Burden Calculation Tables

1952t09.xlsx

NESHAP for Metal Furniture Surface Coating (40 CFR part 63, subpart RRRR) (Final Rule)

Burden Calculation Tables

OMB: 2060-0518

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Overview

Cover
Inputs
Current ICR
TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-SUMMARY
TBL5-EPA-YR1
TBL6-EPA-YR2
TBL7-EPA-YR3
TBL8-EPA SUMMARY


Sheet 1: Cover

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY


National Emission Standards for Hazardous Air Pollutants for Surface Coating of Metal Furniture (40 CFR Part 63, Subpart RRRR) (Amendments)


ATTACHMENT 1



TABLES 1, 2, 3, and 4


Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP – Years 1-3 (Amendments)




Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for theSurface Coating of Metal Furniture NESHAP (Amendments)




ATTACHMENT 2



TABLES 5, 6, 7, and 8


Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP - Year 1-3 (Amendments)


Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP (Amendments)

Sheet 2: Inputs

Respondent Wages ($2016)
Category (1) Hourly Mean Wage (2) Loaded Wage (3)
Technical $43.02 $90.34
Clerical $17.96 $37.72
Managerial $52.87 $111.03
Footnotes:

(1) The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 337000 - Furniture and Related Product Manufacturing," found here:
https://www.bls.gov/oes/current/naics3_337000.htm
(2) Selected "mean hourly wage" in the table referenced in footnote 1.
(3) Loaded Wage is the 2016 Wage increased by 110 percent to account for the benefit packages available to those employed by private industry.






EPA Wages ($2016)
Category (1) Hourly Mean Wage Wage With Fringe & Overhead (2)
(GS- 12, step 1) - Technical $30.05 $48.08
(GS- 13, step 5) - Managerial $40.50 $64.80
(GS-6, step 3) - Clerical $16.26 $26.02
Footnotes:

(1) The hourly mean wage for each category is found here:

https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/17Tables/html/GS_h.aspx
(2) Wage with fringe and overhead is the hourly mean wage increased by 60 percent to account for the benefit packages available to government employees.

Sheet 3: Current ICR

Table 1: Annual Respondent Burden and Cost – NESHAP for Surface Coating of Metal Furniture (40 CFR Part 63, Subpart RRRR) (Amendments)
















Burden Item (A) (B) (C) (D) (E) (F) (G) (H)

Person‑hours per occurrence Number of occurrences per year Person‑hrs. per respondent per year Respondents per year Technical person‑hrs. per year Management person‑hrs. per year Clerical person‑hrs. per year Annual costs ($)



(C=AxB)
(E=CxD) (F=Ex0.05) (G=Ex0.1)
1. Reporting requirements
a. Familiarize with rule requirements 4 1 4 583 2,332 116.6 233.2 $232,419
b. Process/review information 4 4 16 583 9,328 466.4 932.8 $929,675
c. Write reports
i. Initial notification 2 1 2 0 0 0 0 $0
ii. Notification of compliance status 2 1 2 0 0 0 0 $0
iii. Notification of construction/reconstruction 2 1 2 0 0 0 0 $0
iv. Notification of actual startup 2 1 2 0 0 0 0 $0
v. Notification of performance test 2 1.2 2.4 0 0 0 0 $0
vi. Report of performance test 10 1.2 12 0 0 0 0 $0
vii. Semiannual report 6 2 12 583 6,996 349.8 699.6 $697,256
viii. Excess emissions report 4 0.5 2 583 1,166 58.3 116.6 $116,209
ix. Startup, shutdown, malfunction report 4 0.5 2 583 1,166 58.3 116.6 $116,209
Subtotal for Reporting Requirements



