2025.07 Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal)
					108.28	144.33	53.34
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (F=Ex0.05)	Clerical person hours per year (G=Ex0.1)	Total Annual Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Acquisition, installation and utilization of technology and systems	54	1	54	0	0	0	0	$0
4. Reporting requirements
A. Familiarize with regulatory requirements c	0.5	1	0.5	2	1	0.05	0.1	$120.83
B. Required activities
Startup, shutdown, malfunction plan	32	1	32	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4E
E. Write Report
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Semiannual report of deviation d	8	2	16	0.3	4.8	0.24	0.48	$579.99
Semiannual report of no deviation e	8	2	16	1.7	27.2	1.36	2.72	$3,286.59
Startup, shutdown, malfunction report f	8	2	16	0.2	3.2	0.16	0.32	$386.66
Subtotal for Reporting Requirements					42			$4,374
5. Recordkeeping requirements
A. Familiarize with regulatory requirements c	4	1	4	2	8	0.4	0.8	$966.64
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information
Records of solvent weight measurements g	0.033	2,600	85.8	2	171.6	8.58	17.16	$20,734.51
Records of block average solvent weight h	2	52	104	2	208	10.4	20.8	$25,132.74
Records of startup, shutdown, malfunction h	1	52	52	2	104	5.2	10.4	$12,566.37
Copies of notifications/reports i	0.25	5	1.25	2	2.5	0.125	0.25	$302.08
F. Time to train personnel j	20	1	20	2	40	2	4	$4,833.22
G. Time to transmit or disclose information i	0.25	5	1.25	2	2.5	0.125	0.25	$302.08
H. Time to audit	N/A
Subtotals for Recordkeeping Requirements					617			$64,838		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) k					659			$69,200		4	165
TOTAL CAPITAL AND O&M COST (rounded) k								$544
GRAND TOTAL (rounded) k								$69,700
Assumptions:								138400
a We have assumed that there are 2 existing sources, and that no additional new or reconstructed sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $144.33 per hour for Executive, Administrative, and Managerial labor; $108.28 per hour for Technical labor, and $53.34 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, 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 all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that 15 percent of respondents will report deviation.
e We have assumed that 85 percent of respondents will report no deviation.
f We have assumed that 10 percent of respondents will have a startup, shutdown, or malfunction occur that is not managed according to the regulation.
g We have assumed that solvent weights are recorded once per hour (2 minutes [0.033 hr] per record) for 2,600 hours per year (industry average annual operating hours for solvent mixers).
h It is assumed that information would be entered once per week for 52 weeks per year.
i We have assumed that a typical plant transmits the startup, shutdown, and malfunction plan semiannually; deviation report once a year; and no deviation report semiannually for a total of five times per year.
j We have assumed that it will take 20 hours per plant once a year to train personnel.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal)
					48.08	64.8	26.02
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person-hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost, $ b
1. Excess emissions enforcement activities c	48	1	48	0.1	4.8	2.4	0.48	$398.79
2. Report review
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	40	1	40	0	0	0	0	$0
Semiannual report of deviation d	20	2	40	0.3	12	6	1.2	$996.98
Semiannual report of no deviation e	2	2	4	1.7	6.8	3.4	0.68	$564.96
Startup, shutdown, malfunction report f	20	2	40	0.2	8	4	0.8	$664.66
TOTAL ANNUAL BURDEN AND COST (rounded) g					51			$2,630
Assumptions:
a We have assumed that there are 2 existing sources, and that no additional new or reconstructed sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates which have been increased by 60 percent to account for the benefit package available to government employees: $64.80 Managerial rate (GS-13, Step 5, $40.50 + 60%), $48.08 Technical rate (GS-12, Step 1, $30.05+ 60%), and $26.02 Clerical rate (GS-6, Step 3, $16.26 + 60). These rates are from the Office of Personnel Management (OPM) 2017 General Schedule which excludes locality rates of pay.
c We have assumed that 5 percent of plants will be involved in excess emissions enforcement activities.
d We have assumed that 15 percent of respondents will report deviation.
e We have assumed that 85 percent of respondents will report no deviation.
f We have assumed that 10 percent of respondents will have a startup, shutdown, or malfunction occur that is not managed according to the regulation.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.