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 Metal Furniture (40 CFR Part 63, Subpart RRRR) (Amendments)
ATTACHMENT 1
	TABLES 1, 2, 3, and 4
Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP – Years 1-3 (Amendments)
Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for theSurface Coating of Metal Furniture 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 Metal Furniture NESHAP - Year 1-3 (Amendments)
Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP (Amendments)

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Sheet 2: Inputs

Respondent Wages ($2016)
Category (1)	Hourly Mean Wage (2)	Loaded Wage (3)
Technical	$43.02	$90.34
Clerical	$17.96	$37.72
Managerial	$52.87	$111.03
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 NAICS 337000 - Furniture and Related Product Manufacturing," found here:
https://www.bls.gov/oes/current/naics3_337000.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 ($2016)
Category (1)	Hourly Mean Wage	Wage With Fringe & Overhead (2)
(GS- 12, step 1) - Technical	$30.05	$48.08
(GS- 13, step 5) - Managerial	$40.50	$64.80
(GS-6, step 3) - Clerical	$16.26	$26.02
Footnotes:
(1) The hourly mean 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 Metal Furniture (40 CFR Part 63, Subpart RRRR) (Amendments)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person‑hours per occurrence	Number of occurrences per year	Person‑hrs. per respondent per year	Respondents per year	Technical person‑hrs. per year	Management person‑hrs. per year	Clerical person‑hrs. per year	Annual costs ($)
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)
1. Reporting requirements
a. Familiarize with rule requirements	4	1	4	583	2,332	116.6	233.2	$232,419
b. Process/review information	4	4	16	583	9,328	466.4	932.8	$929,675
c. Write reports
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	$697,256
viii. Excess emissions report	4	0.5	2	583	1,166	58.3	116.6	$116,209
ix. Startup, shutdown, malfunction report	4	0.5	2	583	1,166	58.3	116.6	$116,209
Subtotal for Reporting Requirements					24,136			$2,091,768
2. Recordkeeping requirements
a. Familiarize with rule requirements	4	1	4	583	2,332	116.6	233.2	$232,419
b. Plan activities	12	1	12	583	6,996	349.8	699.6	$697,256
c. Implement activities	12	1	12	583	6,996	349.8	699.6	$697,256
d. Maintain record system for material used	20	1	20	583	11,660	583	1166	$1,162,093
e. Time to enter information
i. Material usage	0.5	260	130	583	75,790	3789.5	7579	$7,553,607
ii. Compliance calculation	2	12	24	583	13,992	699.6	1399.2	$1,394,512
f. Time to train personnel	10	1	10	583	5,830	291.5	583	$581,047
g. Store, file, and maintain records	2	12	24	583	13,992	699.6	1399.2	$1,394,512
h. Retrieve records/reports	1	12	12	583	6,996	349.8	699.6	$697,256
Subtotal for Recordkeeping Requirements					166,272			$14,409,957
TOTAL ANNUAL BURDEN AND COSTS (rounded): g					190,000			$16,500,000
Capital and O&M Cost (see Section 6(b)(iii)): g								$700,000
TOTAL COST: g								$17,200,000
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: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 per hour for Clerical
labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage
Estimates NAICS 337000 - Furniture and Related Product Manufacturing." The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account
for the benefit packages available to those employed by private industry.
c We have assumed that each respondent will take six hours twice per year to complete the semiannual report.
d We have assumed that each respondent will take four hours twice per year to complete the excess emissions reports and also four hours twice per year for the SSM reports.
e We have assumed that each respondent will take 0.5 hours 260 times per year to enter information.
f We have assumed that each respondent will have to complete task once per month.
g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.
Table 2: Average Annual EPA Burden and Cost – NESHAP for Surface Coating of Metal Furniture (40 CFR Part 63, Subpart RRRR) (Amendments)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)
	Person‑hours per activity	Number of activities per year	Technical person‑hours per year	Management person‑hours per year	Clerical person‑hours per year	Annual costs ($/yr)
			(C=AxB)	(D=Cx0.05)	(E=Cx0.1)
1. Initial performance test	24	0	0	0	0	$0
2. Repeat performance test	24	0	0	0	0	$0
3. Report review
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	$754,471
i) Excess emissions report	8	291.5	2,332	116.6	233.2	$125,745
j) Startup, shutdown, malfunction report	8	291.5	2,332	116.6	233.2	$125,745
Total Burden (Hrs) and Costs			21,500			$1,006,000
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: $64.80
(GS-13, Step 5, $40.50 + 60%) for Managerial, $48.08 (GS-12, Step 1, $30.05 + 60%) for Technical, and $26.02 (GS-6, Step 3, $16.26 + 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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Sheet 4: TBL1-YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture 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	16	16	64	3.2	6.4	73.6	$6,379
