analysis |
4 |
12 |
48 |
3 |
144 |
7.2 |
14.4 |
$19,882.44 |
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| iii. Monthly Calculation |
2 |
12 |
24 |
3 |
72 |
3.6 |
7.2 |
$9,941.22 |
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| D. Gather existing information |
See 4E |
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| E. Write report |
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| i. Quarterly report of excess opacity and flow rates d |
16 |
2 |
32 |
3 |
96 |
4.8 |
9.6 |
$13,254.96 |
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| ii. Annual report of converter charging rate |
16 |
1 |
16 |
3 |
48 |
2.4 |
4.8 |
$6,627.48 |
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| iii. Notification of performance test |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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| Subtotal for Reporting |
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5454 |
$654,878 |
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| 5. Recordkeeping Requirements |
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| A. Familiarization with regulatory requirements |
See 4A |
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| B. Plan activities |
N/A |
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| C. Implement activities |
See 4C |
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| D. Record data |
8 |
1 |
8 |
3 |
24 |
1.2 |
2.4 |
$3,313.74 |
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| E. Time to transmit or disclose information |
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| 1. Record Method 108A analysis results |
2 |
12 |
24 |
3 |
72 |
3.6 |
7.2 |
$9,941.22 |
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#hrs |
6,260 |
| 2. Monthly measurements |
1.5 |
12 |
18 |
3 |
54 |
2.7 |
5.4 |
$7,455.92 |
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#responses |
9 |
| 3. Daily log of converter operating mode and daily record of matte charge to converter |
0.5 |
365 |
182.5 |
3 |
547.5 |
27.375 |
54.75 |
$75,594.69 |
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hrs/response |
696 |
| F. Time to train personnel |
N/A |
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| G. Time for audits |
N/A |
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| Subtotal for Recordkeeping |
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802 |
$96,306 |
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| TOTAL LABOR BURDEN AND COST e |
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6,260 |
$751,000 |
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6,260 |
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| TOTAL ANNUAL COSTS (O&M) e |
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$1,500 |
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| GRAND TOTAL e |
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$753,000 |
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| a It is assumed that there are 3 respondents currently operating in the United States. It is estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector. |
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| 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, September 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 benefit packages available to those employed by private industry. |
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| c The burden to report information includes labor to perform Method 108A analysis once a month; obtain a grab sample daily; labor to reduce opacity and air flow data; and labor to perform monthly calculations. The estimated time to collect grab samples is 4 hours and the time for monthly calculations is 2 hours based on data provided by an individual facility subject to the NESHAP. The time to record results is 2 hours based on data provided by an individual facility subject to the NESHAP. |
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| d It is assumed that respondents will only need to submit excess opacity or air flow rate reports twice a year. |
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| e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Primary Copper Smelters (40 CFR Part 61, Subpart O) (Renewal) |
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| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Facilities per year a |
(D) Technical person- hours per year (CxD) |
(E) Management person hours per year (Ex0.05) |
(F) Clerical person hours per year (Ex0.1) |
(G) Cost, $ |
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New Labor Rates |
| Report Review: |
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Managerial |
70.56 |
| Review of annual report of feed arsenic content |
8 |
1 |
3 |
24 |
1.2 |
2.4 |
$1,409.57 |
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Technical |
52.37 |
| Review of quarterly excess emissions reports c |
2 |
2 |
3 |
12 |
0.6 |
1.2 |
$704.78 |
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Clerical |
28.34 |
| TOTAL BURDEN AND COST d |
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41 |
$2,110 |
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| a It is assumed that there are 3 respondents currently operating in the United States. It is estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector. |
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| b This ICR uses the following labor rates: $70.56 per hour for Managerial labor; $52.37 per hour for Technical labor, and $28.34 per hour for Clerical labor. 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% to account for the benefit packages available to government employees. |
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| c It is assumed that respondents will only need to submit excess opacity or air flow rate reports twice a year. |
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| d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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| Monitoring Requirement |
Capital/Startup Cost for One Respondent |
Number of New Respondents a |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M b |
Total O&M,
(E X F) |
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| Method 108A analyses of copper matte samples |
$0 |
0 |
$0 |
$500 |
3 |
$1,500 |
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| Totals (rounded) |
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$0 |
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$1,500 |
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$1,500 |
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| Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. |
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