Burden Calculation Tables

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Overview

Cover
Inputs
Current ICR
TBL1-ResY1
TBL2-ResY2
TBL3-ResY3
TBL4-ResSUM
TBL5-EPAY1
TBL6-EPAY2
TBL7-EPAY3
TBL8-EPA SUMMARY

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Sheet 1: Cover

ATTACHMENT 1

SUPPORTING STATEMENT

National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing (40 CFR Part 63, Subpart VVVV)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Boat Manufacturing NESHAP Residual Risk and Technology Review – Years 1-3

TABLE 4

Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Boat Manufacturing NESHAP Residual Risk and Technology Review

TABLES 5, 6, and 7

Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Boat Manufacturing NESHAP Residual Risk and Technology Review - Year 1-3

TABLE 8

Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Boat Manufacturing NESHAP Residual Risk and Technology Review

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Sheet 2: Inputs

Respondent Wages ($2016)
Category (1)	Hourly Mean Wage (2)	Loaded Wage (3)
Technical	$47.88	$100.55
Managerial	$59.33	$124.60
Clerical	$21.56	$45.28
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 336600 - Ship and Boat Building," found here:
https://www.bls.gov/oes/current/naics4_336600.htm
(2) Selected "mean hourly wage" in the table referenced in footnote 1. This value differs from the 2013 ICR amendments, which were based on 2015 wages. The wages used in the 2013 ICR amendments included: managerial $65.92 ($138.43 loaded wage), technical $50.69 ($106.45 loaded wage), and clerical $25.13 ($52.77 loaded wage).
(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 (2)	Wage With Fringe & Overhead (3)
(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 based on 2017 wages, and are found here:
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/17Tables/html/GS_h.aspx
(2) This value differs from the wages used in the 2013 ICR amendments, which were based on 2016 rates of pay
(3) 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: Annual Respondent Burden and Cost – Boat Manufacturing NESHAP (40 CFR Part 63, Subpart VVVV) (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)			2013 ICR Wages
1. Applications	N/A									Technical	$106.45
2. Surveys and studies	N/A									Managerial	$138.43
3. Familiarize with regulatory requirements c	25	1	25	144	3600	180	360	$427,135		Clerical	$52.77
4. Required activities for sources with add-on control devices d
a. Initial performance test and report	410	1	410	0	0	0	0	$0
b. Establish operating parameters	See 4A
c. Prepare startup, shutdown, and malfunction plan	40	1	40	0	0	0	0	$0
5. Required activities for sources using pollution prevention measures e, f
a. Develop recordkeeping system
1) Fiberglass manufacturing operations	22	1	22	0	0	0	0	$0
2) Adhesive operations	1	1	1	0	0	0	0	$0
3) Aluminum coating operations	6	1	6	0	0	0	0	$0
b. Enter information into recordkeeping system
1) Fiberglass manufacturing operations g	84	1	84	144	12096	604.8	1209.6	$1,435,172
2) Adhesive operations h	12	1	12	144	1728	86.4	172.8	$205,025
3) Aluminum coating operations i	22	1	22	16	352	17.6	35.2	$41,764
c. Work practice requirements j	2	12	24	16	384	19.2	38.4	$45,561
6. Create information	See 5B
7. Gather information	See 5B
8. Notification requirements
a. Initial notification that existing sources are subject to the standard k	24	1	24	0	0	0	0	$0
b. Notification for new major sources
1) Intent to construct and application for approval of construction	80	1	80	0	0	0	0	$0
2) Start of construction	2	1	2	0	0	0	0	$0
3) Anticipated startup date	2	1	2	0	0	0	0	$0
4) Actual startup date	2	1	2	0	0	0	0	$0
c. Request for compliance extension	N/A
d. Notification of special compliance requirements	N/A
e. Notification of performance tests	2	1	2	0	0	0	0	$0
f. Notification of compliance status	4	1	4	0	0	0	0	$0
9. Reporting requirements
a. Semiannual compliance reports for all sources l	8	2	16	144	2304	115.2	230.4	$273,366
b. Additional reports for sources with add-on control devices
1) Quarterly compliance report for sources with exceedances	16	4	64	0	0	0	0	$0
2) Request to return to semiannual compliance reporting m	8	1	8	1	8	0.4	0.8	$949
3) Control device performance test report	See 4A
4) Operating range for monitored parameters	See 4B
5) Startup, shutdown, malfunction	8	1	8	0	0	0	0	$0
Subtotal for Reporting Requirements					23,543			$2,428,972.09
10. Recordkeeping requirements
a. Familiarize with regulatory requirements	See 3
b. Plan and develop record system	See 5A
c. Record information	See 5B
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	N/A
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					0			$0
TOTAL LABOR BURDEN AND COST (rounded)n					23,500			$2,430,000
Capital and O&M Cost (see Section 6(b)(iii))								$800
GRAND TOTAL (rounded)n								$2,430,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 144 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $138.43 per hour for Executive, Administrative, and Managerial labor; $106.45 per hour for Technical labor, and $52.77 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “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 it will take the same length of time (25 hours) for both fiberglass and aluminum boat manufacturers to review the rules for each facility.
d We have assumed that sources with add-on control devices will be required to perform initial performance test and report, and to prepare startup, shutdown, and malfunction plan.
e We have assumed that all of the existing facilities except for one are complying with the regulations by using pollution prevention measures.
f We have assumed that there will be no new sources expected over the three-year period of this ICR.
g We have assumed that each of the respondents will take 84 hours to complete the fiberglass manufacturing operations.
h We have assumed that each respondent will take 12 hours to complete the adhesive operations requirements.
i We have assumed that 16 respondents will take 22 hours each to complete the aluminum coating operations requirements.
j We have assumed that 16 respondents will take 2 hours each to complete the work practice requirements.
k We have assumed that all of the existing respondents will each take 24 hours to complete initial notification requirements.
l We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
m We have assumed that one respondent will request to return to semiannual compliance reporting.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
Table: Average Annual EPA Burden and Cost – NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2013 ICR Wages
1. Read instructions	25	1	25	0	0	0	0	$0		Technical	$47.62
2. Enter and update information into agency recordkeeping system c	4	1	4	144	576	28.8	57.6	$30,760.70		Managerial	$64.16
3. Notification review										Clerical	$25.76
a. Review initial notification for existing sources d	2	1	2	0	0	0	0	$0
b. Notification for new major sources e
1. Review intent to construct and application to construct	12	1	12	0	0	0	0	$0
2. Start of construction	2	1	2	0	0	0	0	$0
3. Anticipated startup date	2	1	2	0	0	0	0	$0
4. Actual startup date	2	1	2	0	0	0	0	$0
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	20	1	20	0	0	0	0	$0
f. Review compliance status f	2	1	2	144	288	14.4	28.8	$15,380.35
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	144	1,152	57.6	115.2	$61,521.41
b. Reports for sources with add-on control devices								$0
1. Quarterly compliance report for source with exceedances h	4	4	16	0	0	0	0	$0
2. Request to return to semiannual compliance reporting i	4	2	8	1	8	0.4	0.8	$427.23
3. Review control device performance test report and operating range	20	1	20	1	20	1	2	$1,068.08
4. Review startup, shutdown, malfunction reports j	4	1	4	1	4	0.2	0.4	$213.62
TOTAL LABOR BURDEN AND COST (rounded)k					2,360			$109,400
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 144 existing sources. There will be no additional sources over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $64.16 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $47.62 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.76 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2012 General Schedule”, which excludes locality rates of pay.
c We have assumed that 144 respondents will each take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in the third year.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h we have assumed that 20 percent of the quarterly compliance reports will be reviewed for exceedances.
i We have assumed that two respondents will request to return to semiannual compliance reporting.
j We have assumed that it will take 4 hours to review the startup, shutdown, malfunction report.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 4: TBL1-ResY1

