SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Ferroalloys Production Area Sources (Renewal), EPA ICR Number 2303.04, OMB 

Control Number 2060-0625. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the 

Ferroalloys Production Area Sources were proposed on September 15, 2008 (73 FR 53163) and 

promulgated on December 23, 2008 (73 FR 78637). These regulations apply to existing and new 

ferroalloy production facilities that are an area source of hazardous air pollutant (HAP) 

emissions. A ferroalloys production facility manufactures silicon metal, ferrosilicon, 

ferrotitanium using the aluminum reduction process, ferrovanadium, ferromolybdenum, calcium 

silicon, silicomanganese zirconium, ferrochrome silicon, silvery iron, high-carbon ferrochrome, 

charge chrome, standard ferromanganese, ferromanganese silicon, calcium carbide or other 

ferroalloy products using electrometallurgical operations including electric arc furnaces (EAFs) 

or other reaction vessels. New facilities include those that commenced construction or 

reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR Part 63, Subpart YYYYYY.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Over the next three years, an average of 10 respondents per year will be subject to these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office. The required annual reports are 

used to determine periods of excess emissions, identify problems at the facility, verify

operation/maintenance procedures and for compliance determinations.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance”.
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2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from ferroalloys production area sources

cause or contribute to air pollution that may reasonably be anticipated to endanger public health 

or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 

63, Subpart YYYYYY.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the

applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. The 

performance test may also be observed.
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The required annual reports are used to determine periods of excess emissions, identify

problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted its own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted Metallurg Vanadium at (740) 432-6534.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 
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applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

the Part 70 permit program and the five year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are ferroalloys 

production facilities. The United States Standard Industrial Classification (SIC) codes for the 

respondents affected by the standards and the corresponding North American Industry

Classification System (NAICS) codes are listed in the table below. 

Standard (40 CFR Part 63, Subpart YYYYYY) SIC Codes NAICS Codes

Primary Smelting and Refining of Nonferrous Metal 

(except Copper and Aluminum)

3339 331419
5

Electrometallurgical Ferroalloy Product 3313 331112

All Other Basic Inorganic Chemical Manufacturing 2819 and 2869 325188

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Ferroalloys Production Area Sources.

A source must make the following reports:

Notifications

Notification of applicability 63.9(b)(2), 

63.11529(a)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of performance test 63.9(e)

Notification of opacity/VE observations 63.9(f)

Additional CMS notifications 63.9(g)

Notification of compliance status 63.9(h), 63.11529(b)

Notification of changes in information 63.9(j)

Reports

SSM plan 63.6(e)(3)

Bag leak detection system monitoring plan 63.11527(a)(5)

CMS quality control plan 63.8(d)

CMS performance evaluation test plan 63.8(e)(3)

CMS performance evaluation/report 63.8(e)(5)

SSM report 63.6(e)(3)

Excess emissions reports 63.10(e)(3)

Annual compliance certifications 63.11529(c)

A source must keep the following records:
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Recordkeeping

Records of notifications 63.10, 

63.11529(d)(1)

Records that demonstrate continuous compliance 63.10, 

63.11529(d)(2)

Monitoring information 63.10, 

63.11529(d)(2)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Method 22/9(c) test, and repeat performance tests 

if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.
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5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard (note the operating conditions under which compliance was 

achieved). Data and records maintained by the respondents are tabulated and published for use 

in compliance and enforcement programs. The annual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

The majority of respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the

development of the regulation. Due to technical considerations involving the process operations 
8

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys

Production Area Sources (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 345 (Total Labor Hours from Table 1). These hours 

are based on Agency studies and background documents from the development of the regulation, 

Agency knowledge and experience with the NESHAP program, the previously approved ICR, 

and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs
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The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs. 

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

The only type of industry costs associated with the information collection activity in the 

regulations are labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$1,256. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 

Ferroalloys Production Area Sources (Renewal). 

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

10 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 10 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports
10

Number of Respondents

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents2

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 10 0 0 10

2 0 10 0 0 10

3 0 10 0 0 10

Average 0 10 0 0 10

1

New respondents include sources with constructed, reconstructed and modified affected facilities.

2 Column D is subtracted to avoid double-counting respondents. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

One-time initial notification 0 1 00

One-time notifications of 

compliance status 0 1 0

0

Annual compliance 

certifications 10 1 0

10

Annual reports of exceedances 2 1 0 2

Total 12

The number of Total Annual Responses is 12. 

The total annual labor costs are $35,000. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production 

Area Sources (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 
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(i) Respondent Tally

The total annual labor hours are 350. Details regarding these estimates may be found in 

Table 1. Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production Area 

Sources (Renewal). We assume that burdens for managerial tasks take 5% of the time required 

for technical tasks because the typical tasks for managers are to review and approve reports. 

Clerical burdens are assumed to take 10% of the time required for technical tasks because the 

typical duties of clerical staff are to proofread the reports, make copies and maintain records. 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 30 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are zero. The cost 

calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 28

labor hours at a cost of $1,300. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Ferroalloys Production Area Sources (Renewal). 

