Burden Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Respondent	49
Number of Respondents	16
Total Estimated Burden Hours	3,100
Total Estimated Costs	$470,000
Annualized Capital O&M	$79,400
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical Person-hours per occurrence	No. of occurrences per respondent per year	Technical 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		Labor Rates
1. Applications	N/A									Management	$163.17
2. Survey and Studies	N/A									Technical	$130.28
3. Reporting requirements										Clerical	$65.71
A. Familiarize with regulatory requirements c	1	1	1	16	16	0.8	1.6	$2,320.15
B. Required Activities	N/A
Initial performance emission tests d	80	1	80	0	0	0	0	$0.00
Repeat of performance emission tests d	80	0.2	16	0	0	0	0	$0.00
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Application of construction or modification	2	1	2	0	0	0	0	$0.00
Notification of anticipated startup	2	1	2	0	0	0	0	$0.00
Notification of actual startup	2	1	2	0	0	0	0	$0.00
Source status report	2	1	2	0	0	0	0	$0.00
Notification of initial performance emission test	2	1	2	0	0	0	0	$0.00
Report of initial performance emission test	See 3B
Report results of continuous monitoring system (CMS) evaluation	See 3B
Report of arsenic emission estimates e	16	2	32	15	480	24	48	$69,604.56
Report of uncontrolled arsenic emission rates f	8	2	16	15	240	12	24	$34,802.28
Request approval of control device bypass g	6	1	6	1	6	0.3	0.6	$870.06
Semiannual excess emissions (opacity) h	16	2	32	1	32	1.6	3.2	$4,640.30
Subtotal for Reporting Requirements					890			$112,237
4. Recordkeeping Requirements
A. Familiarize 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 i	40	1	40	16	640	32	64	$92,806.08
Record continuous opacity and temperature of gas entering control device	See 4E
Records of emission test results	See 4E
Records of CMS performance evaluations	See 4E
Occurrence and duration of startup, shutdown, and malfunction of furnace	See 4E
Records of malfunction of control device	See 4E
Periods when monitors are inoperative	See 4E
Maintain and repair of control device, CMS, or monitors	See 4E
Records of approved control device bypass	See 4E
Semiannual records of uncontrolled arsenic emission rate j	40	2	80	16	1,280	64	128	$185,612.16		49	hr/response
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,208			$278,418
TOTAL LABOR BURDEN AND COST (rounded) k					3,100			$391,000
TOTAL CAPITAL AND O&M COST (rounded) k								$79,400
GRAND TOTAL (rounded) k								$470,000
Assumptions:
a We have assumed that there are 16 existing sources, and that no additional new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) 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.
c We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take eighty hours to complete performance tests and 20% of sources will have to repeat performance tests.
e We have assumed that fifteen respondents will write a report of arsenic emission estimates on a semiannual basis.
f We have assumed that fifteen respondents will write a report of uncontrolled arsenic emission rates on a semiannual basis.
g We have assumed that one respondent will write a report requesting approval of control device bypass once a year.
h We have assumed that one respondent will write an excess emissions report semiannually.
i It will take each respondent forty hours to enter information.
j It will take each respondent forty hours twice a year to record uncontrolled arsenic emission rate.
k 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 Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical Person-hours per occurrence	No. of occurrences per year	Technical Person-hours per Plant 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		Labor Rates
Activities										Management	$73.46
New facility										Technical	$54.51
Initial performance test c	24	1	24	0	0	0	0	$0.00		Clerical	$29.50
Repeat performance test d	24	0.2	4.8	0	0	0	0	$0.00
Review reports
New facility
Construction or modification application	0.5	1	0.5	0	0	0	0	$0.00
Notification of anticipated startup	0.5	1	0.5	0	0	0	0	$0.00
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0.00
Source status report	0.5	1	0.5	0	0	0	0	$0.00
Notification of initial performance emissions test	0.5	1	0.5	0	0	0	0	$0.00
Report of initial performance emissions test results	8	1	8	0	0	0	0	$0.00
Notification of physical or operational change	0.5	1	0.5	0	0	0	0	$0.00
Notification of emissions test	0.5	1	0.5	0	0	0	0	$0.00
Report results of CMS evaluation	8	1	8	0	0	0	0	$0.00
Existing facility
Report of arsenic emission estimates rates e	4	1	4	15	60	3	6	$3,667.98
Reports of uncontrolled arsenic emission rates f	8	1	8	15	120	6	12	$7,335.96
Semiannual excess emissions g	6	2	12	1	12	0.6	1.2	$733.60
Request approval of control device bypass h	6	1	6	1	6	0.3	0.6	$366.80
TOTAL LABOR BURDEN AND COST (rounded) i					228			$12,100
Assumptions:
a We have assumed that there are 16 existing sources, and that no additional new sources will become subject to the rule over the next three years.
b The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $73.456 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.512 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.504 (GS-6, Step 3, $18.44 + 60%). 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.
c We have assumed that it will take twenty four hours to perform initial performance test.
d We have assumed that 20% of sources will take twenty four hours to repeat performance test.
e We have assumed that reports submitted by the fifteen respondents will be reviewed once a year. These reports are submitted semiannually.
f We have assumed that it will take eight hours to review reports of uncontrolled arsenic emission rates once a year. These reports are submitted semiannually.
g It is required that excess emissions reports are reviewed on a semiannual basis.
h We have assumed that the report requesting approval of control device bypass will be reviewed once a year.
i 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 a	Number of New Respondents b	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M b	Total O&M, (E X F)
Continuous Opacity Monitor	N/A	N/A	$0	$4,254	16	$68,071		2008 CEPCI CE Index	575.4
Temperature Monitor	N/A	N/A	$0	$709	16	$11,345		2022 CEPCI CE Index	816
Totals (rounded) c			$0			$79,400		$79,400
a Capital/startup costs and O&M costs have been updated from 2008 dollars to 2022 dollars using the CEPCI CE Index. [2008 CEPCI = 575.4; 2022 CEPCI = 816]
b We have assumed that there are 16 existing sources, and that no additional new sources will become subject to the rule over the next three years.
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Application of construction or modification	0	1	0	0
Notification of anticipated startup	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of initial performance test	0	1	0	0
Source status report	0	1	0	0
Report of performance test results	0	1	0	0
Report of arsenic emission estimates	15	2	0	30
Report of uncontrolled arsenic emission rates	15	2	0	30
Request for approval of control device bypass	1	1	0	1
CMS evaluation results report	0	1	0	0
Semiannual excess emissions report	1	2	0	2
			Total	63

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Sheet 6: 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 a	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	16	0	0	16
2	0	16	0	0	16
3	0	16	0	0	16
Average	0	16	0	0	16
a New respondents include sources with constructed, reconstructed, and modified affected facilities.