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 Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Reinforced Plastic Composites Production 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 Reinforced Plastic Composites Production NESHAP Residual Risk and Technology Review

TABLES 5, 6, and 7

Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for theReinforced Plastic Composites Production 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 Reinforced Plastic Composites Production 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	$48.62	$102.11
Managerial	$64.74	$135.96
Clerical	$48.62	$102.11
Footnotes:
(1) 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 326100 – Plastics Product Manufacturing”. The rates are from column 8, “Mean hourly wage.”
https://www.bls.gov/oes/current/naics4_326100.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 (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 WWWW) (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)			2014 ICR Wages
1. Applications	N/A									Technical	$103.97
2. Survey and Studies	N/A									Managerial	$129.93
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									Clerical	$51.79
4. Reporting Requirements
A. Familiarization with the regulatory requirement:
i. Facilities with 4 groups of operations	12	1	12	14.88	178.56	8.93	17.86	$20,649.66
ii. Facilities with 5 groups of operations	13	1	13	1.12	14.56	0.73	1.46	$1,683.80
B. Required activities: Sources with add-on controls
i. Initial performance test c	320	1	320	2	640	32	64	$74,013.12
ii. Repeat of performance test	320	1	320	0.4	128	6.4	12.8	$14,802.62
iii. Operation, maintenance, monitoring plan	40	1	40	2	80	4	8	$9,251.64
iv. Startup, shutdown, malfunction plan	20	1	20	2	40	2	4	$4,625.82
v. Monitoring of operating parameters and equipment d	See 5E
C. Gather Existing Information	See 5D, 5E
D. Write report a, c
i. Notification of compliance status	4	1	4	16	64	3.2	6.4	$7,401.31
ii. Notification of construction/ reconstruction a	2	1	2	16	32	1.6	3.2	$3,700.66
iii. Notification of actual startup	2	1	2	16	32	1.6	3.2	$3,700.66
iv. Notification of performance test	2	1	2	2	4	0.2	0.4	$462.58
v. Reports of performance test results	See 4B
vii. Report of exceedances f	16	2	32	120	3840	192	384	$444,078.72
viii. Report of no exceedances	8	2	16	480	7680	384	768	$888,157.44
ix. Startup, shutdown, malfunction report g	2	1	2	22	44	2.2	4.4	$5,088.40
Subtotal for Reporting Requirements					14,694			$1,477,616.43
5. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system (spreadsheets): h
i. System for low HAP resin	4	1	4	14	56	2.8	5.6	$6,476.15
ii. System for work practices	1	1	1	16	16	0.8	1.6	$1,850.33
iii. System for add-on control devices	2	1	2	2	4	0.2	0.4	$462.58
E. Time to enter and transmit all information into record system h
i. Enter information on low HAP resin	10	1	10	480	4800	240	480	$555,098.40
ii. Enter information on work practices and operating parameters	N/A
F. Develop operator training course and keep records of operators taken it	10	1	10	16	160	8	16	$18,503.28
G. Time to train personnel:
i. Small facilities (less than 100 employees)	2	1	2	13.12	26.24	1.312	2.624	$3,034.54
	0.4	1	0.4	478.88	191.55	9.58	19.16	$22,152.13
ii. Medium facilities (100-250 employees)	4	1	4	1.76	7.04	0.35	0.7	$814.14
	0.8	1	0.8	64.24	51.39	2.57	5.14	$5,943.25
iii. Large facilities (more than 250 employees)	8	1	8	1.12	8.96	0.45	0.9	$1,036.18
	1.6	1	1.6	40.88	65.41	3.27	6.54	$7,564.14
H. Time for audits	N/A
Subtotal for Recordkeeping Requirements					6,195			$622,935
TOTAL LABOR BURDEN AND COST (rounded)n					20,900			$2,100,000
Capital and O&M Cost (see Section 6(b)(iii))								$476,000
GRAND TOTAL (rounded)n								$2,580,000
Assumptions:
a There is an average of 584 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be an average of 16 new RPC facilities each year over the three year period of this ICR of which 93 percent (or 14.88) will consist of facilities with 4 groups of operations and 7 percent (or 1.12) of facilities with 5 groups of operations. There is an average of 600 total respondents per year over the next three year period of this ICR.
b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, ”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.
c New respondents have to comply with the initial rule requirements including notifications and performance tests. We have assumed that two new respondents per year will install add-on controls equipment and therefore, will be require to conduct an initial performance test. We have assumed that performance tests are repeated by 20 percent of the respondents.
d Monitoring and recordkeeping of operations for respondents with enclosures and add-on control devices include: 1) specific operating parameters for each control device established during the performance test, 2) start-up, shutdown, and malfunctions of equipment, and 3) work practices.
