Burden Calculation Table

---

Overview

Table 1
Table 2
Capital O&M
Number of Responses

---

Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)
Burden Item	Person‑Hours per occurrence (A)	Number of occurrences per year (B)	Person‑Hours per respondent per year (C=AxB) (C )	Respondents per Year a (D)	Technical Person Hours per Year (E=CxD) (E)	Managerial Person Hours per Year (F=Ex0.05) (F)	Clerical Person Hours per Year (G=Ex0.10) (G)	Annual Costs per Year b (H)		Managerial (per hour)	Technical (per hour)	Clerical (per hour)	Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.”)
1. Applications	N/A									$147.40	$117.92	$57.02	Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
2. Survey and Studies	N/A												Mgmt.	$70.19	$147.40
3. Reporting requirements													Tech.	$56.15	$117.92
A. Familiarization with regulatory requirements	1	1	1	400	400	20	40	$52,394.58					Cler.	$27.15	$57.02
B. Required Activities
Initial Performance Tests	60	1	60	0	0	0	0	$0
Repeat Performance Tests c	60	0.2	12	0	0	0	0	$0
C. Gather Existing Information	See 3b
D. Write Report
Notification of Construction or Reconstruction	2	1	2	0	0	0	0	$0
Notification of Initial Performance Test	2	1	2	0	0	0	0	$0
Notification of Actual Startup	2	1	2	0	0	0	0	$0
Report of Performance Test	See 3b
Semiannual Report d	8	2	16	400	6400	320	640	$838,313.28
Quarterly Excess Emissions Report and Semiannual Monitoring Systems Performance Report e	16	2	32	80	2560	128	256	$335,325.31
Subtotal for Reporting Requirements					10,764			$1,226,033
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3b
B. Plan activities	See 3b
C. Implement activities
Monthly Performance Test f	1	12	12	400	4800	240	480	$628,734.96
D. Develop record system	N/A
Records of Operating Parameter g	0.25	350	87.5	400	35000	1750	3500	$4,584,525.75
Subtotal for Recordkeeping Requirements					45,770			$5,213,261
TOTAL LABOR BURDEN AND COST (rounded) h					56,500			$6,440,000
TOTAL CAPITAL AND O&M COST (rounded) h								$840,000		Hours Per Response
GRAND TOTAL (rounded) h								$7,280,000		59	hr/resp
a We have assumed that there are approximately 400 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: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” 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 tests will fail 20% of the time.
d We have assumed that each respondent will take eight hours twice per year to complete the semiannual report.
e We have assumed that 20 percent of respondents will experience twice a year both a monitoring exceedance under 40 CFR 60.315(c) and an exceedance of the standard in 40 CFR 60.312. We assume that it will take 16 hours to complete these reports, assuming it takes 8 hours to complete each excess emissions report in 40 CFR 60.315(b) and 8 hours to complete each monitoring systems performance report in 40 CFR 60.315(c).
f We have assumed that each respondent will take one hour once per month to record monthly performance test.
g We have assumed that each respondent will take 0.25 hours per day over 350 days per year to keep record of operating parameters.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Furniture Coating (40 CFR Part 60, Subpart EE) (Renewal)
Activity	EPA Hours per Occurrence (A)	Number of occurrences per year (B)	EPA Person Hours per Year (C=AxB) (C)	Respondents per Year (D) a	Technical Person Hours per Year (E=CxD) (E)	Managerial Person Hours per Year (F=Ex0.05) (F)	Clerical Person Hours per Year (G=Ex0.10) (G)	Annual Costs ($/year) b (H)		Managerial (per hour)	Technical (per hour)	Clerical (per hour)	Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
Required activities										$65.71	$48.75	$26.38		Hourly Mean Wage	With Fringe & Overhead
Initial performance test	24	1	24	0	0	0	0	$0					(GS- 12, step 1) - Tech.	30.47	$48.75
Repeat performance test c	24	0.2	4.8	0	0	0	0	$0					(GS- 13, step 5) - Mgmt.	41.07	$65.71
Report review													(GS-6, step 3) - Cler.	16.49	$26.38
Notification of Construction	2	1	2	0	0	0	0	$0
Notification of Initial Startup	0.5	1	0.5	0	0	0	0	$0
Notification of Actual Startup	0.5	1	0.5	0	0	0	0	$0
Notification of Initial Performance Test	0.5	1.2	0.6	0	0	0	0	$0
Performance Test Results	8	1.2	9.6	0	0	0	0	$0
Semiannual Reports d	2	2	4	400	1600	80	160	$87,481.60
Quarterly Excess Emissions Report and Semiannual Monitoring Systems Performance Report e	2	2	4	80	320	16	32	$17,496.32
TOTAL ANNUAL BURDEN AND COST (rounded) f					2,210			$105,000
a We have assumed that there are approximately 400 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). The rates have been increased by 60 percent to account for the benefit packages available to government employees. These rates are from the Office of Personnel Management (OPM), 2018 General Schedule, which excludes locality rates of pay.
c We have assumed that tests will fail 20% of the time.
d We have assumed that it will take two hours twice per year to review the semiannual report.
e We have assumed that EPA will take two hours to review both reports: one hour to review each excess emissions report and one hour to review each monitoring systems performance report. We also assumed that 20 percent of existing plants will submit twice per year an excess emissions reports and a monitoring systems performance report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost (B x C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M (E x F)
Temperature	4,400	0	$0	$2,100	400	$840,000

---

Sheet 4: Number of Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	0	1	0	0
Notification of initial performance test	0	1.2	0	0
Notification of actual startup	0	1	0	0
Initial performance test report	0	1.2	0	0
Semiannual report	400	2	0	800
Quarterly Excess Emissions Report and Semiannual Monitoring Systems Performance Report	80	2	0	160
			Total	960