Burden Calculation Tables

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Overview

Labor Rate and Summary Data
Table 1
Table 2

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Sheet 1: Labor Rate and Summary Data

Number of Respondents								Total Annual Responses
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports					(A)	(B)	(C)	(D)	(E)
	(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
Year	Number of New Respondents 1	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)			Initial Notification	6	1	0	6
1	6	185	0	0	191			Notification of performance test	6	1	0	6
2	6	191	0	0	197			Notification of compliance status	6	1	0	6
3	6	197	0	0	203			Performance test reports	6	1	0	6
Average	6	191	0	0	197			SSM reports	174	0.2	0	34.8
1 New respondents include sources with constructed and reconstructed affected facilities.								Semiannual report	197	2	0	394
											Total	452.8
Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, September 2018, “Table 2. Civilian Workers, by occupational and industry group.”)				Hours per Response				Note: SSM reports are typically submitted with the semiannual reports. We assume that all 197 facilities use control devices, conducting emission or parametric monitoring, and all 197 will submit an additional report of non-conforming SSM 20% of the time.
Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)		12000	# hours
Mgmt.	$70.19	$147.40		453	# responses
Tech.	$56.15	$117.92		27	hr/resp
Cler.	$27.15	$57.02
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 a	Total O&M, (E X F)
Parametric monitoring (contractor)	$10,000	5	$50,000	$25	174	$4,350
Continuous emission monitoring system (CEMS)	$183,500	1	$183,500	$26,700	23	$614,100
Total cost (rounded) b			$234,000			$618,000
a We estimate an average of 197 sources during the three-year period of this ICR, and that 174 of these sources will use CPMS and 23 sources CEMS. We also estimate that 6 new sources per year will become subject to the rule. Of the new sources, one source will be using solvent recovery devices and will use CEMS to monitor emissions.
b Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal)
					$117.92	$147.40	$57.02
	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Reporting requirements
A. Familiarization with regulatory requirements	4	1	4	197	788	39.4	78.8	$103,221.70
B. Gather information c	4	4	16	6	96	4.8	9.6	$12,575.23
C. Write reports c
i. Initial notification	2	1	2	6	12	0.6	1.2	$1,571.90
ii. Notification of performance test	2	1	2	6	12	0.6	1.2	$1,571.90
iii. Notification of compliance status	2	1	2	6	12	0.6	1.2	$1,571.90
iv. Performance test reports	2	1	2	6	12	0.6	1.2	$1,571.90
v. SSM reports d	2	0.2	0.4	174	69.6	3.48	6.96	$9,117.04
vi. Semiannual summary report	4	2	8	197	1576	78.8	157.6	$206,443.39
Subtotal for Reporting Requirements					2,964			$337,645
2. Recordkeeping requirements
A. Read instructions c	4	1	4	6	24	1.2	2.4	$3,143.81
B. Plan activities c	15	1	15	6	90	4.5	9	$11,789.28
C. Implement activities for compliance coating use f	5	12	60	21	1260	63	126	$165,049.92
D. Implement activities for control devices and process equipment c
i. Design analysis	12	1	12	6	72	3.6	7.2	$9,431.42
ii. Performance test oversight	20	1	20	6	120	6	12	$15,719.04
E. Develop record system
i. Develop startup, shutdown, malfunction plan c	20	1	20	6	120	6	12	$15,719.04
ii. Develop plan for material used f	10	1	10	21	210	10.5	21	$27,508.32
iii. Control equipment and maintenance plan c	10	1	10	6	60	3	6	$7,859.52
F. Time to enter information
i. Compliance calculation e	2	12	24	21	504	25.2	50.4	$66,019.97
ii. Control equipment testing f	1	1	1	197	197	9.85	19.7	$25,805.42
G. Time to train personnel
i. Acquisition and installation c	15	1	15	6	90	4.5	9	$11,789.28
ii. Equipment inspection and monitoring f	10	1	10	197	1970	98.5	197	$258,054.24
iii. Use of technology and systems f	10	1	10	197	1970	98.5	197	$258,054.24
H. Store, file and maintain records g	0.25	12	3	197	591	29.55	59.1	$77,416.27
I. Retrieve records/reports g	0.25	12	3	197	591	29.55	59.1	$77,416.27	Last ICR
Subtotal for Recordkeeping Requirements					9,049			$1,030,776	Hours	Cost
TOTAL LABOR BURDEN AND COST (rounded) h					12,000			$1,370,000	13,800	1,380,000
TOTAL CAPITAL AND O&M COST (rounded) h								$852,000		1,010,000
GRAND TOTAL COST (rounded) h								$2,220,000		2,390,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 197. There will be eighteen additional new sources that will become subject to the rule over the three-year period of the ICR (i.e., six 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 $56.15 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that this is a one-time activity for one new facility using a solvent recovery device.
d Startup, shutdown, malfunction (SSM) reports are to be submitted twice a year with the required semiannual report, and the SSM report applies only to the estimated 174 facilities using a CMPS (see 40 CFR 63.3400). An estimated 20 percent of the respondents using parametric monitoring will submit an additional report for a non-conforming SSM.
e We have assumed that 21 respondents will record activities for compliance coating use.
f We have assumed that 197 respondents for this activity.
g We have assumed that 197 respondents will be involved in the storage, filing, maintenance and retrieval of records and reports twelve times per year.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal)
					48.75	65.71	26.38
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Review initial notification c	8	1	8	6	48	2.4	4.8	$2,624.33
2. Review notification of compliance status c	10	1	10	6	60	3	6	$3,280.41
3. Review SSM reports d	4	0.2	0.8	174	139.2	6.96	13.92	$7,610.55
4. Review semiannual summary reports e	15	2	30	197	5910	295.5	591	$323,120.39
5. Review notification of performance test c	4	1	4	6	24	1.2	2.4	$1,312.16	Last ICR
6. Review test results c, f	10	1	10	6	60	3	6	$3,280.41	Hours	Cost
TOTAL ANNUAL BURDEN AND COST (rounded) g					7,180			$341,000	9,080	413,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 197. There will be eighteen additional new sources that will become subject to the rule over the three-year period of the ICR (i.e., six 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: $65.71 for Managerial (GS-13, Step 5), $48.75 for Technical (GS-12, Step 1), and $26.38 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We have assumed that this is a one-time activity for each new facility.
d Startup, shutdown, malfunction (SSM) reports are to be submitted twice a year with the required semiannual report. However, as estimated 20 percent of the respondents using parametric monitoring will submit an additional report for a non-conforming SSM.
e It is assumed that the agency will review summary reports twice per year.
f We have assumed that it will take the agency ten hours to review test results.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.