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	29
Number of Respondents	164
Total Estimated Burden Hours	13,000
Total Estimated Costs	$5,160,000
Annualized Capital O&M	$4,650,000
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart RRR) (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 (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Applications	N/A
2. Surveys and studies	N/A
3. Acquisition, installation, and utilization of technology and systems c	54	1	54	1.3	72.0	3.6	7.2	$11,340.47
4. Reporting requirements
a. Familiarization with Regulatory Requirements d	1	1	1	164	163.7	8.2	16.4	$25,778.04
b. Required activities											Labor Rates
Initial performance test e, f	24	1	24	1.3	32.0	1.6	3.2	$5,040.21			Technical	$141.75
Repeat performance test e, f	24	0.2	4.8	1.3	6.4	0.3	0.6	$1,008.04			Management	$172.41
Operating, maintenance and monitoring plan e, f	32	1	32	1.3	42.7	2.1	4.3	$6,720.28			Clerical	$71.36
Startup, shutdown, malfunction (SSM) plan	N/A
c. Create information	See 4B
d. Gather existing information	See 4B
e. Write report
Notification of applicability e, f	2	1	2	1.3	3	0.13	0.27	$420.02
Notification of construction/reconstruction	N/A
Notification/report of actual startup	N/A
Notification of special compliance requirements	N/A
Notification of performance test e	2	1	2	1.3	3	0.13	0.27	$420.02
Notification of compliance status e	4	1	4	56	224.0	11.2	22.4	$35,281.46
Waiver application g	2	1	2	0	0	0	0	$0.00
Report of performance test	See 4B
Semiannual reports h	8	2	16	164	2,619	131	262	$412,448.62
Changing furnace classification i	2	1	2	51	101.9	5.1	10.2	$16,044.14
Subtotal for Reporting Requirements					3,757			$514,501
5. Recordkeeping requirements
a. Familarization with Regulatory Requirements	See 4A
b. Plan activities	See 4E
c. Implement activities	See 4B
Verify lime injection rate	0.1	36	3.6	164	589	29.5	58.9	$92,800.94
Changing furnace classification i	2	1	2	51	102	5.1	10.2	$16,044.14
d. Develop record system	N/A
e. Time to enter/transmit information
Records of all information required by the standards	N/A
Major sources j	1.5	52	78	56	4,368	218.4	436.8	$687,988.39
Area sources k	0.5	52	26	108	2,808	140.4	280.8	$442,278.25
f. Time to train personnel l	4	1	4	1.3	5	0.3	0.5	$840.03
g. Time to adjust existing ways to comply with previous applicable requirements	N/A
h. Time to disclose information
New sources m	0.25	2	0.5	1.3	1	0.03	0.07	$105.00
All sources n	0.25	2	0.5	164	82	4.09	8.18	$12,889.02
Sources that changed furnace classification i	1	1	1	51	51	2.55	5.09	$8,022.07
i. Time for audits	N/A									Responses	Hr/Response
Subtotal for Recordkeeping Requirements					9,207			$1,252,946
TOTAL LABOR BURDEN AND COST (rounded) o					13,000			$510,000		441	29
TOTAL CAPITAL AND O&M COSTS (rounded) o								$4,650,000
GRAND TOTAL (rounded) o								$5,160,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 164, of which 56 are major sources. There will be approximately 1.3 new sources per year over the three-year period of this ICR.
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 it will take each new respondent 54 hours to complete the task. This burden cost is associated with the monitoring of all control equipment ensuring that respondents of new respondents meet the required specifications of this subpart. No additional new major or areas sources are anticipated over the three-year period of this ICR.
d We have assumed that it will take each respondent one hour to read and understand the reporting requirements.
e It is assumed that new area sources will comply by meeting the equipment specifications rather than by conducting performance tests. Respondents that are major sources are required to demonstrate initial compliance with the applicable emission limit, equipment, work practice, or operational standard for affected source or emission unit and report results in the notification of compliance status report.
f We have assumed new major sources will conduct initial performance tests. We have determined that respondents of new area sources will not be required to conduct emissions testing to show compliance with the emission limit, since it was determined that sweat furnaces sold in the United States now have an afterburner installed and meet the design residence time of 0.8 seconds or greater and an operating temperature of 1600 oF or greater. All new respondents are required to submit for approval an operation, maintenance and monitoring plan for affected sources.
g It is assumed that there will be no new sources requiring a waiver from the performance test requirements.
h It is assumed that each respondent will take 8 hours to write semiannual report of excess emissions or no excess emissions.
i An estimated 51 facilities would change furnace classifications once per year.
