Burden Calculation Tables

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Overview

Table 1
Table 2
Capital & O&M
# Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (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)
1. Applications	N/A									$147.40	$117.92	$57.02
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirements	1	1	1	72	72	3.6	7.2	$9,431.02		Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.”)
B. Required Activities										Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
Initial Performance Tests	60	1	60	0	0	0	0	$0		Mgmt.	$70.19	$147.40
Repeat Performance Tests	60	0.2	12	0	0	0	0	$0		Tech.	$56.15	$117.92
C. Gather Existing Information	See 3b									Cler.	$27.15	$57.02
D. Write Report
Notification of Construction/ 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 c	5	2	10	72	720	36	72	$94,310.24
Quarterly Excess Emissions Report and Semiannual Monitoring Systems Performance Report d	4	2	8	15	120	6	12	$15,718.37
Subtotal for Reporting Requirements					1,049			$119,460
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3b
B. Plan activities	See 3b
C. Implement activities
Monthly Performance Test e	1	12	12	72	864	43.2	86.4	$113,172.29
D. Develop record system	N/A
Records of Operating Parameter f	0.25	250	62.5	72	4500	225	450	$589,439.03
Subtotal for Recordkeeping Requirements					6,169			$702,611
TOTAL LABOR BURDEN AND COST (rounded)g					7,220			$822,000
TOTAL CAPITAL AND O&M COST (rounded)g								$8,400
GRAND TOTAL (rounded)g								$830,000
Assumptions:
a We have assumed that there are approximately 72 existing sources currently subject to this rule, with no additional new sources becoming subject to the rule over the three-year period of this ICR.
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 each respondent will take 5 hours twice per year to complete the semiannual report.
d We have assumed that 15 respondents will take 4 hours twice per year to write the excess emission report and temperature variance report. We have assumed that 20 percent of respondents (0.20*72=14.4 facilities) will exceed the emission standard in 40 CFR 60.452 at least once in each of two quarterly reporting periods, so will be required to write the quarterly excess emission report in 40 CFR 60.455(b) twice per year. We have assumed that 5% of respondents (i.e., 0.05*72=4 facilities) use incineration, and that 20% of these 4 respondents with incineration (0.20*4=0.8) will exceed their temperature limit during both 6-month periods of each year, so will be required to prepare semiannual monitoring exceedance reports twice per year under 40 CFR 60.455(c). (14.4 respondents + 0.8 respondents =15 respondents)
e We have assumed that each respondent will take one hour once per month to record the monthly performance test.
f We have assumed that each respondent will take 0.25 hours 250 times per year to record operating parameter.
g 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 – NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (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)
Required activities										$65.71	$48.75	$26.38
Initial performance test	24	1	24	0	0	0	0	$0.00
Repeat performance test	24	0.2	4.8	0	0	0	0	$0.00		Agency Rates Source: Office of Personnel Management (OPM), 2018 General Schedule
Report review											Hourly Mean Wage	With Fringe & Overhead
Notification of Construction/ Reconstruction	2	1	2	0	0	0	0	$0.00		(GS- 12, step 1) - Tech.	30.47	$48.75
Notification of Actual Startup	0.5	1	0.5	0	0	0	0	$0.00		(GS- 13, step 5) - Mgmt.	41.07	$65.71
Notification of Initial Performance Test	0.5	1	0.5	0	0	0	0	$0.00		(GS-6, step 3) - Cler.	16.49	$26.38
Performance Test Results	8	1.2	9.6	0	0	0	0	$0.00
Semiannual Reports c	2	2	4	72	288	14.4	28.8	$15,746.69
Quarterly Excess Emissions Report and Semiannual Monitoring Systems Performance Report e	2	2	4	15	60	3	6	$3,280.56
TOTAL ANNUAL BURDEN AND COST (rounded) e					400			$19,000
Assumptions:
a We have assumed that there are approximately 72 existing sources currently subject to this rule. There will be no additional new 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 $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 EPA will take two hours twice per year to review semiannual reports.
d We have assumed that EPA will take 2 hours twice per year to review quarterly excess emissions and semiannual monitoring systems performance reports. We have assumed that 20 percent of respondents (0.20*72=14.4 facilities) will exceed the emission standard in 40 CFR 60.452 once per 6-month reporting period and be required to write the excess emission report in 40 CFR 60.455(b) twice per year. We have assumed that 5% of respondents (i.e., 0.05*72=4 facilities) use incineration, and that 20% of these 4 respondents with incineration (0.20*4=0.8) will exceed their temperature limit during both 6-month periods of each year and be required to prepare semiannual monitoring exceedance report twice per year under 40 CFR 60.455(c). (14.4 respondents + 0.8 respondnents =15 respondents)
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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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 a	(G) Total O&M (E x F)
Temperature	8,000	0	$0	$2,100	4	$8,400
a We are assuming that only 5% of facilities use incineration.

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Sheet 4: # 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 performance test	0	1	0	0
Notification of actual startup	0	1	0	0
Report of performance test	0	1.2	0	0
Semiannual report	72	2	0	144
Quarterly Excess Emissions Report and Semiannual Monitoring Systems Performance Report	15	2	0	30
			Total	174
Total Respondent Hours:	7,217
Hours Per Response:	41