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	1	18	0	0	19
2	1	19	0	0	20
3	1	20	0	0	21
Average	1	19	0	0	20
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		ERG Notes:
Initial notification	1	1	0	1
Application for construction/reconstruction	1	1	0	1
Notification of performance test	1	1	0	1
Notification of compliance status	1	1	0	1
Initial compliance report
Loop slitter sources	0	1	0	0
Flame lamination sources	1	1	0	1
Subsequent compliance reports
Loop slitter sources	0	1	0	0
Flame lamination sources (semiannual reports)	20	2	0	40
SSM report	20	10	0	200
			Total	245
			hrs/response:	90.6

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal)
				Labor Rates:	$117.92	$147.40	$57.02			These rates were updated 11/15/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Familiarization with rule requirements
New Sources	4	1	4	1	4	0.2	0.4	$523.97		<--Split this out into two rows for new and existing, as we are now accounting for existing sources to do this, but it should take less time as they should be somewhat familiar with rule.
Existing Sources	1	1	1	19	19	1.0	1.9	$2,488.85
2. Gather information	4	1	4	20	80	4.0	8.0	$10,479.36
3. Reports
a. Initial notification	2	1	2	1	2	0.1	0.2	$261.98		Source Type	No.
b. Application for construction/reconstruction	2	1	2	1	2	0.1	0.2	$261.98		Existing (average)	19
c. Notification of performance test	2	1	2	1	2	0.1	0.2	$261.98		New	1
d. Notification of compliance status	20	1	20	1	20	1	2	$2,619.84		ERG Notes:	20
e. Initial compliance report
i. Flame lamination facilities	8	1	8	1	8	0.4	0.8	$1,047.94
ii. Loop slitter facilities	8	1	8	0	0	0	0	$0
f. Annual compliance report c	2	1	2	0	0	0	0	$0
g. Semiannual compliance report	4	2	8	20	160	8.0	16.0	$20,958.72
h. SSM report d	2	10	20	20	400	20	40	$52,396.80
Reporting Subtotal					801			$91,301
3. Recordkeeping requirements
a. Plan activities	10	1	10	1	10	0.5	1	$1,309.92
b. Implement activities for flame lamination
i. Record SSM	1	100	100	20	2,000	100	200	$261,984.00
ii. Conduct performance test e	50	1	50	1	50	2.5	5	$6,549.60
iii. Record CPMS measurements	2	300	600	20	12,000	600	1,200	$1,571,904.00
iv. CPMS calibration and maintenance f	4	50	200	20	4,000	200	400	$523,968.00
c. Implement activities for loop slitters
i. Record adhesives used and suppliers	1	1	1	0	0	0	0	$0
ii. Conduct Method 311 test	4	1	4	0	0	0	0	$0
d. Develop record system
i. SSM plan	40	1	40	1	40	2	4	$5,239.68
ii. CPMS maintenance plan	20	1	20	1	20	1	2	$2,619.84
e. Time to train personnel
i. CPMS acquisition and installation	20	1	20	1	20	1	2	$2,619.84
ii. CPMS inspection and monitoring	4	1	4	1	4	0.2	0.4	$523.97
f. Store, file, and maintain all records g	1	12	12	20	240	12.0	24.0	$31,438.08
g. Retrieve records/reports h	1	12	12	20	240	12.0	24.0	$31,438.08
Recordkeeping Subtotal					21,417			$2,439,595
TOTAL LABOR BURDEN AND COST (rounded) i					22,200			$2,530,000
TOTAL ANNUAL CAPITAL AND O&M COST (rounded) i								$34,500
GRAND TOTAL (rounded) i								$2,560,000		Prev. renewal 18,900 hrs and $1,930,000. Net increase due to industry growth.
CPMS - Continuous Parameter Monitoring System										3,300
SSM - Startup, Malfunction, or Startup
Assumptions:
a EPA estimates an average of 19 existing sources will be subject to the standard. One additional new source (flame lamination) will become subject to the rule over the three-year period of this ICR, for a total of 20 respondents per year.
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 Applies to loop slitter adhesive facilities only.
d EPA assumes each respondent will submit SSM reports ten times per year.
e EPA assumes this activity also includes writing the site-specific test plan.
f EPA assumes each respondent will implement CPMS calibration and maintenance activities 50 times per year.
g EPA assumes each respondent will file and maintain records on a monthly basis.
h EPA assumes each respondent will retrieve records/reports 12 times per year.
i 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 – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal)
				Labor Rates:	$48.75	$65.71	$26.38			These rates were updated 11/15/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		ERG Notes:
Review initial notification	4	1	4	1	4	0.2	0.4	$218.69
Review application for construction/reconstruction	4	1	4	1	4	0.2	0.4	$218.69
Review notification of performance test	4	1	4	1	4	0.2	0.4	$218.69
Review notification of compliance status	20	1	20	1	20	1	2	$1,093.47
Review initial compliance report
Flame lamination facilities	20	1	20	1	20	1	2	$1,093.47
Loop slitter facilities	2	1	2	0	0	0	0	$0
Review annual compliance report c	1	1	1	0	0	0	0	$0
Review semiannual compliance report	15	2	30	20	600	30.0	60	$32,804.10
Review SSM report	8	10	80	20	1,600	80	160	$87,477.60
TOTAL ANNUAL BURDEN AND COST (rounded)					2,590			$123,000		Prev renewal: 2,210 hrs and $101,000. Net increase due to industry growth.
Assumptions:
a EPA estimates an average of 19 existing sources will be subject to the standard. One additional new source (flame lamination) will become subject to the rule over the three-year period of this ICR, for a total of 20 respondents per year.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 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%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c Applies to loop slitter adhesive facilities only.
d 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)
Requirement	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C) b	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Differential pressure, pH, liquid flow rate, data recorder	$997	1	$997	$1,674	20	$33,480
Total			$997			$33,500
N/A - Not Applicable