Burden Calculation Tables

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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

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Sheet 1: Cover

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
National Emission Standards for Hazardous Air Pollutants for Printing, Coating, and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (Amendments)
ATTACHMENT 1
	TABLES 1, 2, 3, and 4
Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP – Years 1-3 (Amendments)
Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP (Amendments)
ATTACHMENT 2
	TABLES 5, 6, 7, and 8
Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP - Year 1-3 (Amendments)
Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP (Amendments)

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Sheet 2: Inputs

Respondent Wages ($2016)
Category (1)	Hourly Mean Wage (2)	Loaded Wage (3)
Technical	$45.14	$94.79
Clerical	$18.11	$38.03
Managerial	$57.25	$120.23
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 313000 - Textile Mills," found here:
https://www.bls.gov/oes/current/naics3_313000.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.

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Sheet 3: Current ICR

Table 1: Annual Respondent Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)				72	coating and printing facilities
1. Applications	N/A										74	slashing, dyeing, and finishing facilities
2. Survey and Studies	N/A										146	Total
3. Reporting Requirements
A. Familiarization with rule requirement	4	1	4	146	584	29.2	58.4	$61,091
B. Required activities
Initial oxidizer performance test c, e	280	1	280	1	280	14	28	$29,290
Repeat oxidizer performance test c, e, f	280	1	280	0.2	56	2.8	5.6	$5,858
Initial capture performance test c, e	215	1	215	1	215	10.75	21.5	$22,491
Repeat capture performance test c, e, f	215	1	215	0.2	43	2.15	4.3	$4,498
Startup, shutdown, malfunction plan c	40	1	40	1	40	2	4	$4,184
Solvent recovery system compliance determination c, p	4	12	48	14.4	691.2	34.56	69.12	$72,305
Emission rate limit compliance determination	4	12	48	146	7,008	350.4	700.8	$733,095
Coordination with suppliers g	40	1	40	146	5,840	292	584	$610,913
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report
Initial notification c	2	1	2	1	2	0.1	0.2	$209
Notification of construction/reconstruction c	2	1	2	1	2	0.1	0.2	$209
Notification of anticipated startup c	2	1	2	1	2	0.1	0.2	$209
Notification of actual startup c	2	1	2	1	2	0.1	0.2	$209
Notification of compliance status c	4	1	4	1	4	0.2	0.4	$418
Notification of performance test c, e	2	1	2	1	2	0.1	0.2	$209
Performance test report c, e	40	1	40	1	40	2	4	$4,184
Report of monitoring exceedances c, h, k	16	2	32	7.2	230.4	11.52	23.04	$24,102
Report of no excess emissions c, i, k	8	2	16	64.8	1,037	51.84	103.68	$108,458
Startup, shutdown, malfunction report c, j, k	8	2	16	7.2	115.2	5.76	11.52	$12,051
Report of compliance deviation d, k, l	16	2	32	7.4	236.8	11.84	23.68	$24,771
Report of no compliance deviations d, k, m	8	2	16	66.6	1,066	53.28	106.56	$111,471
Subtotal for Reporting Requirements					20,120			$1,830,228
4. Recordkeeping Requirements
A. Familiarization with rule requirement	See 4B
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards n	0.25	52	13	146	1,898	94.9	189.8	$198,547
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information o	0.25	2	0.5	146	73	3.65	7.3	$7,636
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,267			$206,183
TOTAL LABOR BURDEN AND COST q					22,400			$2,040,000
Capital and O&M Cost (see Section 6(b)(iii)): q								$6,750
TOTAL COST: q								$2,050,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 146, which equates to 69 coating and printing sources, and 74 slashing, dyeing, and finishing sources. There will
be one additional new source per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $120.22 per hour for Executive, Administrative, and Managerial labor; $94.79 per hour for Technical labor, and $38.03 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 313000 - Textile Mills." 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 This applies only to coating and printing facilities.
d This applies only to slashing, dyeing and finishing facilities.
e Occurs one time for new sources and involves one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support
recordkeeping and reporting.
f It is assumed that 20 percent of respondents will have to repeat performance tests.
g We have assumed that it will take 40 hours for each respondent to coordinate with suppliers.
h We have assumed that 10 percent of respondents will report monitoring exceedances.
i We have assumed that 90 percent of respondents will report no excess emissions.
j We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction reports.
k Semiannual reports are required.
l It is assumed that 10 percent of respondents will report compliance deviations.
m It is assumed that 90 percent of respondents will report no compliance deviations.
n It is assumed that all of the respondents will be required to record information on a weekly basis.
o It is assumed that respondents will be required to transmit/disclose information on a semiannual basis.
p It is assumed that 20 percent of the coating and printing facilities will use solvent recovery equipment.
