ICR Burden Tables

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Overview

Cover
Inputs
Current ICR
TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-SUMMARY
TBL5-EPA-YR1
TBL6-EPA-YR2
TBL7-EPA-YR3
TBL8-EPA SUMMARY

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Sheet 1: Cover

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
National Emission Standards for Hazardous Air Pollutants for Surface Coating of Large Appliances (40 CFR Part 63, Subpart NNNN) (Amendments)
ATTACHMENT 1
	TABLES 1, 2, 3, and 4
Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP – Years 1-3 (Amendments)
Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP (Amendments)
ATTACHMENT 2
	TABLES 5, 6, 7, and 8
Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP - Year 1-3 (Amendments)
Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP (Amendments)

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Sheet 2: Inputs

Respondent Wages ($2016)
Category (1)	Hourly Wage (2)	Loaded Wage (3)
Managerial	$71.25	$149.63
Technical	$48.11	$101.03
Clerical	$22.08	$46.37
Footnotes:
(1) The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2016 National Industry-Specific Occupational Employment and Wage Estimates 335200 - Household Appliance Manufacturing," found here:
https://www.bls.gov/oes/current/naics4_335200.htm
(2) Selected "mean hourly wage" in the table referenced in footnote 1.
(3) Loaded Wage is the 2016 Wage increased by 110 percent to account for the benefit packages available to those employed by private industry.
EPA Wages ($2017)
Category (1)	Hourly Wage	Wage With Fringe & Overhead (2)
(GS- 13, step 5) - Managerial	$40.50	$64.80
(GS- 12, step 1) - Technical	$30.05	$48.08
(GS-6, step 3) - Clerical	$16.26	$26.02
Footnotes:
(1) The hourly wage for each category is found here:
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/17Tables/html/GS_h.aspx
(2) Wage with fringe and overhead is the hourly mean wage increased by 60 percent to account for the benefit packages available to government employees.

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Sheet 3: Current ICR

Table 1: Annual Respondent Burden and Cost – NESHAP for Surface Coating of Large Appliances (40 CFR Part 63, Subpart NNNN) (Renewal)
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	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)	Per year b
1 Familiarization with rule requirements c	4	1	4	114	456	22.8	45.6	$51,596
2 Plan activities d	8	1	8	114	912	45.6	91.2	$103,192
3 Training d	8	1	8	114	912	45.6	91.2	$103,192
4 Create, test, and research and development	1	0	0	-	0	0	0	$0
5 Gather information, monitor, and inspect e	12	12	144	114	16,416	820.8	1641.6	$1,857,455
6 Process/compile and review f	8	12	96	114	10,944	547.2	1094.4	$1,238,303
7 Complete reports g	8	2	16	114	1,824	91.2	182.4	$206,384
Subtotal for Reporting Requirements					36,184			$3,560,122
8 Record/disclose h	1	2	2	114	228	11.4	22.8	$25,798
9 Store/file	0.25	2	0.5	114	57	2.85	5.7	$6,449
10 LDAR reporting and recordkeeping	0	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					196			$32,247
TOTAL LABOR BURDEN AND COST (rounded)								$3,590,000
Capital and O&M Cost i								$680,000
TOTAL COST								$4,270,000
Assumptions:
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: $149.62 per hour for Executive, Administrative, and Managerial labor; $101.03 per hour for Technical labor, and $46.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates 335200 - Household Appliance Manufacturing." 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.
d We have assumed that it will take eight hours for each respondent to plan activities and eight hours for training.
e We have assumed that each respondent will take twelve hours, twelve times per year to complete task.
f We have assumed that each respondent will take eight hours twelve times per year to complete task.
g We have assumed that each respondent will take eight hours twice per year to complete reports.
h We have assumed that each respondent will take one hour two times per week to record and disclose information.
i We have assumed that four new respondents install a $16,000 CEM and annual O&M costs are $5,400 for each respondent. For additional information see ICR Reference No. 201509-2060-013.
Table 2: Average Annual EPA Burden and Cost – NESHAP for Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN)
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	Respondents per year a	Technical person- hours per year	Management person-hours per year	Clerical person-hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)
1 Initial performance test c	24	1	24	4	96	4.8	9.6	$5,176
2 Repeat performance test d	24	0.2	4.8	4	19.2	0.96	1.92	$1,035
3 Report review
a) Initial notification e	8	1	8	4	32	1.6	3.2	$1,725
b) Notification of performance test e	8	1	8	4	32	1.6	3.2	$1,725
c) Notification of compliance status e	8	1	8	4	32	1.6	3.2	$1,725
d) Semiannual reports f	12	2	24	114	2,736	136.8	273.6	$147,529
TOTAL ANNUAL BURDEN AND COST (rounded)					3,390			$158,918
Assumptions:
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.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM), 2017 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.
d We have assumed that tests will fail 20% of the time and that it will take 24 hours to complete the task.
e We have assumed that it will take 8 hours to complete the task for each respondent.
f We have assumed that it will take 12 hours to complete the task for each respondent.

