Burden Calculation Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden
Capital O&M

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Sheet 1: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	158	0	0	158
2	0	158	0	0	158
3	0	158	0	0	158
Average	0	158	0	0	158
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

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Sheet 2: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of CMS demonstration date	0	1	0	0
Notification of performance test	0	1	0	0
VOC emissions report	142	2	0	284
Excess emissions report	16	4	0	64		new - previously the quarterly line item was missing
Temperature variance report	126	0.5	0	63
			Total	411		-- increase from prev. ICR -old responses # was 379

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)
										TECH	$112.98
Burden item	(A) Person-hours per occurrence	(B) Annual occurrences per respondent	(C) Person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b	ERG Notes	MGMT	$149.35
1. Applications	N/A									CLER	$54.81
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirementsa	1	1	1	158	158	8	16	19,896.70		Source Type	No.
B. Required activities										Existing	158
Initial performance test c	30	0.07	2	0	0	0	0	0	made the hours consistent with the NESHAP 1957.08 and the related RTR rules; these are facility hours only the test is contracted out.	New	0
Repeat performance test c	30	0.07	2	0	0	0	0	0	made the hours consistent with the NESHAP 1957.08 and the related RTR rules; these are facility hours only the test is contracted out.
C. Gather existing information	See 3B
D. Write report
Notification of construction/reconstructionc	2	1	2	0	0	0	0	0
Notification of actual startupc	2	1	2	0	0	0	0	0
Notification of CMS demonstration date	2	1	2	0	0	0	0	0
Report of performance testc	See 3B
VOC emissions reportd	5	2	10	142	1,420	71	142	178,818.47	90% do not have exceess
Excess emissions reportd	5	4	20	16	320	16	32	40,297.12	10% have excess
Temperature variance report e	4	0.5	2	126	252	12.6	25.2	31,733.98
Subtotal for Reporting Requirements					2,473			270,746
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities
Monthly VOC weighted average calculationsf	1	12	12	32	384	19.2	38.4	48,356.54	60.465(a)
D. Develop record system
Records of temperaturee	0.25	365	91.25	126	11,498	575	1,150	1,447,862.93	daily temperature, 60.465(e)
Records of data used to support monthly VOC calculationsf	0.25	12	3.0	32	96	4.8	9.6	12,089.14	monthly calculations 60.465 (e)
Subtotal for Recordkeeping Requirements					13,774			1,508,309
TOTAL ANNUAL BURDEN AND COST (ROUNDED)g					16,200			1,780,000			increase from last renewal of 15,643; increase attributed to accounting for hours to familiarize with requlatory requirements each year, and the adjusted frequency of records for sources complying with incineration (daily) vs sources complying with VOC content (monthly calculations). In addition this renewal estimates burden for a small fraction of sources that may have excess emissions.
Total CAPITAL and O&M COST (rounded)g								170,000			decrease from last renewal because only 80% of sources have O&M associated with temperature monitoring.
GRAND TOTAL (rounded)g					16,200			1,950,000
								39 hrs/resp
a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR. This ICR assumes each respondent will incur a burden to re-familiarize themselves with the regulatory requirements each year.
b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c This is a one-time requirement and does not apply since no new sources are estimated. EPA assumes 20% of new sources must repeat performance testing due to failure.
d EPA assumes 10% of respondents have excess VOC emissions and must report quarterly instead of semi-annually. The remaining 90% of sources report semi-annually.
e EPA assumes 80% of facilities will use incineration, and will file a temperature variance report every other year. These facilities will also have to maintain daily temperature records of incinerator combustion temperature (for therm incineration) or gas temperature (for catalytic incineration)									So, this means that 80% of them have a control device to destruct emissions, and that only 20% are using the monthly averaging approach. I adjusted the burden above and created new footnotes to account for this.
f EPA assumes the remaining 20% of sources do not have control devices will compliy using the monthly weighted average VOC calculation approach.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)
											TECH	$48.08
Burden item	(A) EPA person-hours per occurrence	(B) Annual occurrences per respondent	(C) EPA person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b			MGMT	$64.80
Initial performance test											CLER	$26.02
New plantc	24	0.07	2	0	0	0	0	0
Repeat performance test
New plant c	24	1	24	0	0	0	0	0
Report review
New plantc
Notification of construction/reconstruction	2	1	2	0	0	0	0	0
Notification of actual startup	0.5	1	0.5	0	0	0	0	0
Notification of CMS demonstration date	0.5	1	0.5	0	0	0	0	0
Review test results	8	1	8	0	0	0	0	0
Existing plant
VOC emissions reportd	2	2	4	142	568	28.4	56.8	30,627.70
Excess emissions reportd	2	4	8	16	128	6.4	12.8	6,902.02
Temperature variance report e	2	0.5	1	126	126	6.3	12.6	6,794.17
TOTAL ANNUAL BURDEN AND COST (ROUNDED)f					945			44,300			increase since last renewal of 872 hours
a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). 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 This is a one-time requirement and does not apply since no new sources are estimated.
d EPA assumes 10% of sources will have excess emissions and will file a quarterly report instead of the semi-annual frequency submitted from the other 90% of sources.
e EPA assumes 80% of facilities will use incineration, and will file a temperature variance report every other year.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
						(E X F)
Temperature Monitoring System	N/A	N/A	0	$1,200a	142	$170,400
Method 25 Performance Test	$18,750b	0	$0	N/A	N/A	$0
Total			0			$170,000		decrease since previous renewal which assumed all 158 sources had temperature monitoring
a According to industry consultation comment received on an ICR for a related rulemaking (40 CFR part 63 subpart SSSS), the O&M cost to maintain continuous temperature measuring monitor is $1,200 per respondent. The cost covers replacement of temperature sensor each calendar year. This cost is applied to the 80 percent of respondents assumed to use an incinerator to comply with the requirements.
b Costs included to contract out for a one-time initial performance test using Method 25 or Method 25A for facilities with control devices. It is assumed that all existing facilities have conducted an initial performance test.