q 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 Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (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	Plants per year a	Technical person-hours per year	Management person-hours per year	Clerical person- hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)				72	coating and printing facilities
1. Initial performance test c	495	1	495	1	495	24.75	49.5	$26,691			74	slashing, dyeing, and finishing facilities
2. Repeat performance test preparations c, e	4	0.1	0.4	1	0.4	0.02	0.04	$22			146	Total
3. Repeat performance test c, e	495	0.1	49.5	1	49.5	2.475	4.95	$2,669
4. Report Review
Notification of applicability	2	1	2	1	2	0.1	0.2	$108
Notification of construction/ reconstruction	2	1	2	1	2	0.1	0.2	$108
Notification of anticipated startup	2	1	2	1	2	0.1	0.2	$108
Notification of actual startup	2	1	2	1	2	0.1	0.2	$108
Notification of initial performance test c	2	1	2	1	2	0.1	0.2	$108
Notification of compliance status c	2	1	2	1	2	0.1	0.2	$108
Review of initial performance test report c	8	1	8	1	8	0.4	0.8	$431
Review of repeat performance test report c, f	8	0.1	0.8	1	0.8	0.04	0.08	$43
Review of excess emissions report c, g	8	1	8	7.2	57.6	2.88	5.76	$3,106
Review of no excess emissions report c, h	2	1	2	64.8	129.6	6.48	12.96	$6,988
Review of startup, shutdown, malfunction reports c, i	2	1	2	7.2	14.4	0.72	1.44	$776
Review of compliance deviations report d, j	8	1	8	7.4	59.2	2.96	5.92	$3,192
Review of no compliance deviations reports d, k	2	1	2	66.6	133.2	6.66	13.32	$7,182
TOTAL ANNUAL BURDEN AND COST l					1,100			$51,700
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 145, which equates to 70 coating and printing sources, and 75
slashing, dyeing, and finishing sources. There will be one additional new source per year 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 which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.90 (GS-13, Step 5, $39.31 x 1.6), Technical rate
of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.
c This applies only to coating and printing facilities.
d This applies only to slashing, dyeing and finishing facilities.
e We have assumed that 10 percent of new sources will have to repeat performance test preparations and testing.
f Assume that 10 percent of new sources will review the repeat performance test report.
g We have assumed that 10 percent of respondents will be engaged in the reviewing of excess emissions reports.
h We have assumed that 90 percent of respondents will be engaged in the reviewing of no excess emissions reports.
i We have assumed that 10 percent of respondents will have to review the startup, shutdown, malfunction reports.
j We have assumed that 10 percent of respondents will review the compliance deviations report.
k We have assumed that 90 percent of respondents will review the no compliance deviations report.
l Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 4: TBL1-YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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	43	43	172	8.6	17.2	197.8	$17,993
2 Plan activities	0	0	0	0	0	0	0	0	0	$0
3 Training d	8	1	8	0	0	0	0	0	0	$0
Due To Final Revisions e	0	0	0	0	0	0	0	0	0	$0
4 Add-on control performance test f	30	1	30	0	0	0	0	0	0	$0
Repeat performance test g	30	1	30	0	0	0	0	0	0	$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						198				$17,993
8 Record/transmit/disclose k	2	52	104	0	0	0	0	0	0	$0
Due To Final Revisions l	8	2	16	43	86	688	34.4	68.8	791.2	$71,971
9 Store/file m	0.25	2	0.5	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						791				$71,971
TOTAL LABOR BURDEN AND COST (rounded)										$90,000
Capital and O&M Cost (see Section 6(b)(iii)):										$0
TOTAL COST					129					$90,000
Assumptions:
a It is assumed that there are fourty two 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: $120.22 per hour for Executive, Administrative, and Managerial labor; $94.79 per hour for Technical labor, and $38.03 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 313000 - Textile Mills." 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 current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff. The final RTR amendments do not impact this item.
e EPA did not identify any add-on control technologies, other equipment or work practices and procedures that had not previously been considered during development of the NESHAP, nor did we identify any developments since the promulgation of the NESHAP. Therefore, no additional training is required.
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. Eighteen process lines have add-on controls and would require testing in year 3 due to the final revisions. The 18 does not include other lines also with add-on controls that are already required to periodically test because of state operating permit conditions.
g It is assumed that 20 percent of respondents will have to repeat performance tests.
h The final RTR amendments do not impact this item. 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.
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 current ICR assumes that each respondent will take eight hours twice per year to complete reports. The final RTR amendments do not impact this item.
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.
m 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.

