| Table 1: Annual Respondent Burden and Cost - NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal) |
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103.97 |
129.93 |
51.79 |
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ERG:
This table is carried over from the previous ICR. It's a bit strange because it doesn't include have breakdowns by initial v. semiannual reports, rather, it just have generic line items of "complete reports".
Looking at several renewals, this format was used prior to the .04 renewal ICR.
Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| Person‑Hours per occurrence |
Number of occurrences per year |
Person‑Hours per respondent per year
(C=A*B) |
Respondents per year a |
Technical person‑hours per year (E=C*D) |
Management person‑hours per year
(F=E*0.05) |
Clerical person‑hours per year (G=E*0.1) |
Annual costs ($) b |
| 1 Familiarization with rule requirements c |
4 |
1 |
4 |
114 |
456 |
22.8 |
45.6 |
$52,734.35 |
| 2 Plan activities d |
8 |
1 |
8 |
114 |
912 |
45.6 |
91.2 |
$105,468.70 |
| 3 Training d |
8 |
1 |
8 |
114 |
912 |
45.6 |
91.2 |
$105,468.70 |
| 4 Create, test, and research and development |
1 |
0 |
0 |
0 |
0 |
0 |
0 |
$0.00 |
| 5 Gather information, monitor, and inspect e |
12 |
12 |
144 |
114 |
16416 |
820.8 |
1641.6 |
$1,898,436.53 |
| 6 Process/compile and review f |
8 |
12 |
96 |
114 |
10944 |
547.2 |
1094.4 |
$1,265,624.35 |
| 7 Complete reports g |
8 |
2 |
16 |
114 |
1824 |
91.2 |
182.4 |
$210,937.39 |
| Subtotal for Reporting Requirements |
36,184 |
$3,638,670.01 |
| 8 Record/disclose h |
1 |
2 |
2 |
114 |
228 |
11.4 |
22.8 |
$26,367.17 |
| 9 Store/file |
0.25 |
2 |
0.5 |
114 |
57 |
2.85 |
5.7 |
$6,591.79 |
| 10 LDAR reporting and recordkeeping |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
$0.00 |
| Subtotal for Recordkeeping Requirements |
328 |
$32,958.97 |
| TOTAL ANNUAL BURDEN AND COST (rounded) |
36,500 |
$3,670,000 |
| Capital and O&M Cost (see Section 6(b)(iii)): |
$680,000 |
| TOTAL COST: |
$4,350,000 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be 114. There will be four additional new sources that will become subject to the rule over the three-year period of this ICR. |
| b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c We have assumed that each respondent will take 4 hours to read the rule and instructions. |
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| d We have assumed that it will take eight hours for each respondent to plan activities and eight hours for training. |
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| e We have assumed that each respondent will take twelve hours twelve times per year to complete task. |
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| f We have assumed that each respondent will take eight hours twelve times per year to complete task. |
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| g We have assumed that each respondent will take eight hours twice per year to complete reports. |
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| h We have assumed that each respondent will take one hour two times per week to record and disclose information. |
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| Table 2: Average Annual EPA Burden and Cost - NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal) |
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46.67 |
62.9 |
25.25 |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| Person‑hours per activity |
Number of occurences per year |
Person hours per respondent per year
(C = A*B) |
Respondents per yeara |
Technical person‑hours per year
(E=C*D) |
Management person‑hours per year
(F=E*0.05) |
Clerical person‑hours per year
(G=E*0.1) |
Annual
Costs ($/yr) b |
| 1 Initial performance test c |
24 |
1 |
24 |
4 |
96 |
4.8 |
9.6 |
$5,024.64 |
| 2 Repeat performance test d |
24 |
0.2 |
4.8 |
4 |
19.2 |
0.96 |
1.92 |
$1,004.93 |
| 3 Report review |
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| a) Initial notification e |
8 |
1 |
8 |
4 |
32 |
1.6 |
3.2 |
$1,674.88 |
| b) Notification of performance test e |
8 |
1 |
8 |
4 |
32 |
1.6 |
3.2 |
$1,674.88 |
| c) Notification of compliance status e |
8 |
1 |
8 |
4 |
32 |
1.6 |
3.2 |
$1,674.88 |
| d) Semiannual reports f |
12 |
2 |
24 |
114 |
2736 |
136.8 |
273.6 |
$143,202.24 |
| TOTAL ANNUAL BURDEN AND COST (rounded) |
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3,390 |
$154,000 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be 114. There will be four additional sources that will become subject to the rule over the three-year period of this ICR |
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| b This cost is based on the following labor rates: Managerial rate of $62.90 (GS-13, Step 5, $39.31 + 60%), Technical rate of $46.67 (GS-12, Step 1, $29.17 + 60%), and Clerical rate of $25.25 (GS-6, Step3, $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. |
| c We have assumed that it will take 24 hours to complete the task for each respondent. |
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| d We have assumed that tests will fail 20% of the time and that it will take 24 hours to complete the task. |
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| e We have assumed that it will take 8 hours to complete the task for each respondent. |
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| f We have assumed that it will take 12 hours to complete the task for each respondent. |
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