Calculation Tables for ICR 2044.06

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Overview

Industry
Agency

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Sheet 1: Industry

					103.97	129.93	51.79
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 a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Reporting requirements
a. Familiarization with the regulatory requirements	4	1	4	835	3,340	167	334	$386,255.97
b. Process/review information	4	4	16	835	13,360	668	1,336.0	$1,545,023.88
c. Write reports
i. Initial notification	2	1	2	1	2	0.1	0.2	$231.29
ii. Notification of compliance status	2	1	2	1	2	0.1	0.2	$231.29
iii. Notification of construction/ reconstruction	2	1	2	1	2	0.1	0.2	$231.29
iv. Notification of actual startup	2	1	2	1	2	0.1	0.2	$231.29
v. Notification of performance test	2	1.2	2.4	1	2	0.12	0.24	$277.55
vi. Report of performance test	10	1.2	12	1	12	0.6	1.2	$1,387.75
vii. Semiannual report c	6	2	12	835	10,020	501	1002	$1,158,767.91
viii. Excess emissions report	2	2	4	835	3,340	167	334	$386,255.97
ix. Startup, shutdown, malfunction report d	2	1	2	209	418.0	20.9	41.8	$48,339.82
Subtotal for Reporting Requirements					35,075			$3,527,234.01
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	4	1	4	835	3,340	167	334	$386,255.97
b. Plan activities	12	1	12	835	10,020	501	1002	$1,158,767.91
c. Implement activities	12	1	12	835	10,020	501	1002	$1,158,767.91
d. Maintain record system for material used	20	1	20	835	16,700	835	1670	$1,931,279.85
e. Time to enter information
i. Material usage e	0.5	365	182.5	835	152,388	7,619.4	15,239	$17,622,928.63
ii. Compliance calculation f	2	12	24	835	20,040	1002	2,004.0	$2,317,535.82
f. Time to train personnel	10	1	10	835	8,350	417.5	835	$965,639.93
g. Store, file, and maintain records g	2	12	24	835	20,040	1002	2,004.0	$2,317,535.82
h. Retrieve records/reports	1	12	12	835	10,020	501	1002	$1,158,767.91
Subtotal for Recordkeeping Requirements					288,555			$29,017,479.75		hr per resp
TOTAL ANNUAL BURDEN AND COSTS (rounded): i					324,000			$32,500,000		91
Capital and O&M Cost (see Section 6(b)(iii)): i								$267,000
TOTAL COST: i								$32,800,000
Assumptions:
a We have assumed that there are approximately 835 respondents, with one additional new source becoming subject to the rule over the next three years of this ICR.
b This ICR uses the following labor rates: Managerial $129.93 ($61.87+ 110%) , Technical $103.97 ($49.51 + 110%), and 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. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We assume that each respondent will take 6 hours two time per year to write semiannual report.
d It is estimated that 25 percent of facilities use add-on controls submit startup, shutdown, and malfunction report once per year.
e We assumed that each respondent will take 0.5 hours each day to enter daily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating.
f We have assumed that each respondent will take 2 hours once per month to enter compliance calculation.
g We have assumed that each respondent will take 2 hours once per month to store, file and maintain records.
h We have assumed that each respondent will take I hour once per month to retrieve records/reports.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

					46.67	62.9	25.25
Burden Item	(A) EPA Person hours per occurrence	(B) Number of occurrences per year	(C) EPA Person hrs per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Initial performance test	24	1	24	1	24	1.2	2.4	$1,256.16
1. Repeat performance test	24	0.2	4.8	1	4.8	0.24	0.48	$251.23
3. Report review
a. Initial notification	8	1	8	1	8	0.4	0.8	$418.72
b. Notification of compliance status	8	1	8	1	8	0.4	0.8	$418.72
c. Notification of construction/reconstruction	8	1	8	1	8	0.4	0.8	$418.72
d. Notification of actual startup	8	1	8	1	8	0.4	0.8	$418.72
e. Notification of performance test	8	1.2	9.6	1	9.6	0.48	0.96	$502.46
f. Report of performance test	8	1.2	9.6	1	9.6	0.48	0.96	$502.46
g. Semiannual report c	12	2	24	835	20,040	1002	2,004.0	$1,048,893.60
h. Excess emissions report d	4	2	8	835	6,680	334	668	$349,631.20
i. Startup, shutdown, malfunction report	8	1	8	209	1,672	83.6	167.2	$87,512.48
Total Burden (rounded): e					32,700			$1,490,000
Assumptions:
a We have assumed that there are approximately 835 respondents, with one additional new source becoming subject to the rule over the next three years of this ICR.
b This ICR uses the following labor rates: Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) Technical $46.67 (GS-12, Step 1, $29.17 + 60%), and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2016 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. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have assumed that each respondent will take 12 hours two times per year to review semiannual report.
d We have assumed that each respondent will take 4 hours two times per year to review the excess emissions report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.