24,136 $2,091,768
2. Recordkeeping requirements
a. Familiarize with rule requirements 4 1 4 583 2,332 116.6 233.2 $232,419
b. Plan activities 12 1 12 583 6,996 349.8 699.6 $697,256
c. Implement activities 12 1 12 583 6,996 349.8 699.6 $697,256
d. Maintain record system for material used 20 1 20 583 11,660 583 1166 $1,162,093
e. Time to enter information
i. Material usage 0.5 260 130 583 75,790 3789.5 7579 $7,553,607
ii. Compliance calculation 2 12 24 583 13,992 699.6 1399.2 $1,394,512
f. Time to train personnel 10 1 10 583 5,830 291.5 583 $581,047
g. Store, file, and maintain records 2 12 24 583 13,992 699.6 1399.2 $1,394,512
h. Retrieve records/reports 1 12 12 583 6,996 349.8 699.6 $697,256
Subtotal for Recordkeeping Requirements



166,272 $14,409,957
TOTAL ANNUAL BURDEN AND COSTS (rounded): g



190,000 $16,500,000
Capital and O&M Cost (see Section 6(b)(iii)): g






$700,000
TOTAL COST: g






$17,200,000









Assumptions:
















a We have assumed that there are approximately 583 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: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 per hour for Clerical







labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage







Estimates NAICS 337000 - Furniture and Related Product Manufacturing." 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 six hours twice per year to complete the semiannual report.







d We have assumed that each respondent will take four hours twice per year to complete the excess emissions reports and also four hours twice per year for the SSM reports.







e We have assumed that each respondent will take 0.5 hours 260 times per year to enter information.







f We have assumed that each respondent will have to complete task once per month.







g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.


































Table 2: Average Annual EPA Burden and Cost – NESHAP for Surface Coating of Metal Furniture (40 CFR Part 63, Subpart RRRR) (Amendments)
















Burden Item (A) (B) (C) (D) (E) (F)


Person‑hours per activity Number of activities per year Technical person‑hours per year Management person‑hours per year Clerical person‑hours per year Annual costs ($/yr)




(C=AxB) (D=Cx0.05) (E=Cx0.1)


1. Initial performance test 24 0 0 0 0 $0

2. Repeat performance test 24 0 0 0 0 $0

3. Report review







a) Initial notification 8 0 0 0 0 $0

b) Notification of performance test 8 0 0 0 0 $0

c) Notification of compliance status 8 0 0 0 0 $0

d) Notification of construction/reconstruction 8 0 0 0 0 $0

e) Notification of actual startup 8 0 0 0 0 $0

f) Notification of performance test 8 0 0 0 0 $0

g) Report of performance test 8 0 0 0 0 $0

h) Semiannual report 12 1,166 13,992 699.6 1399.2 $754,471

i) Excess emissions report 8 291.5 2,332 116.6 233.2 $125,745

j) Startup, shutdown, malfunction report 8 291.5 2,332 116.6 233.2 $125,745

Total Burden (Hrs) and Costs

21,500 $1,006,000










Assumptions:
















a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80







(GS-13, Step 5, $40.50 + 60%) for Managerial, $48.08 (GS-12, Step 1, $30.05 + 60%) for Technical, and $26.02 (GS-6, Step 3, $16.26 + 60%) for Clerical. These







rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.







b The semiannual report would have to be completed twice per year.







g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.








Sheet 4: TBL1-YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP
Year 1 (Amendments)
Burden item (A) (B) (C) (D) (E) (F) (G) (H) (I) (J)
Person hours per occurrence No. of occurrences per respondent per year Person hours per respondent per year (C=AxB) Respondents per year a Total Number of Responses per Year
(E=BXD)
Technical person- hours per year
(F=CxD)
Management person hours per year (G=Fx0.05) Clerical person hours per year (H=Fx0.1) Total Hours per Year
(I=F+G+H)
Total Cost Per year b
1 Familiarization with rule requirements c 4 1 4 16 16 64 3.2 6.4 73.6 $6,379
2 Plan activities 0 0 0 0 0 0 0 0 0 $0
3 Training d 8 1 0 0 0 0 0 0 0 $0
Due To Final Revisions e 8 1 8 0 0 0 0 0 0 $0
4 Add-on control performance test f 16 0 0 0 0 0 0 0 0 $0
Repeat performance test g