6(f) Reasons for Change in Burden

There is a slight increase of five hours in the total estimated respondent burden compared 

with the ICR current approved by OMB. This is due to the rounding of estimates. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 30 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 
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burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2014-0099. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0099 and OMB Control Number 2060-0625 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production Area Sources (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

(A) (B) (C) (D) (E) (F) (G) (H)

Personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent

Respondents 

per year

Technical 

personhour per 

year

Management 

person-hour 

per year

Clerical 

personhour per 

year

Cost, $ (a)

(A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, & Utilization of Tech. & 

Systems

40 1 40 0 0 0 0 $0 

4. Reporting Requirements

A. Read instructions (b) 4 1 4 0 0 0 0 $0 

B. Required Activities

One-time activity, Initial control device Method 

22 Planning N/A

One-time activity, Initial control device Method 

22 Test N/A

Periodic control device Method 22 2 2 4 19 76 3.8 7.6 $8,789.06 

Retest control device 2 1 2 1 2 0.1 0.2 $231.29 

Weekly VE check (19 control devices) 0.1 52 5.2 19 98.8 4.94 9.88 $11,425.78 

One-time activity, initial building opacity 

Method 9 (c) N/A

Periodic (semi-annual) building VE Method 22 2 2 4 10 40 2 4 $4,625.82 

Retest building opacity Method 9 10 0 0 0 $0 

C. Create information See 4B

D. Gather existing information See 4B

E. Write Report See 4B

Initial Notification 2 1 2 0 0 0 0 $0 

Notification of Compliance Status 4 1 4 0 0 0 0 $0 

Annual Compliance Certification (d) 4 1 4 10 40 2 4 $4,625.82 

Report of Exceedances (e) 2 1 2 2 4 0.2 0.4 $462.58 

Reporting Subtotal 300 $30,160.35 
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REPORTING/RECORDKEEPING 

REQUIREMENT

(A) (B) (C) (D) (E) (F) (G) (H)

Personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent

Respondents 

per year

Technical 

personhour per 

year

Management 

person-hour 

per year

Clerical 

personhour per 

year

Cost, $ (a)

(A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities See 5E

C. Implement activities See 5E

D. Develop record system See 5E

E. Time to enter information

Records of all info. required by standards (f) 0.3 12 3.6 10 36 1.8 3.6 $4,163.24 

F. Time to train personnel N/A

G. Time to adjust existing ways to comply w/ 

prev. appl. req.

N/A

H. Time to transmit or disclose information (g) 0.3 1 0.3 10 3 0.15 0.3 $346.94 

I. Time for audits N/A

Recordkeeping Subtotal 45 $4,510.17

Total Labor Burden and Cost 345 $34,670.52 

Capital and O&M Cost $0 

GRAND TOTAL1,2 $34,671 

Assumptions:

(a) Costs are based on the following 2014 OPM General Schedule hourly rates: technical at $103.97, management at $129.93, and clerical at $51.79.

(b) One-time activity. There are an estimated 10 existing ferroalloys production facilities and no new facilities are expected.

(c)One-time activity. Assume the facilities hire a contractor.

(d) The 10 existing plants would be required to submit and Annual Compliance Certification at the end of Year 1 of the ICR and each year thereafter.

(e) Assumes that 2 facilities per year would have to submit a report of exceedance.

(f) Recordkeeping requirements begin in Year 1 of ICR clearance period for all existing plants.
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(g) Transmittals would include Annual Compliance Certifications for 10 plants.

N/A = Not Applicable.

Note: Totals in the text have been rounded to 3 significant values. Figures may not add exactly due to rounding. 
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Ferroalloys Production Area Sources (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

(A) (B) (C) (D) (E) (F) (G) (H)

Personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent

Respondents 

per year

Technical 

personhours

Managerial 

personhours

Clerical 

personhours

Cost, $ 

(a)

(A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10

Report Review:

 Initial Notification of applicability (b) 1 1 1 0 0 0 0 $0 

 Notification of Compliance Status (c) 2 1 2 0 0 0 0 $0 

 Annual Compliance Certification (d) 2 1 2 10 20 1 2 $1,046.80

 Annual Report of Deviations (e) 2 1 2 2 4 0.2 0.4 $209.36 

GRAND TOTAL (rounded) 28 $1,256 

Assumptions:

(a) Costs are based on the following 2014 OPM General Schedule hourly rates: technical at $46.67, management at $62.90, and clerical at $25.25. Management 

person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

(b) All 10 plants have submitted initial notification during the initial compliance period. 

(c) All 10 plants have submitted the notification of compliance status during the initial compliance period. 

(d) All 10 plants will submit an annual compliance certification each year. 

(e) Assumes that 2 facilities per year would have to submit an exceedance report per year. 

N/A = Not applicable

Note: Totals in the text have been rounded to 3 significant values. Figures may not add exactly due to rounding.