e Monitoring and recordkeeping of operations for respondents that comply by limiting the HAP content of their raw materials include: 1) monitoring and recording in a spreadsheet the monthly consumption of material and the weighted-average HAP content over the past 12 months, and 2) work practices. However, if all the materials in an operation meet the HAP content limit, then each respondent would need only to record HAP content and would not need to track monthly consumption or record the computations. For open molding and centrifugal casting operations, respondents would also have the option of averaging among thirteen different processes (open molding) and two different processes (centrifugal casting to calculate the monthly average of the actual and allowable emissions for the combined open molding and centrifugal casting operations).
f We have assumed that approximately 80 percent of the 600 (or 480) existing respondents will report no excess emissions twice a year and approximately 20 percent (or 120) will report excess emissions twice a year.
g We have assumed that all RPC facilities with add-on controls (18 existing and 2 new each year or an average of 22) will have at least one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plan.
h New respondents (16) have to develop a record system. In addition, existing RPC facilities have to record operational data. In general, the following monitoring is required: 1) facilities with open molding and/or centrifugal casting operations (452 existing and 14 new each year or an average of 480 per year) would have to record for low HAP resins; 2) facilities with add-on controls (18 existing and 2 new or an average of 22 RPCs per year) would have to record add-on control devices operating parameters; and 3) all facilities (600) need to keep records of its work practices. Since operating parameters for control equipment and standard work practices are already monitored by industry for other purposes, we are not attributing these burdens to the rule.
i We have assumed that he amount of time it takes a respondent to train its employees would vary with the number of employees at its facility. We have also assumed that the distribution in size of the new respondents would be identical to that of the existing PRC universe. Therefore, we have assumed that 82 percent of the respondents would be small business (i.e., 478.88 RPCs existing and 13.12 new RPC per year), 11 percent (i.e. 64.24 existing RPCs and 1.76 new RPCs per year), would be medium business, and 7 percent (i.e., 40.88 existing RPCs and 1.12 new RPCs) are large business. Furthermore, we have assumed that respondents will be providing full training to new employees only. Therefore, to train existing respondents, it will take 20 percent of the time it takes to train new employees.
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
Notification of applicability a	2	1	2	2	4	0.1	0.4	$203.07		Technical	$47.62
Notification of intent to construct a major source and review application	12	1	12	16	192	0.8	19.2	$9,495.76		Managerial	$64.16
Notification of start of construction	2	1	2	16	32	0.8	3.2	$1,624.56		Clerical	$25.76
Notification of actual startup	2	1	2	16	32	0.8	3.2	$1,624.56
Notification of initial performance test and test plan	12	1.2	14.4	2	28.8	0.1	2.88	$1,423.11
Report of performance test results including operating parameters	12	1.2	14.4	2	28.8	0.1	2.88	$1,423.11
Notification of compliance status	2	1	2	16	32	0.8	3.2	$1,624.56
Review reports of excess emissions c	4	2	8	120	960	6	96	$47,604.60
Review reports of no excess emissions c	2	2	4	480	1920	24	192	$95,964.00
Review of startup, shutdown, malfunction report d	4	1	4	22	88	1.1	8.8	$4,398.35
TOTAL ANNUAL BURDEN AND COST (rounded)					3,680			$165,390
Assumptions:
a There is an average of 584 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be an average of 16 new RPC facilities each year over the three year period of this ICR. Therefore, there is an average of 600 total respondents per year over the next three year period of this ICR. We have assumed that 82 percent of the existing RPC facilities are small business, 11 percent are medium size facilities and 7 percent are large facilities. Furthermore, we have assumed that 93 percent of the new RPC facilities will consist of an average of four groups of operations and 7 percent will consist of five groups of operations.
b This cost is based on the following labor rates: Managerial rate of $62.90 (GS-13, Step 5, $39.31 + 60%), Technical rate of $46.67 (GS-12, Step 1, $29.17 + 60%), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2014 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 approximately 80 percent (or 480) of the respondents will report no excess emissions twice a year and approximately 20 percent (or 120) will report excess emissions twice a year.
d We have assumed that all RPC facilities with add-on controls (18 existing and 2 new each year or an average of 22) will have at least one startup, shutdown, or malfunction occurrence that is not managed according to the plan.