$0
5 Gather info, monitor, inspect, and determine complaince h 12 12 144 0 0 0 0 0 0 $0
6 Process/compile and review i 8 12 96 0 0 0 0 0 0 $0
7 Complete notifications and reports j 30 1 30 0 0 0 0 0 0 $0
Subtotal for Reporting Requirements 74 $6,379
8 Record/transmit/disclose k 2 52 0 0 0 0 0 0 0 $0
Due To Final Revisions l 8 2 16 16 32 256 12.8 25.6 294.4 $25,514
9 Store/file m 0.25 2 0 0 0 0 0 0 0 $0
10 Reporting and recordkeeping 0 0 0 0 0 0 0 0 0 $0
Subtotal for Recordkeeping Requirements
294 $25,514
TOTAL LABOR BURDEN AND COST (rounded)




$31,900
Capital and O&M Cost (see Section 6(b)(iii)):




$0
TOTAL COST 48



$31,900











Assumptions:









a It is assumed that there are sixteen sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.









b This ICR uses the following labor rates: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 337000 - Furniture and Related Product Manufacturing." 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 It is assumed that each respondent will take 4 hours to read the rule and instructions.









d The final RTR amendments do not impact this item. The current ICR assumes each respondent will take ten hours, once per year to plan activities and train staff.









e No training hours are expected due to the final rule revisions.
f Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the facility to obtain the testing contractor, plan and attend the test, review the test report, and load it to ERT. There were no Surface Coating of Metal Furniture facilities (subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs.
g It is assumed that 5 percent of respondents will have to repeat performance tests.









h The current ICR assumes each respondent will take twelve hours, twelve times per year to complete task. Labor totals include hours for the facility to coordinate with suppliers, and gather information on monitoring and emissions. The final RTR amendments do not impact this item.
i The final RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours twelve times per year to complete task.









j The final RTR amendments do not impact this item. The current ICR assumes that each respondent will take eight hours twice per year to complete reports.









k The current ICR assumes each respondent will take one hour two times per week to record and disclose information. EPA is requiring sources to electronically submit semiannual reports starting 2 years after the effective date of the final rule. It is assumed that this will not increase labor.
l We are eliminating the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
j The final RTR amendments do not impact this item. The current ICR assumes that each respondent will take half an hour annually to store and file reports.










Sheet 5: TBL2-YR2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP
Year 2 (Amendments)
Burden item (A) (B) (C) (D) (E) (F) (G) (H) (I) (J)
Person hours per occurrence No. of occurrences per respondent per year Person hours per respondent per year (C=AxB) Respondents per year a Total Number of Responses per Year
(E=BXD)
Technical person- hours per year
(F=CxD)
Management person hours per year (G=Fx0.05) Clerical person hours per year (H=Fx0.1) Total Hours per Year
(I=F+G+H)
Total Cost Per year b
1 Familiarization with rule requirements c 4 1 4 0 0 0 0 0 0 $0
2 Plan activities 0 0 0 0 0 0 0 0 0 $0
3 Training d 8 1 0 0 0 0 0 0 0 $0
Due To Final Revisions e 8 1 8 0 0 0 0 0 0 $0
4 Add-on control performance test f 16 0 0 0 0 0 0 0 0 $0
Repeat performance test g








$0
5 Gather info, monitor, inspect, and determine complaince h 12 12 144 0 0 0 0 0 0 $0
6 Process/compile and review i 8 12 96 0 0 0 0 0 0 $0
7 Complete notifications and reports j 8 2 16 0 0 0 0 0 0 $0
Subtotal for Reporting Requirements 0 $0
8 Record/transmit/disclose k 2 52 0 0 0 0 0 0 0 $0
Due To Final Revisions l 8 2 16 0 0 0 0 0 0 $0
9 Store/file m 0.25 2 0 0 0 0 0 0 0 $0
10 Reporting and recordkeeping 0 0 0 0 0 0 0 0 0 $0
Subtotal for Recordkeeping Requirements
0 $0
TOTAL LABOR BURDEN AND COST (rounded)




