Burden Tables

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Overview

0649ss12 - Table 1
0649ss12 - Table 2
0649ss12 - Capital_O&M

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Sheet 1: 0649ss12 - Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)
BURDEN ITEM				Hours/ Occurrence (A)	Occurences/Year (b)	Hours/Year (C=AxB) (C)	Respondents/ Year b (D)	Technical Person Hours (E=CxD) (E)	Managerial Person Hours (Ex0.05)	Clerical Person Hours (Ex0.10)	Total Costs/Year a (F)		Managerial (per hour)	Technical (per hour)	Clerical (per hour)
1.	APPLICATIONS			N/A									$129.93	$103.97	$51.79
2.	SURVEY AND STUDIES			N/A
3.	REPORTING REQUIREMENTS
	a.	Familiarize with rule requirement		1	1	1	400	400	20	40	$46,258.20
	b.	Required Activities
			Initial Performance Tests	60	1	60	0	0	0	0	$0.00
			Repeat Performance Tests	60	0.2	12	0	0	0	0	$0.00
	c.	Gather Existing Information		See 3b
	d.	Write Report
			Notification of Construction/ Reconstruction	2	1	2	0	0	0	0	$0.00
			Notification of Initial Performance Test	2	1	2	0	0	0	0	$0.00
			Notification of Actual Startup	2	1	2	0	0	0	0	$0.00
			Report of Performance Test	See 3b
			Semiannual Report c	8	2	16	400	6,400	320	640	$740,131.20
			Excess Emissions Report d	16	2	32	80	2,560	128	256	$296,052.48
Subtotal for Reporting Requirements								10,764			$1,082,442
4.	RECORDKEEPING REQUIREMENTS
	a.	Familiarize with rule requirement		See 3b
	b.	Plan Activities		See 3b
	c.	Implement Activities (Monthly Performance Test) e		1	12	12	400	4,800	240	480	$555,098.40
	d.	Develop Record System		N/A
			Records of Operating Parameter f	0.25	350	87.5	400	35,000	1,750	3,500	$4,047,592.50
Subtotal for Recordkeeping Requirements								45,770			$4,602,691
TOTAL LABOR BURDEN AND COST								56,500			$5,690,000
Total Capital/O&M Costs (rounded†)											$840,000
Grand Total (Labor and Capital/O&M Costs) (rounded†)											$6,530,000		59	hr/resp
Assumptions:
a This ICR uses the following labor rates: $129.44 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.
b We have assumed that there are approximately 400 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
c We have assumed that each respondent will take eight hours twice per year to complete the semiannual report.
d We have assumed that 20 percent of respondent will each take 16 hours twice per year to complete the excess emissions reports.
DWang: Changed from: "We have assumed that each respondent will take one hour once per year to record monthly performance test." e We have assumed that each respondent will take one hour once per month to record monthly performance test.
f We have assumed that each respondent will take 0.25 hours per day over 350 days per year to keep record of operating parameters.
† Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: 0649ss12 - Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)
REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/Occurrence (a)	Occurences/ Plant/Year (B)	EPA Hours/Year (C=A*B) (C)	Plants/Year (D)	Technical Person Hours (E=CxD) (E)	Managerial Person Hours (Ex0.05)	Clerical Person Hours (Ex0.10)	Total Costs/Year a (F)		Managerial (per hour)	Technical (per hour)	Clerical (per hour)
INITIAL PERFORMANCE TESTS										$62.90	$46.67	$25.25
New Plant	24	1	24	0	0	0	0	$0.00
REPEAT PERFORMANCE TEST
New Plant	24	0.2	4.8	0	0	0	0	$0.00
REPORT REVIEW
New Plants
Notification of Construction	2	1	2	0	0	0	0	$0.00
Notification of Initial 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
Notification of Initial Test	0.5	1.2	0.6	0	0	0	0	$0.00
Review Test Results	8	1.2	9.6	0	0	0	0	$0.00
Existing Plants
Semiannual Reports	2	2	4	400	1600	80	160	$83,744.00
Excess Emissions Report c	2	2	4	80	320	16	32	$16,748.80
TOTAL ANNUAL BURDEN AND COST (rounded) d					2,210			$100,000
Assumptions
a 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, Step 3, $15.78 + 60%). The rates have been increased by 60 percent to account for the benefit packages available to government employees. These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay.
b We have assumed that it will take two hours twice per year to review the semiannual report.
DWang: Changed from: "We have assumed that 20 percent of existing plants will each take two hours twice per year to review the excess emissions reports." c We have assumed that EPA will take two hours twice per year to review each excess emissions reports. We also assumed that 20 percent of existing plants will submit excess emissions reports.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: 0649ss12 - Capital_O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost (B x C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M (E x F)
Temperature	4,400	0	$0	$2,100	400	$840,000