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Sheet 4: TBL1-YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP Year 1 (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(J)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Total Number of Responses per Year (E=BXD)	Technical person- hours per year (F=CxD)	Management person hours per year (G=Fx0.05)	Clerical person hours per year (H=Fx0.1)	Total Hours per Year (I=F+G+H)	Total Cost Per year b
1 Familiarization with rule requirements c	4	1	4	10	10	40	2	4	46	$4,526
2 Plan activities	0	0	0	0	0	0	0	0	0	$0
3 Training d	8	1	0	0	0	0	0	0	0	$0
4 Add-on control performance test e	30	1	30	0	0	0	0	0	0	$0
Repeat failed performance test f	30	1	30	0	0	0	0	0	0	$0
5 Gather info, monitor, inspect, and determine complaince g	12	12	144	0	0	0	0	0	0	$0
6 Process/compile and review h	8	12	96	0	0	0	0	0	0	$0
7 Complete notifications and reports i	8	2	16	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements						46				$4,526
8 Record/transmit/disclose j	2	52	0	0	0	0	0	0	0	$0
Due To Proposed Revisions k	8	2	16	10	20	160	8	16	184	$18,104
9 Store/file l	0.25	2	0	0	0	0	0	0	0	$0
10 Reporting and recordkeeping	0	0	0	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements						184				$18,104
TOTAL LABOR BURDEN AND COST (rounded)										$23,000
Capital and O&M Cost (see Section 6(b)(iii)): m										$0
TOTAL COST					30					$23,000
Assumptions:
a It is assumed that there are ten sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $149.62 per hour for Executive, Administrative, and Managerial labor; $101.03 per hour for Technical labor, and $46.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates 335200 - Household Appliance Manufacturing." 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 It is assumed that each respondent will take 4 hours to read the rule and instructions.
d The proposed RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff.
e If a source owner or operator chooses to comply with the standards using add-on controls, the results of an initial performance test are used to determine compliance; however, the rule does not require on-going periodic performance testing for these emission capture systems and add-on controls. The EPA specifically is requesting comment on whether performance testing should be required anytime a source plans to undertake an operational change that may adversely affect compliance with an applicable standard, operating limit, or parametric monitoring value.
f Performance testing is not currently required after the initial performance test.
g The current ICR assumes each respondent will take twelve hours, twelve times per year to complete task. Labor totals include hours for the facility to coordinate with suppliers, and gather information on monitoring and emissions. The proposed RTR amendments do not impact this item.
h The proposed RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours twelve times per year to complete task.
i The proposed RTR amendments do not impact this item. The current ICR assumes that each respondent will take eight hours twice per year to complete reports.
j The current ICR assumes each respondent will take one hour two times per week to record and disclose information. EPA is proposing to require sources to electronically submit semiannual reports starting 2 years after the effective date of the final rule. It is assumed that this will not increase labor.
k We are proposing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
l The proposed RTR amendments do not impact this item. The current ICR assumes that each respondent will take half an hour annually to store and file reports.
m EPA is proposing to require the use of high efficiency spray guns where the source is not using add-on controls. Because of the economic incentives to use high efficiency application methods for spray applied coatings, we do not expect any facilities will have to switch to high efficiency application methods.