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	16	0	0	0	0	0	0	0	0	$0
Repeat failed performance test f										$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	30	1	30	0	0	0	0	0	0	$0
Subtotal for Reporting Requirements						74				$6,379
8 Record/transmit/disclose j	2	52	0	0	0	0	0	0	0	$0
Due To Proposed Revisions k	8	2	16	16	32	256	12.8	25.6	294.4	$25,514
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						294				$25,514
TOTAL LABOR BURDEN AND COST (rounded)										$31,900
Capital and O&M Cost (see Section 6(b)(iii)): m										$0
TOTAL COST					48					$31,900
Assumptions:
a It is assumed that there are 16 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: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 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 NAICS 337000 - Furniture and Related Product 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 ten 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 It is assumed that 20 percent of respondents will have to repeat performance tests.
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 four hours, four 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 ten hours for notifications, ten hours for performance test, and ten hours for 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 Metal Furniture 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	16	0	0	0	0	0	0	0	0	$0
Repeat failed performance test f										$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	2	16	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 16 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: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 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 NAICS 337000 - Furniture and Related Product 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 ten 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 It is assumed that 20 percent of respondents will have to repeat performance tests.
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 four hours, four 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 ten hours for notifications, ten hours for performance test, and ten hours for 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 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP Year 3 (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	16	0	0	0	0	0	0	0	0	$0
Repeat failed performance test f										$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	2	16	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 16 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: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 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 NAICS 337000 - Furniture and Related Product 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 ten 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 It is assumed that 20 percent of respondents will have to repeat performance tests.
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 four hours, four 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 ten hours for notifications, ten hours for performance test, and ten hours for 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 Metal Furniture 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	320	32	16	368	$32,000	$0	$32,000
2	0	0	0	0	$0	$0	$0
3	0	0	0	0	$0	$0	$0
Total	320	32	16	368	$32,000	$0	$32,000
Average	107	11	5.3	123	$11,000	$0	$11,000
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	16	48	74	294	368	8.0	23
2	16	0	0	0	0	0	0
3	16	0	0	0	0	0	0
Total	48	48	74	294	368	8.0	23
Average	16	16	25	98	123	2.7	7.7
(a) = Average annual additional costs per respondent: $690

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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 Metal Furniture 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								$0
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	16	64	3.2	6.4	$3,451
TOTAL ANNUAL BURDEN AND COST (rounded)					74			$3,500
Assumptions:
a It is assumed that there are 16 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 Metal Furniture 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								$0
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 16 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 Metal Furniture 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								$0
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 16 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 Metal Furniture NESHAP (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	64	3.2	6.4	74	$3,500	$0	$3,500
2	0	0	0	0	$0	$0	$0
3	0	0	0	0	$0	$0	$0
Total	64	3.2	6.4	74	$3,500	$0	$3,500
Average	21	1.1	2.1	25	$1,200	$0	$1,200
Year	Number of Responses	Total Hours
1	16	74	(a)
2	0	0
3	0	0
Total	16	74
Average	5.3	25
(a) = Average annual additional hours per respondent: 4.6