$0
Capital and O&M Cost (see Section 6(b)(iii)):




$0
TOTAL COST 0



$0











Assumptions:









a It is assumed that there are sixteen sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.









b This ICR uses the following labor rates: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 337000 - Furniture and Related Product Manufacturing." 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 It is assumed that each respondent will take 4 hours to read the rule and instructions.









d The final RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff.









e No training hours are expected due to the final rule revisions.
f Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the facility to obtain the testing contractor, plan and attend the test, review the test report, and load it to ERT. There were no Surface Coating of Metal Furniture facilities (subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs.
g It is assumed that 5 percent of respondents will have to repeat performance tests.









h The current ICR assumes each respondent will take twelve hours, twelve times per year to complete task. Labor totals include hours for the facility to coordinate with suppliers, and gather information on monitoring and emissions. The final RTR amendments do not impact this item.
i The final RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours twelve times per year to complete task.









j The final RTR amendments do not impact this item. The current ICR assumes that each respondent will take eight hours twice per year to complete reports.









k The current ICR assumes each respondent will take one hour two times per week to record and disclose information. EPA is requiring sources to electronically submit semiannual reports starting 2 years after the effective date of the final rule. It is assumed that this will not increase labor.
l We are eliminating the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
j The final RTR amendments do not impact this item. The current ICR assumes that each respondent will take half an hour annually to store and file reports.










Sheet 6: TBL3-YR3

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP
Year 3 (Amendments)
Burden item (A) (B) (C) (D) (E) (F) (G) (H) (I) (J)
Person hours per occurrence No. of occurrences per respondent per year Person hours per respondent per year (C=AxB) Respondents per year a Total Number of Responses per Year
(E=BXD)
Technical person- hours per year
(F=CxD)
Management person hours per year (G=Fx0.05) Clerical person hours per year (H=Fx0.1) Total Hours per Year
(I=F+G+H)
Total Cost Per year b
1 Familiarization with rule requirements c 4 1 4 0 0 0 0 0 0 $0
2 Plan activities 0 0 0 0 0 0 0 0 0 $0
3 Training d 8 1 0 0 0 0 0 0 0 $0
Due To Final Revisions e 8 1 8 0 0 0 0 0 0 $0
4 Add-on control performance test f 16 0 0 0 0 0 0 0 0 $0
Repeat performance test g








$0
5 Gather info, monitor, inspect, and determine complaince h 12 12 144 0 0 0 0 0 0 $0
6 Process/compile and review i 8 12 96 0 0 0 0 0 0 $0
7 Complete notifications and reports j 8 2 16 0 0 0 0 0 0 $0
Subtotal for Reporting Requirements 0 $0
8 Record/transmit/disclose k 2 52 0 0 0 0 0 0 0 $0
Due To Final Revisions l 8 2 16 0 0 0 0 0 0 $0
9 Store/file m 0.25 2 0 0 0 0 0 0 0 $0
10 Reporting and recordkeeping 0 0 0 0 0 0 0 0 0 $0
Subtotal for Recordkeeping Requirements
0 $0
TOTAL LABOR BURDEN AND COST (rounded)




$0
Capital and O&M Cost (see Section 6(b)(iii)):




$0
TOTAL COST 0



$0











Assumptions:









a It is assumed that there are sixteen sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.









b This ICR uses the following labor rates: $111.03 per hour for Executive, Administrative, and Managerial labor; $90.34 per hour for Technical labor, and $37.72 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 337000 - Furniture and Related Product Manufacturing." 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 It is assumed that each respondent will take 4 hours to read the rule and instructions.