j It is assumed that it will take 1.5 hours for major source respondents to enter and transmit records.
k It is assumed that it will take 0.5 hours for existing area source respondents to enter and transmit records.
l We have assumed that it will take 4 hours to train new employees.
m We have assumed that it will take 0.25 hours to each new respondent to disclose information.
n We have assumed that it will take 0.25 hours for each respondent to disclose information.
o Totals have been rounded to 3 significant figures. 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 Secondary Aluminum Production (40 CFR Part 63, Subpart RRR) (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-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
Initial performance tests	40	1.4	56	1.3	75	3.73	7.47	$4,779		Labor Rates
Report performance test including retesting c	48	1	48	1.3	64	3.2	6.4	$4,096		Managerial	$76.91
Notification of applicability	0.5	1	0.5	1.3	0.67	0.03	0.07	$43		Technical	$57.07
Notification of construction/reconstruction	N/A									Clerical	$30.88
Notification of actual startup	N/A
Notification of special compliance requirements	N/A
Notification of performance test	2	1	2	1.3	2.66	0.13	0.27	$170
Notification of compliance status d	2	1	2	56	112	5.6	11.2	$7,169
Report of performance test c	40	1	40	1.3	53	2.67	5.33	$3,414
Repeat of performance test report c	40	1	40	1.3	53	2.67	5.33	$3,414
Semiannual reports e	4	2	8	164	1,309	65	131	$83,803
Review performance test reports and reports from facilities changing furnace classification f	4	1	4	60	240	12	24	$15,361
TOTAL (rounded) i					2,200			$122,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 164, of which 56 are major sources. There will be approximately 1.3 new sources per year over the three-year period of this ICR.
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 existing respondents are in compliance with the initial rule requirements.
d We have assumed that it will take 2 hours for each respondent to complete notification of compliance status.
e We have assumed that each existing respondent will take 4 hours two times per year to complete the semiannual reports.
f Assumes Agency will review all annual reports, including 4 HF tests/yr, 5 tests/yr for uncontrolled furnaces, and 51 reports/yr for changing furnace classification.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
h Assumes that 10 percent of plants per year (0.1×6 = 0.6, rounded to 1) will report a malfunction incident.
i Totals have been rounded to 3 significant figures. 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, (E x F)
Bag leak detectorsa	$291,111	1.3	$387,178	$66,667	19	$1,266,673
Flow Metersb	$3,000	1.3	$3,990	$0	0	$0
Continuous opacity monitorsc	$36,000	0	$0	$7,500	0	$0
Temporary hoodsd	$21,650	109	$2,359,716	$0	0	$0
HF testinge	$11,000	1.3	$14,630	$11,000	8	$89,640
Furnace testingf	$10,000	1.3	$13,300	$10,000	51	$509,317
Temperature monitorsg	$1,200	1.3	$1,596	$0	0	$0	Totals
Totals (rounded) h			$2,780,000			$1,870,000	$4,650,000
Assumptions:
a  Assume that 34 percent of major sources (or 19 respondents) will use bag leak detectors on fabric filters with an average cost to industry at $291,111. The actual cost of the bag leak detectors depends on the number of probes on the unit, and O&M costs for bag leak detectors is approximately $66,667.
b  The operation and maintenance costs of chlorine flow meters are negligible.
c  Sources with fabric filters will be complying with the monitoring requirements through the use of a bag leak detector or visible emissions observations and not continuous opacity monitors.
d  An estimated 109 furnaces and 28 facilities would need temporary hoods installed every 5 years and testing conducted. Total annualized cost per furnace would average $21,650 per year.
e  An estimated 8 affected facilities would incur a total annual O&M cost of $11,000 for measurement of hydrogen fluoride (HF) emissions.
f   Switching furnace classifications would result in total annual O&M costs for testing of $500,000/yr or, for an estimated 51 furnaces, a cost of $10,000 per furnace.
g  Temperature monitors will be installed at new sweat furnaces at a cost of $1,200. The O&M costs for temperature monitors are negligible.
h  Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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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	1.3	161.0	0	0	162
2	1.3	162.3	0	0	164
3	1.3	163.7	0	0	165
Average	1.3	162.3	0	0	164
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	1.3	1	0	1.33
Notification of construction/reconstruction	1.3	1	0	1.33
Notification of actual startup	1.3	1	0	1.33
Notification of special compliance requirements	1.3	1	0	1.33
Notification of performance test	1.3	1	0	1.33
Notification of compliance status	56	1	0	56
Waiver application	0	1	0	0
Semiannual reports	164	2	0	327
Changing furnace classification	51	1	0	51
		Total (rounded)		441