Table 1 : Annual Respondent Burden and Cost Year One – Boat Manufacturing NESHAP (40 CFR Part 63, Subpart VVVV) (2018 RTR)
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)			2013 ICR Wages
1. Applications	N/A									Technical	$106.45
2. Surveys and studies	N/A									Managerial	$138.43
3. Familiarize with regulatory requirements c	4	1	4	92	368	18.4	36.8	$43,663		Clerical	$52.77
4. Required activities for sources with add-on control devices d
a. Initial performance test and report h	N/A
b. Establish operating parameters h	N/A
c. Re-evaluating startup, shutdown, and amlfucntion requirements	4	1	4	92	368	18.4	36.8	$43,663
5. Required activities for sources using pollution prevention measures
a. Develop recordkeeping system h	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
c. Work practice requirements e	4	12	48	92	4416	220.8	441.6	$523,952
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					5,925			$611,277.07
8. Notification requirements
a. Initial notification that existing sources are subject to the standard h	N/A
b. Notification for new major sources h	N/A
c. Request for compliance extension h	N/A
d. Notification of special compliance requirements h	N/A
e. Notification of performance tests e	N/A
f. Notification of compliance status h	N/A
9. Reporting requirements
a. Semiannual compliance reports for all sources f	8	2	16	92	1472	73.6	147.2	$174,651
b. Additional reports for sources with add-on control devices e	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	4	1	4	92	368	18.4	36.8	$43,663
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	92	552	27.6	55.2	$65,494
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10.a.
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,751			$283,807
TOTAL LABOR BURDEN AND COST					8,676			$895,084
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)g								$895,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 93 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $124.59 per hour for Executive, Administrative, and Managerial labor; $100.55 per hour for Technical labor, and $45.28 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2016, “May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 336600 – Ship and Boat Building”. 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 it will take the same length of time (4 hours) for both fiberglass and aluminum boat manufacturers to review the final RTR rules for each facility.
d We have assumed that facilities will require some time to evaluate the effect of the rule removing the SSM exemption, and adjusting recordkeeping and reporting to accommodate these changes.
e We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
f We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
h We have assumed that no new facilities will become operational in the next three years.