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Sheet 5: TBL2-YR2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP Year 2 (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(J)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Total Number of Responses per Year (E=BXD)	Technical person- hours per year (F=CxD)	Management person hours per year (G=Fx0.05)	Clerical person hours per year (H=Fx0.1)	Total Hours per Year (I=F+G+H)	Total Cost Per year b
1 Familiarization with rule requirements c	4	1	4	0	0	0	0	0	0	$0
2 Plan activities	0	0	0	0	0	0	0	0	0	$0
3 Training d	8	1	0	0	0	0	0	0	0	$0
4 Add-on control performance test e	30	1	30	0	0	0	0	0	0	$0
Repeat failed performance test f	30	1	30	0	0	0	0	0	0	$0
5 Gather info, monitor, inspect, and determine complaince g	12	12	144	0	0	0	0	0	0	$0
6 Process/compile and review h	8	12	96	0	0	0	0	0	0	$0
7 Complete notifications and reports i	8	2	16	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements						0				$0
8 Record/transmit/disclose j	2	52	0	0	0	0	0	0	0	$0
Due To Proposed Revisions k	8	1	8	0	0	0	0	0	0	$0
9 Store/file l	0.25	2	0	0	0	0	0	0	0	$0
10 Reporting and recordkeeping	0	0	0	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements						0				$0
TOTAL LABOR BURDEN AND COST (rounded)										$0
Capital and O&M Cost (see Section 6(b)(iii)): m										$0
TOTAL COST					0					$0
Assumptions:
a It is assumed that there are ten sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $149.62 per hour for Executive, Administrative, and Managerial labor; $101.03 per hour for Technical labor, and $46.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates 335200 - Household Appliance Manufacturing." 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 It is assumed that each respondent will take 4 hours to read the rule and instructions.
d The proposed RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff.
e If a source owner or operator chooses to comply with the standards using add-on controls, the results of an initial performance test are used to determine compliance; however, the rule does not require on-going periodic performance testing for these emission capture systems and add-on controls. The EPA specifically is requesting comment on whether performance testing should be required anytime a source plans to undertake an operational change that may adversely affect compliance with an applicable standard, operating limit, or parametric monitoring value.
f Performance testing is not currently required after the initial performance test.
g The current ICR assumes each respondent will take twelve hours, twelve times per year to complete task. Labor totals include hours for the facility to coordinate with suppliers, and gather information on monitoring and emissions. The proposed RTR amendments do not impact this item.
h The proposed RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours twelve times per year to complete task.
i The proposed RTR amendments do not impact this item. The current ICR assumes that each respondent will take eight hours twice per year to complete reports.
j The current ICR assumes each respondent will take one hour two times per week to record and disclose information. EPA is proposing to require sources to electronically submit semiannual reports starting 2 years after the effective date of the final rule. It is assumed that this will not increase labor.
k We are proposing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
l The proposed RTR amendments do not impact this item. The current ICR assumes that each respondent will take half an hour annually to store and file reports.
m EPA is proposing to require the use of high efficiency spray guns where the source is not using add-on controls. Because of the economic incentives to use high efficiency application methods for spray applied coatings, we do not expect any facilities will have to switch to high efficiency application methods.

