| Table 1: Annual Respondent Burden and Cost – NESHAP for Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal) |
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(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Burden item |
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, $ |
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| 1. Applications |
N/A |
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2022 Labor Rates |
| 2. Surveys and Studies |
N/A |
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Technical |
$163.17 |
| 3. Acquisition, Installation, and Utilization of Technology and Systems |
N/A |
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Management |
$130.28 |
| 4. Reporting Requirements |
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Clerical |
$65.71 |
| A. Familiarize with regulatory requirements c |
8 |
1 |
8 |
21 |
168 |
8.4 |
16.8 |
$29,610.84 |
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| B. Required activities d |
N/A |
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| Operating CEMS e |
0.25 |
365 |
91.25 |
4 |
365 |
18.25 |
36.5 |
$64,333.08 |
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| Weekly and monthly sampling |
1 |
52 |
52 |
17 |
884 |
44.2 |
88.4 |
$155,809.42 |
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| Annual Method 29 Performance Test f |
15 |
1 |
15 |
17 |
255 |
12.75 |
25.5 |
$44,945.03 |
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| C. Create information |
See 4B |
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| D. Gather existing information |
See 4B |
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| E. Write report |
See 4B |
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| Initial notification of applicability g |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status g |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Request for compliance extension |
N/A |
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| Site-specific test plan g |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Quality assurance plan for CEMS e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test g |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Startup, shutdown, malfunction plan g |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Annual performance test for Hg emissions f |
8 |
1 |
8 |
17 |
136 |
6.8 |
13.6 |
$23,970.68 |
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| Semiannual report of excess emissions h |
8 |
2 |
16 |
4.2 |
67.2 |
3.36 |
6.72 |
$11,844.34 |
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| Subtotal for Reporting Requirements |
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2,156 |
$330,513 |
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| 5. Recordkeeping Requirements |
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| A. Familiarize with regulatory requirements |
See 4A |
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| B. Plan activities |
See 4A |
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| C. Implement activities |
See 4A |
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| D. Develop record system |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to enter information |
0.5 |
52 |
26 |
21 |
546 |
27.3 |
54.6 |
$96,235.23 |
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| F. Time to transmit or disclose information |
0.25 |
2 |
0.5 |
21 |
10.5 |
0.53 |
1.05 |
$1,850.68 |
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| G. Time to adjust existing ways |
2 |
1 |
2 |
21 |
42 |
2.1 |
4.2 |
$7,402.71 |
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| H. Time to train personnel |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| I. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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688 |
$105,489 |
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Responses |
Hrs/Response |
| TOTAL LABOR BURDEN AND COST (rounded) i |
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2,840 |
$436,000 |
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25 |
114 |
| TOTAL CAPITAL AND O&M COST (rounded) i |
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$227,000 |
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| GRAND TOTAL (rounded) i |
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$663,000 |
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| Assumptions: |
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| a We assume there are 21 existing facilities subject to the rule and no additional sources will become subject to the rule during the three-year period of this ICR. |
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| b This ICR uses the following labor rates: $163.17 per hour for Executive, Administrative, and Managerial labor; $130.28 per hour for Technical labor, and $65.71 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been 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. |
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| c This ICR assumes all existing sources will have to familiarize with the regulatory requirements each year. |
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| d Rule will require operating CEMS, weekly sampling, and monthly sampling. |
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| e Assumes 4 roaster stacks will be equipped with mercury CEMS, and that QA plan has already been developed during initial rule compliance. |
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| f We assume it will take 5 hours to test each stack and that each test will require 3 technicians to complete. 5 hours 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. |
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| g These requirements apply only to new sources. |
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| h Assumes 20% of existing facilities (21 x 20% = 4.2 facilities) will need to submit excess emissions reports. |
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| i 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 Gold Mine Ore Processing (40 CFR Part 63, Subpart EEEEEEE) (Renewal)
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(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Burden Item |
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, $ |
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| Observe performance test c |
16 |
1 |
16 |
1 |
16 |
0.8 |
1.6 |
$1,266.17 |
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2019 Labor Rates |
| Report Review: |
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Technical |
$73.46 |
| Initial notification of applicability d |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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Management |
$54.51 |
| Notification of compliance status d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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Clerical |
$29.50 |
| Notification of performance test d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Deviation reports |
N/A |
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| Startup, shutdown, malfunction plan d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Semiannual excess emissions report e |
1 |
2 |
2 |
4.2 |
8.4 |
0.42 |
0.84 |
$664.74 |
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| Annual performance test report for Hg emission f |
1 |
1 |
1 |
17 |
17 |
0.85 |
1.7 |
$1,345.30 |
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| TOTAL COST (rounded) g |
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48 |
$3,280 |
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| Assumptions: |
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| a We assume there are 21 existing facilities subject to the rule and no additional sources will become subject to the rule during the three-year period of this ICR. |
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| b This ICR uses the following labor rates: $73.46 for managerial, $54.51 for technical, and $29.50 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2023 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. |
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| c Assumes Agency staff will observe the performance test of one affected plant per year. |
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| d These requirements apply only to new sources. |
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| e Assumes 20% of existing facilities (21 x 20% = 4.2 facilities) will need to submit excess emissions reports. |
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| f 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. |
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| g 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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| 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, |
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(E X F) |
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| Monitoring equipment 1 |
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| $9,085 |
0 |
$0 |
$0 |
0 |
$0 |
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| Method 29 Hg stack sampling 2 |
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| NA |
NA |
NA |
$9,420 |
17 |
$160,140 |
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| Material and supply 3 |
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| NA |
NA |
NA |
$3,190 |
21 |
$66,990 |
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Totals |
| Total 4 |
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$0 |
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$227,000 |
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$227,000 |
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| 1 Annualized installed capital cost is $190,790 per year for the source category, based on a capital recovery factor of 0.1424 (10-year life at 7%), and a total installed capital cost of $1.34 million for monitoring equipment. We assume no new sources will become subject over the three-year period of this ICR. |
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| 2 Annualized cost for Method 29 stack sampling for mercury on 17 process units 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. |
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| 3 O&M costs are for materials and supplies (e.g., sorbent trap tubes, calibration standards) estimated as 5% of the installed capital cost ($1.34 million). |
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| 4 Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. |
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| 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 |
| Initial notification of applicability |
0 |
1 |
0 |
0 |
| Initial notification of compliance status |
0 |
1 |
0 |
0 |
| Notification of performance test |
0 |
1 |
0 |
0 |
| Test plan |
0 |
1 |
0 |
0 |
| QA plan for CEMS |
0 |
1 |
0 |
0 |
| Startup, shutdown, and malfunction (SSM) plan |
0 |
1 |
0 |
0 |
| Annual performance test for Hg emissions 1 |
17 |
1 |
0 |
17 |
| Semiannual reports of excess emissions 2 |
4.2 |
2 |
0 |
8.4 |
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Total (rounded) |
25 |
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| 1 Method 29 stack sampling for mercury on 17 process units outside of Nevada. Facilities in Nevada already perform annual sampling and analysis for mercury; consequently, those facilities will not incur any additional stack testing burden under this rule. |
| 2 We assume 20% of the 21 facilities will have excess emissions reports. |