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Sheet 4: TBL1-ResY1

Table 1 : Annual Respondent Burden and Cost Year One – Reinforced Plastic Composites Production NESHAP (40 CFR Part 63, Subpart WWWW) (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)			2016 ICR Wages
1. Applications	N/A									Technical	$102.10
2. Surveys and studies	N/A									Managerial	$135.95
3. Familiarize with regulatory requirements	4	1	4	448	1792	89.6	179.2	$202,630		Clerical	$41.77
4. Required activities for sources with add-on control devices c
a. Initial performance test and report g	N/A
b. Establish operating parameters g	N/A
c. Re-evaluating startup, shutdown, and amlfucntion requirements	4	1	4	448	1792	89.6	179.2	$202,630
5. Required activities for sources using pollution prevention measures
a. Develop recordkeeping system g	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
c. Work practice requirements d	4	12	48	448	21504	1075.2	2150.4	$2,431,554
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					28,851			$2,836,813.06
8. Notification requirements
a. Initial notification that existing sources are subject to the standard g	N/A
b. Notification for new major sources g	N/A
c. Request for compliance extension g	N/A
d. Notification of special compliance requirements g	N/A
e. Notification of performance tests d	N/A
f. Notification of compliance status g	N/A
9. Reporting requirements
a. Semiannual compliance reports for all sources e	8	2	16	448	7168	358.4	716.8	$810,518
b. Additional reports for sources with add-on control devices d	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	4	1	4	448	1792	89.6	179.2	$202,630
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	448	2688	134.4	268.8	$303,944
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					13,395			$1,317,092
TOTAL LABOR BURDEN AND COST					42,246			$4,153,905
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)f								$4,154,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 448 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $135.95 per hour for Executive, Administrative, and Managerial labor; $102.10 per hour for Technical labor, and $41.77 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 326100 – Plastics Product Manufacturing”. The rates are from column 8, “Mean hourly wage.” 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 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.
d We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
e We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
g 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 – Reinforced Plastic Composites Production NESHAP (40 CFR Part 63, Subpart WWWW) (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)			2016 ICR Wages
1. Applications	N/A									Technical	$102.10
2. Surveys and studies	N/A									Managerial	$135.95
3. Familiarize with regulatory requirements c	0	1	0	448	0	0	0	$0		Clerical	$41.77
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	448	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	448	21504	1075.2	2150.4	$2,431,554
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					24,730			$2,431,554.05
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	448	7168	358.4	716.8	$810,518
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	448	0	0	0	$0
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	448	2688	134.4	268.8	$303,944
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					11,334			$1,114,462
TOTAL LABOR BURDEN AND COST					36,064			$3,546,016
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)g								$3,546,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 448 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $135.95 per hour for Executive, Administrative, and Managerial labor; $102.10 per hour for Technical labor, and $41.77 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 326100 – Plastics Product Manufacturing”. The rates are from column 8, “Mean hourly wage.” 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 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.
d We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
e We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
g We have assumed that no new facilities will become operational in the next three years.
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 – Reinforced Plastic Composites Production NESHAP (40 CFR Part 63, Subpart WWWW) (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)			2016 ICR Wages
1. Applications	N/A									Technical	$102.10
2. Surveys and studies	N/A									Managerial	$135.95
3. Familiarize with regulatory requirements c	0	1	0	448	0	0	0	$0		Clerical	$41.77
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	448	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	448	21504	1075.2	2150.4	$2,431,554
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					24,730			$2,431,554.05
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	448	7168	358.4	716.8	$810,518
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	448	0	0	0	$0
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	448	2688	134.4	268.8	$303,944
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					11,334			$1,114,462
TOTAL LABOR BURDEN AND COST					36,064			$3,546,016
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)g								$3,546,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 448 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $135.95 per hour for Executive, Administrative, and Managerial labor; $102.10 per hour for Technical labor, and $41.77 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 326100 – Plastics Product Manufacturing”. The rates are from column 8, “Mean hourly wage.” 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 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.
d We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
e We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
g We have assumed that no new facilities will become operational in the next three years.
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 Reinforced Plastic Composites Production 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	36,736	1,837	3,674	42,246	$4,153,905	$0	$4,154,000
2	31,360	1,568	3,136	36,064	$3,546,016	$0	$3,546,000
3	31,360	1,568	3,136	36,064	$3,546,016	$0	$3,546,000
Total	99,456	4,973	9,946	114,374	$11,245,937	$0	$11,246,000
Average	33,152	1,658	3,315	38,125	$3,748,600	$0	$3,749,000

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Sheet 8: TBL5-EPAY1

Table 5: Average Annual EPA Burden and Cost Year One – NESHAP for Reinforced Plastic Composites Production NESHAP (40 CFR Part 63, Subpart WWWW) (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	448	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	448	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	448	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 448 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 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 Reinforced Plastic Composites Production NESHAP (40 CFR Part 63, Subpart WWWW) (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	448	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	448	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	448	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 448 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 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 – Reinforced Plastic Composites Production NESHAP (40 CFR Part 63, Subpart WWWW) (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	448	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	448	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	448	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 448 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 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 Reinforced Plastic Composites Production 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