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Sheet 6: TBL3-YR3

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP Year 2 (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(J)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Total Number of Responses per Year (E=BXD)	Technical person- hours per year (F=CxD)	Management person hours per year (G=Fx0.05)	Clerical person hours per year (H=Fx0.1)	Total Hours per Year (I=F+G+H)	Total Cost Per year b
1 Familiarization with rule requirements c	4	1	4	0	0	0	0	0	0	$0
2 Plan activities	0	0	0	0	0	0	0	0	0	$0
3 Training d	8	1	0	0	0	0	0	0	0	$0
4 Add-on control performance test e	30	1	30	0	0	0	0	0	0	$0
Repeat failed performance test f	30	1	30	0	0	0	0	0	0	$0
5 Gather info, monitor, inspect, and determine complaince g	12	12	144	0	0	0	0	0	0	$0
6 Process/compile and review h	8	12	96	0	0	0	0	0	0	$0
7 Complete notifications and reports i	8	2	16	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements						0				$0
8 Record/transmit/disclose j	2	52	0	0	0	0	0	0	0	$0
Due To Proposed Revisions k	8	1	8	0	0	0	0	0	0	$0
9 Store/file l	0.25	2	0	0	0	0	0	0	0	$0
10 Reporting and recordkeeping	0	0	0	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements						0				$0
TOTAL LABOR BURDEN AND COST (rounded)										$0
Capital and O&M Cost (see Section 6(b)(iii)): m										$0
TOTAL COST					0					$0
Assumptions:
a It is assumed that there are ten sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $149.62 per hour for Executive, Administrative, and Managerial labor; $101.03 per hour for Technical labor, and $46.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates 335200 - Household Appliance Manufacturing." 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 It is assumed that each respondent will take 4 hours to read the rule and instructions.
d The proposed RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff.
e If a source owner or operator chooses to comply with the standards using add-on controls, the results of an initial performance test are used to determine compliance; however, the rule does not require on-going periodic performance testing for these emission capture systems and add-on controls. The EPA specifically is requesting comment on whether performance testing should be required anytime a source plans to undertake an operational change that may adversely affect compliance with an applicable standard, operating limit, or parametric monitoring value.
f Performance testing is not currently required after the initial performance test.
g The current ICR assumes each respondent will take twelve hours, twelve times per year to complete task. Labor totals include hours for the facility to coordinate with suppliers, and gather information on monitoring and emissions. The proposed RTR amendments do not impact this item.
h The proposed RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours twelve times per year to complete task.
i The proposed RTR amendments do not impact this item. The current ICR assumes that each respondent will take eight hours twice per year to complete reports.
j The current ICR assumes each respondent will take one hour two times per week to record and disclose information. EPA is proposing to require sources to electronically submit semiannual reports starting 2 years after the effective date of the final rule. It is assumed that this will not increase labor.
k We are proposing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
l The proposed RTR amendments do not impact this item. The current ICR assumes that each respondent will take half an hour annually to store and file reports.
m EPA is proposing to require the use of high efficiency spray guns where the source is not using add-on controls. Because of the economic incentives to use high efficiency application methods for spray applied coatings, we do not expect any facilities will have to switch to high efficiency application methods.

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Sheet 7: TBL4-SUMMARY

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP (Amendments)
Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	200	20	10	230	$23,000	$0	$23,000
2	0	0	0	0	$0	$0	$0
3	0	0	0	0	$0	$0	$0
Total	200	20	10	230	$23,000	$0	$23,000
Average	67	6.7	3.3	77	$7,700	$0	$7,700
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	10	30	46	184	230	8	23
2	10	0	0	0	0	0	0
3	10	0	0	0	0	0	0
Total	10	30	46	184	230	8	23
Average	10	10.0	0	61	100	2.7	7.7
(a) = Average annual additional cost per respondent: $770

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Sheet 8: TBL5-EPA-YR1

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP - Year 1 (Amendments)
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 Add-on control performance test a, c, d	24	0	0	0	0	0	0	$0
2 Repeat failed performance test d	24	0	0	0	0	0	0	$0
3 Report review
a) Initial notification e	4	1	4	0	0	0	0	$0
b) Performance test report f	8	1	8	0	0	0	0	$0
c) Notification of compliance status g	8	1	0	0	0	0	0	$0
d) Semiannual reports h	12	2	0	0	0	0	0	$0
Due To Proposed Revisions i	2	2	4	10	40	2	4	$2,157
TOTAL ANNUAL BURDEN AND COST (rounded)					46			$2,200
Assumptions:
a It is assumed that there are ten sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM), 2017 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 The proposed RTR amendments do not impact this item. The current ICR assumes it will take 24 hours to complete the task for each respondent.
d If a source owner or operator chooses to comply with the standards using add-on controls, the results of an initial performance test are used to determine compliance; however, the rule does not require on-going periodic performance testing for these emission capture systems and add-on controls. The EPA specifically is requesting comment on whether performance testing should be required anytime a source plans to undertake an operational change that may adversely affect compliance with an applicable standard, operating limit, or parametric monitoring value.
e It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.
f It is assumed that it will take eight hours to review the test report for each respondent.
g The proposed RTR amendments do not impact this item. The current ICR assumes that it will take eight hours, once a year to review the complaince stats for each respondent.
h The proposed RTR amendments do not impact this item. The current ICR assumes that it will take twelve hours to review the test reports, twice a year for each respondent.
i EPA is proposing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for evaluating new SSM record systems in year one.