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Sheet 5: TBL2-ResY2

Table 2 : Annual Respondent Burden and Cost Year Two – Boat Manufacturing NESHAP (40 CFR Part 63, Subpart VVVV) (2018 RTR)
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)			2013 ICR Wages
1. Applications	N/A									Technical	$106.45
2. Surveys and studies	N/A									Managerial	$138.43
3. Familiarize with regulatory requirements c	0	1	0	92	0	0	0	$0		Clerical	$52.77
4. Required activities for sources with add-on control devices d
a. Initial performance test and report h	N/A
b. Establish operating parameters h	N/A
c. Re-evaluating startup, shutdown, and amlfucntion requirements	0	1	0	92	0	0	0	$0
5. Required activities for sources using pollution prevention measures
a. Develop recordkeeping system h	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
c. Work practice requirements e	4	12	48	92	4416	220.8	441.6	$523,952
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					5,078			$523,951.78
8. Notification requirements
a. Initial notification that existing sources are subject to the standard h	N/A
b. Notification for new major sources h	N/A
c. Request for compliance extension h	N/A
d. Notification of special compliance requirements h	N/A
e. Notification of performance tests e	N/A
f. Notification of compliance status h	N/A
9. Reporting requirements
a. Semiannual compliance reports for all sources f	8	2	16	92	1472	73.6	147.2	$174,651
b. Additional reports for sources with add-on control devices e	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	0	1	0	92	0	0	0	$0
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	92	552	27.6	55.2	$65,494
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10.a.
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,328			$240,145
TOTAL LABOR BURDEN AND COST					7,406			$764,096
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)g								$764,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 93 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $124.59 per hour for Executive, Administrative, and Managerial labor; $100.55 per hour for Technical labor, and $45.28 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2016, “May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 336600 – Ship and Boat Building”. 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 it will take the same length of time (4 hours) for both fiberglass and aluminum boat manufacturers to review the final RTR rules for each facility.
d We have assumed that facilities will require some time to evaluate the effect of the rule removing the SSM exemption, and adjusting recordkeeping and reporting to accommodate these changes.
e We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
f We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
h We have assumed that no new facilities will become operational in the next three years.

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Sheet 6: TBL3-ResY3

Table 3 : Annual Respondent Burden and Cost Year Three – Boat Manufacturing NESHAP (40 CFR Part 63, Subpart VVVV) (2018 RTR)
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)			2013 ICR Wages
1. Applications	N/A									Technical	$106.45
2. Surveys and studies	N/A									Managerial	$138.43
3. Familiarize with regulatory requirements c	0	1	0	92	0	0	0	$0		Clerical	$52.77
4. Required activities for sources with add-on control devices d
a. Initial performance test and report h	N/A
b. Establish operating parameters h	N/A
c. Re-evaluating startup, shutdown, and amlfucntion requirements	0	1	0	92	0	0	0	$0
5. Required activities for sources using pollution prevention measures
a. Develop recordkeeping system h	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
c. Work practice requirements e	4	12	48	92	4416	220.8	441.6	$523,952
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					5,078			$523,951.78
8. Notification requirements
a. Initial notification that existing sources are subject to the standard h	N/A
b. Notification for new major sources h	N/A
c. Request for compliance extension h	N/A
d. Notification of special compliance requirements h	N/A
e. Notification of performance tests e	N/A
f. Notification of compliance status h	N/A
9. Reporting requirements
a. Semiannual compliance reports for all sources f	8	2	16	92	1472	73.6	147.2	$174,651
b. Additional reports for sources with add-on control devices e	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	0	1	0	92	0	0	0	$0
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	92	552	27.6	55.2	$65,494
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10.a.
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,328			$240,145
TOTAL LABOR BURDEN AND COST					7,406			$764,096
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)g								$764,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 93 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $124.59 per hour for Executive, Administrative, and Managerial labor; $100.55 per hour for Technical labor, and $45.28 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2016, “May 2016 National Industry-Specific Occupational Employment and Wage Estimates NAICS 336600 – Ship and Boat Building”. 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 it will take the same length of time (4 hours) for both fiberglass and aluminum boat manufacturers to review the final RTR rules for each facility.
d We have assumed that facilities will require some time to evaluate the effect of the rule removing the SSM exemption, and adjusting recordkeeping and reporting to accommodate these changes.
e We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
f We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
h We have assumed that no new facilities will become operational in the next three years.