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Sheet 5: TBL2-YR2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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	8	0	0	0	0	0	0	$0
Due To Final Revisions e	0	0	0	0	0	0	0	0	0	$0
4 Add-on control performance test f	30	1	30	0	0	0	0	0	0	$0
Repeat performance test g	30	1	30	0	0	0	0	0	0	$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	104	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	0.5	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 fourty two 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: $120.22 per hour for Executive, Administrative, and Managerial labor; $94.79 per hour for Technical labor, and $38.03 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 313000 - Textile Mills." 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 current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff. The final RTR amendments do not impact this item.
e EPA did not identify any add-on control technologies, other equipment or work practices and procedures that had not previously been considered during development of the NESHAP, nor did we identify any developments since the promulgation of the NESHAP. Therefore, no additional training is required.
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. Eighteen process lines have add-on controls and would require testing in year 3 due to the final revisions. The 18 does not include other lines also with add-on controls that are already required to periodically test because of state operating permit conditions.
g It is assumed that 20 percent of respondents will have to repeat performance tests.
h The final RTR amendments do not impact this item. 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.
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 current ICR assumes that each respondent will take eight hours twice per year to complete reports. The final RTR amendments do not impact this item.
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.
m 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.

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Sheet 6: TBL3-YR3

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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	8	0	0	0	0	0	0	$0
Due To Final Revisions e	0	0	0	0	0	0	0	0	0	$0
4 Add-on control performance test f	30	1	30	18	18	540	27	54	621	$56,489
Repeat performance test g	30	1	30	1	1	30	1.5	3	34.5	$3,138
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						656				$59,627
8 Record/transmit/disclose k	2	52	104	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	0.5	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)										$60,000
Capital and O&M Cost (see Section 6(b)(iii)):										$332,000
TOTAL COST					19					$392,000
Assumptions:
a It is assumed that there are fourty two 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: $120.22 per hour for Executive, Administrative, and Managerial labor; $94.79 per hour for Technical labor, and $38.03 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 313000 - Textile Mills." 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 current ICR assumes each respondent will take eight hours, once per year to plan activities and train staff. The final RTR amendments do not impact this item.
e EPA did not identify any add-on control technologies, other equipment or work practices and procedures that had not previously been considered during development of the NESHAP, nor did we identify any developments since the promulgation of the NESHAP. Therefore, no additional training is required.
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. Eighteen process lines have add-on controls and would require testing in year 3 due to the final revisions. The 18 does not include other lines also with add-on controls that are already required to periodically test because of state operating permit conditions.
g It is assumed that 20 percent of respondents will have to repeat performance tests.
h The final RTR amendments do not impact this item. 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.
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 current ICR assumes that each respondent will take eight hours twice per year to complete reports. The final RTR amendments do not impact this item.
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.
m 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.

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Sheet 7: TBL4-SUMMARY

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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	860	86	43	989	$90,000	$0	$90,000
2	0	0	0	0	$0	$0	$0
3	570	57	29	656	$60,000	$332,000	$392,000
Total	1,430	143	72	1,645	$150,000	$332,000	$482,000
Average	477	48	24	548	$50,000	$110,000	$160,000
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	43	129	198	791	989	7.7	23.0
2	43	0	0	0	0	0	0
3	43	19	656	0	656	34.5	15.2
Total	43	148	853	791	1,645	42.2	38.2
Average	43	49	284	264	548	14.1	12.7
(a) = Average annual per respondant cost: $3700

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Sheet 8: TBL5-EPA-YR1

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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 Add-on control performance test a, c, d	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	10	1	10	0	0	0	0	$0
b) Performance test report f	20	1	20	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	1	2	43	86	4.3	8.6	$4,637
TOTAL ANNUAL BURDEN AND COST (rounded)					99			$4,640
Assumptions:
a It is assumed that there are fourty two 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. Eighteen process lines have add-on controls and would require testing due to the final revisions. It is assumed that 5 percent of respondents will have to repeat performance tests.
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 eliminating 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.

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Sheet 9: TBL6-EPA-YR2

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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 Add-on control performance test a, c, d	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	10	1	10	0	0	0	0	$0
b) Performance test report f	20	1	20	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 fourty two 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. Eighteen process lines have add-on controls and would require testing due to the final revisions. It is assumed that 5 percent of respondents will have to repeat performance tests.
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 eliminating 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.

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Sheet 10: TBL7-EPA-YR3

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles 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 Add-on control performance test a, c, d	24	1	24	18	432	21.6	43.2	$23,294
2 Repeat performance test d	24	1	24	1	24	1.2	2.4	$1,294
3 Report review								$0
a) Initial notification e	10	1	4	19	76	3.8	7.6	$4,098
b) Performance test report f	20	1	8	19	152	7.6	15.2	$8,196
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)					787			$36,900
Assumptions:
a It is assumed that there are fourty two 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. Eighteen process lines have add-on controls and would require testing due to the final revisions. It is assumed that 5 percent of respondents will have to repeat performance tests.
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 eliminating 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.

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Sheet 11: TBL8-EPA SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	86	4	9	99	$4,640	$0	$4,640
2	0	0	0	0	$0	$0	$0
3	684	34	68	787	$36,900	$0	$36,900
Total	770	39	77	886	$41,540	$0	$41,540
Average	257	13	26	295	$14,000	$0	$14,000
Year	Number of Responses	Total Hours
1	43	99
2	0	0
3	57	787
Total	100	886
Average	33	295	(a)
(a) = Average annual hours per respondant: 8.9