Burden Calculations Table

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Overview

Table 1
Table 2

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Sheet 1: Table 1

TABLE 1: Annual Respondent Burden and Cost - NSPS for the Surface Coating of Plastic Parts for Business Machines
			(40 CFR part 60, subpart TTT)
	REPORTING/RECORDKEEPING REQUIREMENT			(A) Respondent Hours per Occurrence (Technical hours)	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (A x B)	(D) Number of Respondents per Yeara	(E) Technical Hours per Year (C x D)	(F) Management Hours per Year (E x 0.05)	(G) Clerical Hours per Year (E x 0.1)	Total Labor Costs per Yearb
1.	APPLICATIONS			N/A
2.	SURVEY AND STUDIES			N/A
3.	REPORTING REQUIREMENTS
	a.	Familiarization with regulatory requirements c		0.87	1	0.87	10	8.70	0.44	0.87	$1,139.63			Manager	$147.40
	b.	Required Activities												Technical	$117.92
			Initial Performance Testsd	2.61	1	2.61	0	0	0	0	$0			Clerical	$57.02
			Demonstration of CMS	N/A										Hours per response	35
			Repeat of Performance Testse	2.61	0.2	0.52	0	0	0	0	$0
			Method 24 Testingf,g	78.26	4	313.04	0.01	3.13	0.16	0.31	$410.06			Number of Responses	28
	c.	Create Information		See 3b
	d.	Gather Existing Information		See 3e
	e.	Write Report
			Notification of Construction/Reconstructionh	1.74	1	1.74	0	0	0	0	$0
			Notification of Actual Startuph	1.74	1	1.74	0	0	0	0	$0
			Notification of Initial Performance Testh	1.74	1	1.74	0	0	0	0	$0
			Report of Performance Test	5.22	1	5.22	0	0	0	0	$0
			Quarterly Report of Noncompliancei	13.91	4	55.64	2	111.28	5.56	11.13	$14,576.79
			Semiannual Report of Compliancej	0.43	2	0.86	10	8.60	0.43	0.86	$1,126.53
	Subtotal for Reporting Requirements							151			$17,253
4.	RECORDKEEPING REQUIREMENTS
	a.	Read Instructions		See 3a
	b.	Plan Activities		See 3b
	c.	Implement Activities		See 3b
	d.	Develop Record System		0.87	1	0.87	0	0	0	0	$0
	e.	Time to Enter Information
			Record of monthly performance testsa,k	6.09	12	73.08	10	730.80	36.54	73.08	$95,728.95
	f.	Train Personnel		N/A
	g.	Audits		N/A
	Subtotal for Recordkeeping Requirements							840			$95,729
Total Labor Burden and Costs (rounded)l								992			$113,000
Total Capital and O&M Costs (rounded)l											$0
Grand Total (rounded)l											$113,000
Assumptions
a We have assumed that the average number of sources that will be subject to the standard will be 10. There will be no additional new sources 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: $147.40 (Managerial), $117.92 (Technical), and $57.02 (Clerical). 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", 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 it will take 1 hour for existing respondents to refamiliarize themselves with rule requirements.
d We have assumed that it will take each respondent 2.61 hours once per year to complete the initial performance tests.
e We have assumed that 20 percent of respondents will have to repeat performance tests due to failure.
f We have assumed that it will take 78.26 hours to perform Method 24 testing. This testing is performed on the coatings used by the respondents and is generally done by the coating manufacturers, who will then provide the test result to the respondents.
g We have assumed that 0.1 percent of respondents must generate Method 24 test data for coating usage four times per year due to modification.
h We have assumed that it will take 1.74 hours once per year to complete notification reports.
i We have assumed that 20 percent of respondents (0.20*10=2 facilities) will exceed the emission standard at least once in each quarterly reporting period; therefore, an average of two facilities will be required to write the quarterly excess emission report four times per year.We have assumed that it will take 13.91 hours to write each quarterly report of noncompliance.
j We have assumed that each respondent will take 0.43 hours two times per year to write the semiannual report of compliance.
k Hours required to record monthly performance tests are 6.09.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

TABLE 2: Annual Agency Burden and Cost - NSPS for the Surface Coating of Plastic Parts for Business Machines
		(40 CFR part 60, subpart TTT)
REPORTING/RECORDKEEPING REQUIREMENT			(A) EPA Hours per Occurrence (Technical hours)	(B) Number of Occurrences per Plant per Year	(C) EPA Hours per Year (A x B)	(D) Plants per Yeara	(E) Technical Hours per Year (C x D)	(F) Management Hours per Year (E x 0.05)	(G) Clerical Hours per Year (E x 0.1)	Costs per Yearb
Observe Initial Performance Testsc			2.61	1	2.61	0	0	0	0	$0
Observe Repeat of Initial Performance Testd			2.61	0.2	0.52	0	0	0	0	$0
Review Reports
		Notification of Constructione	1.74	1	1.74	0	0	0	0	$0			Manager	$65.71
		Notification of Initial Startupe	1.74	1	1.74	0	0	0	0	$0			Technical	$48.75
		Notification of Actual Startupe	1.74	1	1.74	0	0	0	0	$0			Clerical	$26.38
		Notification of Initial Teste	1.74	1	1.74	0	0	0	0	$0
		Review Test Resultse	1.74	1	1.74	0.01	0.017	0.001	0.002	$1
		Quarterly Reports of Noncompliancef	6.96	4	27.83	2	55.65	2.78	5.57	$3,042.70
		Semiannual Reports of Complianceg	0.43	2	0.87	10	8.70	0.43	0.87	$475.42
Total Annual Burden and Costs (rounded)h							74			$3,520
Assumptions
a We have assumed that the average number of sources that will be subject to the standard will be 10. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following average hourly labor rates: $65.71 Managerial (GS-13, Step 5%), $48.75 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. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that it will take 2.61 hours once per year to complete initial performance test.
d We have assumed that it will take 2.61 hours 0.2 times per year to repeat performance test.
e We have assumed that it will take 1.74 hours once per year to review notification and review test results.
f We have assumed that 20 percent of facilities will take 6.96 hours four times per year to report noncompliance.
g We have assumed that each facility will take 0.43 hours two times per year to report semiannual compliance.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.