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Sheet 7: TBL4-ResSUM

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Boat Manufacturing NESHAP (2018 RTR)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	7,544	377	754	8,676	$895,084	$0	$895,000
2	6,440	322	644	7,406	$764,096	$0	$764,000
3	6,440	322	644	7,406	$764,096	$0	$764,000
Total	20,424	1,021	2,042	23,488	$2,423,276	$0	$2,423,000
Average	6,808	340	681	7,829	$807,800	$0	$808,000

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Sheet 8: TBL5-EPAY1

Table 5: Average Annual EPA Burden and Cost Year One – NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (2018 RTR)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2013 ICR Wages
1. Read instructions	N/A									Technical	$47.62
2. Enter and update information into agency recordkeeping system c	4	1	4	92	576	28.8	57.6	$30,760.70		Managerial	$64.16
3. Notification review d										Clerical	$25.76
a. Review initial notification for existing sources	N/A
b. Notification for new major sources e	N/A
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	N/A
f. Review compliance status f	2	1	2	92	288	14.4	28.8	$15,380.35
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	92	1,152	57.6	115.2	$61,521.41
TOTAL LABOR BURDEN AND COST (rounded)h					2,320			$107,700
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 93 existing sources. There will be no additional sources over the three-year period of this ICR.
b 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 Managerial rate, $48.08 Technical rate, and $26.02 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2017 General Schedule”, which excludes locality rates of pay.
c We have assumed that 144 respondents will each take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in year one.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 9: TBL6-EPAY2

Table 6: Average Annual EPA Burden and Cost Year Two – NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (2018 RTR)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2013 ICR Wages
1. Read instructions	N/A									Technical	$47.62
2. Enter and update information into agency recordkeeping system c	4	1	4	92	576	28.8	57.6	$30,760.70		Managerial	$64.16
3. Notification review d										Clerical	$25.76
a. Review initial notification for existing sources	N/A
b. Notification for new major sources e	N/A
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	N/A
f. Review compliance status f	2	1	2	92	288	14.4	28.8	$15,380.35
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	92	1,152	57.6	115.2	$61,521.41
TOTAL LABOR BURDEN AND COST (rounded)h					2,320			$107,700
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 93 existing sources. There will be no additional sources over the three-year period of this ICR.
b 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 Managerial rate, $48.08 Technical rate, and $26.02 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2017 General Schedule”, which excludes locality rates of pay.
c We have assumed that 144 respondents will each take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in year one.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 10: TBL7-EPAY3

Table 7: Average Annual EPA Burden and Cost Year Three – NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (2018 RTR)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2013 ICR Wages
1. Read instructions	N/A									Technical	$47.62
2. Enter and update information into agency recordkeeping system c	4	1	4	92	576	28.8	57.6	$30,760.70		Managerial	$64.16
3. Notification review d										Clerical	$25.76
a. Review initial notification for existing sources	N/A
b. Notification for new major sources e	N/A
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	N/A
f. Review compliance status f	2	1	2	92	288	14.4	28.8	$15,380.35
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	92	1,152	57.6	115.2	$61,521.41
TOTAL LABOR BURDEN AND COST (rounded)h					2,320			$107,700
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 93 existing sources. There will be no additional sources over the three-year period of this ICR.
b 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 Managerial rate, $48.08 Technical rate, and $26.02 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2017 General Schedule”, which excludes locality rates of pay.
c We have assumed that 144 respondents will each take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in year one.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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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 Boat Manufacturing NESHAP (2018 RTR)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	2,016	101	202	2,318	$107,700	$0	$107,700
2	2,016	101	202	2,318	$107,700	$0	$107,700
3	2,016	101	202	2,318	$107,700	$0	$107,700
Total	6,048	302	605	6,955	$323,100	$0	$323,100
Average	2,016	101	202	2,318	$107,700	$0	$107,700