| Table 1: Annual Respondent Burden and Cost - NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal) |
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Respondant Rates
(Source: United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.”) |
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$112.98 |
$149.35 |
$54.81 |
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| Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Person‑Hours per occurrence |
Number of occurrences per year |
Person‑Hours per respondent per year
(C=A*B) |
Respondents per year a |
Technical person‑hours per year (E=C*D) |
Management person‑hours per year
(F=E*0.05) |
Clerical person‑hours per year (G=E*0.1) |
Annual costs ($) b |
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Labor Type |
Total Compensation ($/hr) |
Loaded Rate (Rate + 110%rate) |
| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting requirements |
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| A. Familiarization with regulatory requirements c |
4 |
1 |
4 |
10 |
40 |
2 |
4 |
$5,037.14 |
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Mgmt. |
$71.12 |
$149.35 |
| B. Plan activities d |
8 |
1 |
8 |
10 |
80 |
4 |
8 |
$10,074.29 |
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Tech. |
$53.80 |
$112.98 |
| C. Training d |
8 |
1 |
8 |
10 |
80 |
4 |
8 |
$10,074.29 |
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Cler. |
$26.10 |
$54.81 |
| D. Gather information, monitor, and inspect e |
12 |
12 |
144 |
10 |
1440 |
72 |
144 |
$181,337.18 |
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| E. Process/compile and review f |
8 |
12 |
96 |
10 |
960 |
48 |
96 |
$120,891.46 |
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Tracy Curtis:
Items F. and G. were not included in the prior ICR renewal and have been added as a requirement. While a small burden increase on its own, the overall burden is decreased due to the changes in the number of respondents
F. Complete excess emission report g |
8 |
1 |
8 |
5 |
40 |
2 |
4 |
$5,037.14 |
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| G. Complete startup, shutdown, malfunction report g |
8 |
1 |
8 |
5 |
40 |
2 |
4 |
$5,037.14 |
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Hours per Response |
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| H. Complete semiannual report h |
8 |
2 |
16 |
10 |
160 |
8 |
16 |
$20,148.58 |
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3870 |
# hours |
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| Subtotal for Reporting Requirements |
3,266 |
$357,637 |
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30 |
# responses |
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| 4. Recordkeeping requirements |
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129 |
hr/resp |
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| A. Familiarization with regulatory requirements |
See 3A |
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| B. Plan activities |
See 3B |
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| C. Implement activities |
See 3B |
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| D. Develop record system |
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| Record/disclose i |
1 |
52 |
52 |
10 |
520 |
26 |
52 |
$65,482.87 |
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| Store/file |
0.25 |
2 |
0.5 |
10 |
5 |
0.25 |
0.5 |
$629.64 |
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| E. Time to enter information |
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| F. Audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
604 |
$66,113 |
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| TOTAL LABOR BURDEN AND COSTS (rounded) j |
3,870 |
$424,000 |
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| TOTAL CAPITAL AND O&M COST (rounded): j |
$5,400 |
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| GRAND TOTAL (rounded): j |
$429,000 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be 10. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR. |
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| b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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. |
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| c We have assumed that it will take 4 hours for existing respondents to refamiliarize themselves with rule requirements. |
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| d We have assumed that it will take eight hours for each respondent to plan activities and eight hours for training. |
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| e We have assumed that each respondent will take twelve hours twelve times per year to complete task. |
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| f We have assumed that each respondent will take eight hours twelve times per year to complete task. |
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| g We have assumed that 50% of respondents will have to submit an excess emission report and 50% of respondents will have to submit an SSM report . |
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| h We have assumed that each respondent will take eight hours twice per year to complete reports. |
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| i We have assumed that each respondent will take one hour two times per week to record and disclose information. |
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| j Totals have been rounded to three significant digits. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost - NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal) |
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Agency Rates
Source: Office of Personnel Management (OPM), 2017 General Schedule |
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$48.08 |
$64.80 |
$26.02 |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Person‑hours per activity |
Number of occurences per year |
Person hours per respondent per year
(C = A*B) |
Respondents per yeara |
Technical person‑hours per year
(E=C*D) |
Management person‑hours per year
(F=E*0.05) |
Clerical person‑hours per year
(G=E*0.1) |
Annual
Costs ($/yr) b |
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Hourly Mean Wage |
With Fringe & Overhead |
| Required activities |
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| Initial performance test c |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
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(GS- 12, step 1) - Tech. |
30.05 |
$48.08 |
| Repeat performance test d |
24 |
0.2 |
4.8 |
0 |
0 |
0 |
0 |
$0 |
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(GS- 13, step 5) - Mgmt. |
40.5 |
$64.80 |
| Report review |
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(GS-6, step 3) - Cler. |
16.26 |
$26.02 |
| a) Initial notification e |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| b) Notification of performance test e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| c) Notification of compliance status e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| d) Semiannual reports f |
12 |
2 |
24 |
10 |
240 |
12 |
24 |
$12,941.18 |
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| TOTAL ANNUAL BURDEN AND COST (rounded) g |
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276 |
$12,900 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be 10. There will be no additional sources that will become subject to the rule over the three-year period of this ICR |
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| 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. |
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| c We have assumed that it will take 24 hours to complete the task for each respondent. |
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| d We have assumed that tests will fail 20% of the time and that it will take 24 hours to complete the task. |
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| e Based on Agency experience, we assume that it will take four hours to review the notification of the test and the test plan for each respondent. |
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| f We have assumed that it will take 12 hours to complete the task for each respondent. |
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| g Totals have been rounded to three significant digits. Figures may not add exactly due to rounding. |
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