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Sheet 9: TBL6-EPA-YR2

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP - Year 2 (Amendments)
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 Add-on control performance test a, c, d	24	0	0	0	0	0	0	$0
2 Repeat failed performance test d	24	0	0	0	0	0	0	$0
3 Report review
a) Initial notification e	4	1	4	0	0	0	0	$0
b) Performance test report f	8	1	8	0	0	0	0	$0
c) Notification of compliance status g	8	1	0	0	0	0	0	$0
d) Semiannual reports h	12	2	0	0	0	0	0	$0
Due To Proposed Revisions i	2	2	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)					0			$0
Assumptions:
a It is assumed that there are ten sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM), 2017 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 The proposed RTR amendments do not impact this item. The current ICR assumes it will take 24 hours to complete the task for each respondent.
d If a source owner or operator chooses to comply with the standards using add-on controls, the results of an initial performance test are used to determine compliance; however, the rule does not require on-going periodic performance testing for these emission capture systems and add-on controls. The EPA specifically is requesting comment on whether performance testing should be required anytime a source plans to undertake an operational change that may adversely affect compliance with an applicable standard, operating limit, or parametric monitoring value.
e It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.
f It is assumed that it will take eight hours to review the test report for each respondent.
g The proposed RTR amendments do not impact this item. The current ICR assumes that it will take eight hours, once a year to review the complaince stats for each respondent.
h The proposed RTR amendments do not impact this item. The current ICR assumes that it will take twelve hours to review the test reports, twice a year for each respondent.
i EPA is proposing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for evaluating new SSM record systems in year one.

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Sheet 10: TBL7-EPA-YR3

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP - Year 3 (Amendments)
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 Add-on control performance test a, c, d	24	0	0	0	0	0	0	$0
2 Repeat failed performance test d	24	0	0	0	0	0	0	$0
3 Report review
a) Initial notification e	4	1	4	0	0	0	0	$0
b) Performance test report f	8	1	8	0	0	0	0	$0
c) Notification of compliance status g	8	1	0	0	0	0	0	$0
d) Semiannual reports h	12	2	0	0	0	0	0	$0
Due To Proposed Revisions i	2	2	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)					0			$0
Assumptions:
a It is assumed that there are ten sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM), 2017 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 The proposed RTR amendments do not impact this item. The current ICR assumes it will take 24 hours to complete the task for each respondent.
d If a source owner or operator chooses to comply with the standards using add-on controls, the results of an initial performance test are used to determine compliance; however, the rule does not require on-going periodic performance testing for these emission capture systems and add-on controls. The EPA specifically is requesting comment on whether performance testing should be required anytime a source plans to undertake an operational change that may adversely affect compliance with an applicable standard, operating limit, or parametric monitoring value.
e It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.
f It is assumed that it will take eight hours to review the test report for each respondent.
g The proposed RTR amendments do not impact this item. The current ICR assumes that it will take eight hours, once a year to review the complaince stats for each respondent.
h The proposed RTR amendments do not impact this item. The current ICR assumes that it will take twelve hours to review the test reports, twice a year for each respondent.
i EPA is proposing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for evaluating new SSM record systems in year one.

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Sheet 11: TBL8-EPA SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Large Appliances NESHAP (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	40	2.0	4.0	46	$2,200	$0	$2,200
2	0	0	0	0	$0	$0	$0
3	0	0	0	0	$0	$0	$0
Total	40	2.0	4.0	46	$2,200	$0	$2,200
Average	13	0.7	1.3	15	$700	$0	$700
Year	Number of Responses	Total Hours
1	10	46	(a)
2	0	0
3	0	0
Total	10	46
Average	3.3	15
(a) = Average annual hours per respondent: 4.6