Calculation Tables for ICR 1952.06

Copy of ICR1952 06 Burden Calculations.xlsx

NESHAP for Metal Furniture Surface Coating (40 CFR part 63, subpart RRRR) (Renewal)

Calculation Tables for ICR 1952.06

OMB: 2060-0518

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Overview

Industry
EPA


Sheet 1: Industry













Burden Item (A) Person‑hours per occurrence (B) Number of occurrences per year (C) Person‑hrs. per respondent per year (C=AxB) (D) Respondents per year (E) Technical person‑hrs. per year (E=CxD) (F) Management person‑hrs. per year (F=Ex0.05) (G) Clerical person‑hrs. per year (G=Ex0.1) (H) Annual costs ($)


1. Reporting requirements



a. Familiarize with rule requirements 4 1 4 583 2,332 116.6 233.2 $269,686.36
Tech $103.97
b. Process/review information 4 4 16 583 9,328 466.4 932.8 $1,078,745.42
Mgm $129.93
c. Write reports

Cler $51.79
i. Initial notification 2 1 2 0 0 0 0 $0


ii. Notification of compliance status 2 1 2 0 0 0 0 $0


iii. Notification of construction/reconstruction 2 1 2 0 0 0 0 $0


iv. Notification of actual startup 2 1 2 0 0 0 0 $0


v. Notification of performance test 2 1.2 2.4 0 0 0 0 $0


vi. Report of performance test 10 1.2 12 0 0 0 0 $0


vii. Semiannual report 6 2 12 583 6,996 349.8 699.6 $809,059.07


viii. Excess emissions report 4 0.5 2 583 1,166 58.3 116.6 $134,843.18


ix. Startup, shutdown, malfunction report 4 0.5 2 583 1,166 58.3 116.6 $134,843.18


Subtotal for Reporting Requirements



24,136 $2,427,177


2. Recordkeeping requirements



a. Familiarize with rule requirements 4 1 4 583 2,332 116.6 233.2 $269,686.36


b. Plan activities 12 1 12 583 6,996 349.8 699.6 $809,059.07


c. Implement activities 12 1 12 583 6,996 349.8 699.6 $809,059.07


d. Maintain record system for material used 20 1 20 583 11,660 583 1166 $1,348,431.78


e. Time to enter information



i. Material usage 0.5 260 130 583 75,790 3789.5 7579 $8,764,806.55


ii. Compliance calculation 2 12 24 583 13,992 699.6 1399.2 $1,618,118.13


f. Time to train personnel 10 1 10 583 5,830 291.5 583 $674,215.89


g. Store, file, and maintain records 2 12 24 583 13,992 699.6 1399.2 $1,618,118.13


h. Retrieve records/reports 1 12 12 583 6,996 349.8 699.6 $809,059.07


Subtotal for Recordkeeping Requirements



166,272 $16,720,554


TOTAL ANNUAL BURDEN AND COSTS (rounded): g



190,000 $19,100,000
109 hr/resp
Capital and O&M Cost (see Section 6(b)(iii)): g






$700,000


TOTAL COST: g






$19,800,000














Assumptions:






















a We have assumed that there are approximately 583 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.










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 percent to account for the benefit packages available to those employed by private industry.










c We have assumed that each respondent will take six hours twice per year to complete the semiannual report.










d We have assumed that each respondent will take four hours twice per year to complete the excess emissions reports and also four hours twice per year for the SSM reports.










e We have assumed that each respondent will take 0.5 hours 260 times per year to enter information.










f We have assumed that each respondent will have to complete task once per month.










g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.











Sheet 2: EPA











Burden Item (A) (B) (C) (D) (E) (F)



Person‑hours per activity Number of activities per year Technical person‑hours per year (C=AxB) Management person‑hours per year (D=Cx0.05) Clerical person‑hours per year (E=Cx0.1) Annual costs ($/yr)


1. Initial performance test 24 0 0 0 0 $0
Tech $46.67
2. Repeat performance test 24 0 0 0 0 $0
Mgm $62.90
3. Report review






Cler $25.25
a) Initial notification 8 0 0 0 0 $0


b) Notification of performance test 8 0 0 0 0 $0


c) Notification of compliance status 8 0 0 0 0 $0


d) Notification of construction/reconstruction 8 0 0 0 0 $0


e) Notification of actual startup 8 0 0 0 0 $0


f) Notification of performance test 8 0 0 0 0 $0


g) Report of performance test 8 0 0 0 0 $0


h) Semiannual report 12 1,166 13,992 699.6 1399.2 $732,363.67


i) Excess emissions report 8 291.5 2,332 116.6 233.2 $122,060.61


j) Startup, shutdown, malfunction report 8 291.5 2,332 116.6 233.2 $122,060.61


Total Burden (Hrs) and Costs

21,500 $976,000












Assumptions:


















a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 (GS-13, Step 5, $39.31 + 60%) for Managerial, $46.67 (GS-12, Step 1, $29.17 + 60%) for Technical, and $25.25 (GS-6, Step 3, $15.78 + 60%) for Clerical. These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.








b The semiannual report would have to be completed twice per year.








g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.








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