Burden Calculation Tables

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Overview

Industry
Agency

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Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal)
											TECH	117.92
	Burden Item	(A) Hours per occurrence	(B) No. of occurrences per respondent per year	(C) Hours per respondent per year (A x B)	(D) 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)	(H) Total costs per year ($)b		MNG	147.4
	1. Applications	N/A									CLER	57.02
	2. Survey and studies	N/A
	3. Acquisition, installation, and utilization of technical systems	N/A
	4. Reporting requirements
	A. Familiarization with the regulatory requirement	2	1	2	22	44	2.2	4.4	$5,763.65
	B. Required activities
	Initial notificationc	1	1	1	0	0	0	0	$0
	Notification of compliance statusc	1	1	1	0	0	0	0	$0
	Annual compliance certificationd	1	1	1	22	22	1.10	2.2	$2,881.82
	Report of exceedencesd	2	1	2	22	44	2.2	4.4	$5,763.65
	C. Create information	See 4B
	D. Gather existing information	See 4B
	E. Write report	See 4B
	Reporting subtotal					127			$14,409.12
	5. Recordkeeping requirements
	A. Familiarization with the regulartory requirement	See 4A
	B. Plan activities	See 5E
	C. Implement activities	See 5E
	D. Develop record system	See 5E
	E. Time to enter information
	Records of all information required by standards	0.25	1	0.25	219	54.8	2.74	5.48	$7,171.81
	F. Time and cost to perform VE observatione	1	1	1	219	219	11.0	22	$102,052.25
	G. Time to adjust existing ways to comply with previous applicable regulations	N/A
	H. Time to transmit or disclose information	0.25	1	0.25	219	54.8	2.74	5.48	$7,171.81
	I. Time for audits	N/A
	Recordkeeping subtotal					378			$116,395.87
	TOTAL ANNUAL BURDEN AND COSTS (rounded): f					500			$131,000
	Capital and O&M Cost (see Section 6(b)(iii)):								$0
	TOTAL COST: f								$131,000		1	hrs/response
	Assumptions:
	a We have assumed that there are 219 existing facilities that are subject to the rule, and that no new major sources per year will become subject over the 3 year-period of this ICR. We assume that 10 percent of foundries will be required to respond and will refamiliarize with the rule requirements each year.
	b This ICR uses the following labor rates: Technical $117.92 ($56.15 + 110%); Managerial $147.40 ($70.19+ 110%); and Clerical $57.02 ($27.15 + 110%). 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.” 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
	c This burden item applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
	d This report does not need to be submitted unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of the foundries will experience deviations.
	e Cost includes $335 per facility to certify technical person in VE (EPA Method 9) testing.
	f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal)
										TECH	48.75
										MNG	65.71
Burden Item	(A) EPA Hours per Occurrence	(B) No. of occurrences per plant per year	(C) EPA hours per plant per year (A x B)	(D) Plants per yeara	(E) EPA technical hours per year (C x D)	(F) EPA managerial hours per year (E x 0.05)	(G) EPA clerical hours per year (E x 0.1)	(H) Total cost per yearb ($)		CLER	26.38
Report review
Initial notificationc	1	1	1	0	0	0	0	$0
Notification of compliance statusc	2	1	2	0	0	0	0	$0
Annual compliance certificationd	2	1	2	22	44	2.2	4.4	$2,405.63
Report of exceedanced	2	1	2	22	44	2.2	4.4	$2,405.63
TOTAL ANNUAL BURDEN e					100			$4,810
Assumptions:
a We have assumed that there are 219 existing facilities that are subject to the rule, and that no new major sources per year will become subject over the 3 year-period of this ICR. We assume that 10 percent of foundries will be required to respond.
b This cost is based on the average hourly labor rate as follows: Technical $48.75 (GS-12, Step 1, $30.47 + 60%); Managerial $65.71 (GS-13, Step 5, $41.07 + 60%); and Clerical $26.38 (GS-6, Step 3, $16.49 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the 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 This burden item applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
d This report does not need to be submitted unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of the foundries will experience deviations.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.