d The final RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff.









e No training hours are expected due to the final rule revisions.
f Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the facility to obtain the testing contractor, plan and attend the test, review the test report, and load it to ERT. There were no Surface Coating of Metal Furniture facilities (subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs.
g It is assumed that 5 percent of respondents will have to repeat performance tests.









h The current ICR assumes each respondent will take twelve hours, twelve times per year to complete task. Labor totals include hours for the facility to coordinate with suppliers, and gather information on monitoring and emissions. The final RTR amendments do not impact this item.
i The final RTR amendments do not impact this item. The current ICR assumes each respondent will take eight hours twelve times per year to complete task.









j The final RTR amendments do not impact this item. The current ICR assumes that each respondent will take eight hours twice per year to complete reports.









k The current ICR assumes each respondent will take one hour two times per week to record and disclose information. EPA is requiring sources to electronically submit semiannual reports starting 2 years after the effective date of the final rule. It is assumed that this will not increase labor.
l We are eliminating the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
j The final RTR amendments do not impact this item. The current ICR assumes that each respondent will take half an hour annually to store and file reports.










Sheet 7: TBL4-SUMMARY

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP (Amendments)
Year Technical Hours Clerical Hours Management Hours Total Labor Hours Labor Costs Non-Labor (Capital/Startup and O&M) Costs Total Costs
1 320 32 16 368 $31,900 $0 $31,900
2 0 0 0 0 $0 $0 $0
3 0 0 0 0 $0 $0 $0
Total 320 32 16 368 $31,900 $0 $31,900
Average 107 11 5.3 123 $11,000 $0 $11,000








Year Number of Respondents Number of Responses Reporting Hours Recordkeeping Hours Total Hours Hours per Response Hours Per Respondent
1 16 48 74 294 368 8.0 23
2 16 0 0 0 0 0 0
3 16 0 0 0 0 0 0
Total 48 48 74 294 368 8.0 23
Average 16 16 25 98 123 2.7 7.7
(a) = Average annual additional costs per respondant: $690







Sheet 8: TBL5-EPA-YR1

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP - Year 1 (Amendments)
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year (C=AxB) Plants per year a Technical person- hours per year (E=CxD) Management person-hours per year (F=Ex0.05) Clerical person-hours per year (G=Ex0.1) Cost, $ b
1 Initial performance test a, c 24 0 0 0 0 0 0 $0
2 Repeat performance test d 24 0 0 0 0 0 0 $0
3 Report review






$0
a) Initial notification e 4 1 4 0 0 0 0 $0
b) Performance test report f 8 1 8 0 0 0 0 $0
c) Notification of compliance status g 8 1 0 0 0 0 0 $0
d) Semiannual reports h 12 2 0 0 0 0 0 $0
Due To Final Revisions i 2 2 4 16 64 3.2 6.4 $3,451
TOTAL ANNUAL BURDEN AND COST (rounded) 74 $3,500









Assumptions:







a It is assumed that there are nine sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). 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 The final RTR amendments do not impact this item. The current ICR assumes it will take 24 hours to complete the task for each respondent.







d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the agency to travel to and from the facility to attend the test.
There are no Surface Coating of Metal Furniture facilities (subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs. Therefore, the final periodic testing would not add any new testing burden.
e It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.







f It is assumed that it will take eight hours to review the test report for each respondent.







g The final RTR amendments do not impact this item. The current ICR assumes that it will take eight hours, once a year to review the complaince stats for each respondent.







h The final RTR amendments do not impact this item. The current ICR assumes that it will take twelve hours to review the test reports, twice a year for each respondent.







i EPA is finalizing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for evaluating new SSM record systems in year one.

Sheet 9: TBL6-EPA-YR2

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP - Year 2 (Amendments)
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year (C=AxB) Plants per year a Technical person- hours per year (E=CxD) Management person-hours per year (F=Ex0.05) Clerical person-hours per year (G=Ex0.1) Cost, $ b
1 Initial performance test a, c 24 0 0 0 0 0 0 $0
2 Repeat performance test d 24 0 0 0 0 0 0 $0
3 Report review






$0
a) Initial notification e 4 1 4 0 0 0 0 $0
b) Performance test report f 8 1 8 0 0 0 0 $0
c) Notification of compliance status g 8 1 0 0 0 0 0 $0
d) Semiannual reports h 12 2 0 0 0 0 0 $0
Due To Final Revisions i 2 2 4 0 0 0 0 $0
TOTAL ANNUAL BURDEN AND COST (rounded) 0 $0









Assumptions:







a It is assumed that there are nine sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). 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 The final RTR amendments do not impact this item. The current ICR assumes it will take 24 hours to complete the task for each respondent.







d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the agency to travel to and from the facility to attend the test.
There are no Surface Coating of Metal Furniture facilities (subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs. Therefore, the final periodic testing would not add any new testing burden.
e It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.







f It is assumed that it will take eight hours to review the test report for each respondent.







g The final RTR amendments do not impact this item. The current ICR assumes that it will take eight hours, once a year to review the complaince stats for each respondent.







h The final RTR amendments do not impact this item. The current ICR assumes that it will take twelve hours to review the test reports, twice a year for each respondent.







i EPA is finalizing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for evaluating new SSM record systems in year one.

Sheet 10: TBL7-EPA-YR3

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP - Year 3 (Amendments)
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year (C=AxB) Plants per year a Technical person- hours per year (E=CxD) Management person-hours per year (F=Ex0.05) Clerical person-hours per year (G=Ex0.1) Cost, $ b
1 Initial performance test a, c 24 0 0 0 0 0 0 $0
2 Repeat performance test d 24 0 0 0 0 0 0 $0
3 Report review






$0
a) Initial notification e 4 1 4 0 0 0 0 $0
b) Performance test report f 8 1 8 0 0 0 0 $0
c) Notification of compliance status g 8 1 0 0 0 0 0 $0
d) Semiannual reports h 12 2 0 0 0 0 0 $0
Due To Final Revisions i 2 2 4 0 0 0 0 $0
TOTAL ANNUAL BURDEN AND COST (rounded) 0 $0









Assumptions:







a It is assumed that there are nine sources that are subject to the standard, and no additional new sources will become subject to the rule over the next three years.
b This cost is based on the following labor rates: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (GS-6, Step3, $16.26 + 60%). 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 The final RTR amendments do not impact this item. The current ICR assumes it will take 24 hours to complete the task for each respondent.







d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the agency to travel to and from the facility to attend the test.
There are no Surface Coating of Metal Furniture facilities (subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs. Therefore, the final periodic testing would not add any new testing burden.
e It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.







f It is assumed that it will take eight hours to review the test report for each respondent.







g The final RTR amendments do not impact this item. The current ICR assumes that it will take eight hours, once a year to review the complaince stats for each respondent.







h The final RTR amendments do not impact this item. The current ICR assumes that it will take twelve hours to review the test reports, twice a year for each respondent.







i EPA is finalizing the elimination of the startup, shutdown, and malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for evaluating new SSM record systems in year one.

Sheet 11: TBL8-EPA SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Surface Coating of Metal Furniture NESHAP (Amendments)
Year Technical Hours Management Hours Clerical Hours Total Hours Labor Costs Non-Labor Costs Total Costs
1 64 3.2 6.4 74 $3,500 $0 $3,500
2 0 0 0 0 $0 $0 $0
3 0 0 0 0 $0 $0 $0
Total 64 3.2 6.4 74 $3,500 $0 $3,500
Average 21 1.1 2.1 25 $1,200 $0 $1,200








Year Number of Responses Total Hours




1 16 74




2 0 0




3 0 0




Total 16 74




Average 5.3 25 (a)











(a) = Average annual additional hours per respondant: 4.6






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