Burden Calculation Tables

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Overview

Respondent
EPA
Respondents
Total Annual

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Sheet 1: Respondent

Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences 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	Total Cost
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)	Per year b	Technical	117.92
1. Applications	N/A								Managerial	147.4
2. Surveys and studies	N/A								Clerical	57.02
3. Reporting requirements
a. Familiarization with the regulatory requirements c	4	1	4	352	1,408	70.4	140.8	$184,436.74
b. Required activities
Initial performance test d	240	1	240	0	0	0	0	$0
Repeat performance tests d	240	1	240	0	0	0	0	$0
Install CMS d	100	1	100	0	0	0	0	$0
Develop CMS/QC program and test plan d	100	1	100	0	0	0	0	$0
Conduct CMS performance evaluation d	300	1	300	0	0	0	0	$0
Maintain, adjust, and calibrate CMS e	6	52	312	46	14,352	717.6	1,435.2	$1,879,997.18
c. Create information	See 3B
d. Gather existing information	See 3E
e. Write report
New Sources
Notification of initial and HAP usage d	4	1	4	0	0	0	0	$0
Notification of compliance status d	4	1	4	0	0	0	0	$0
Notification of performance test d	2	1	2	0	0	0	0	$0
Report of performance test d	40	1	40	0	0	0	0	$0
Existing Sources
Startup, shutdown, malfunction report f	2	2	4	30	120	6	12	$15,719.04
Semiannual excess emission and CMS performance report g	16	2	32	76	2,432	121.6	243.2	$318,572.54
Subtotal for Reporting Requirements					21,059			$2,398,725.50
4 Recordkeeping requirements
a. Familiarization with the regulatory requirements	See 3A
b. Plan activities	N/A
c. Implement activities	N/A
d. Develop record system d	40	1	40	0	0	0	0	$0
e. Time to enter information
Records of maintenance h	4	52	208	105	21,840	1,092	2,184	$2,860,865.28
Records of startup, shutdown, and malfunction i	2	52	104	30	3,120	156	312	$408,695.04
Records of malfunction or inoperative CMS i	2	2	4	30	120	6	12	$15,719.04
Records of applicability determination d	2	1	2	0	0	0	0	$0
Records of CMS operation j	2	52	104	46	4,784	239.2	478.4	$626,665.73
Records of liquid-liquid material balances; HAP, volatile material, solids and materials applied, operating parameters k	2	12	24	105	2,520	126	252	$330,099.84
Records of materials used by incidental printers l	40	1	40	2	80	4	8	$10,479.36
Records of HAP usage (area sources) m , n	0.5	12	6	200	1,200	60	120	$157,190.40
f. Time to train personnel	See 3A
g. Time for audits	N/A
Subtotal for Recordkeeping Requirements					38,714			$4,409,714.69
TOTAL LABOR BURDEN AND COST (rounded) o					59,800			$6,810,000
Capital and O&M Cost (rounded): o								$414,000
TOTAL COST (rounded): o								$7,220,000
								98	hr/resp
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 352. Of the 352 facilities, 152 are major sources, and 200 are area sources. There will be no additional new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. 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.
c We have assumed that all facilities will take 4 hours to read and review instructions.
d We have assumed that there will be no new sources during the three-year period of this ICR.
e We have assumed that 30 percent of the 152 major source respondents (46 facilities) will be required to maintain, adjust, and calibrate CMS.
f We have assumed that 20 percent of the 152 major source respondents (30 facilities) will have startup, shutdown, malfunction incidents with equipment or inoperative CMS reports to complete.
g We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions.
h We have assumed that 105 facilities do not have CMS installed in them.
i We have assumed that 20 percent of respondents (major source) will enter information on startup, shutdown, malfunction problems with equipment or inoperative CMS.
j We have assumed that 46 respondents (major source) will enter information on CMS operations.
k We have assumed that 105 facilities do not have CMS installed in them.
l We have assumed that 2 existing facilities will be required to enter information on records of materials used by incidental printers.
m We have assumed that 200 area sources, which includes products and packaging rotogravure and wide-web flexographic printing presses, are subject to recordkeeping requirements, and are required to keep a monthly record of HAP usage to show that they are meeting the limit.
n We have assumed that it will take each respondent 0.5 hours to record HAP usage.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: EPA

Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year	Plants 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)
Required activities									Technical	48.75
New sources									Managerial	65.71
Initial performance tests c	24	1	24	0	0	0	0	$0	Clerical	26.38
Repeat performance tests c	24	1	24	0	0	0	0	$0
Report review
New sources
Notification of initial startup c	2	1	2	0	0	0	0	$0
Notification of compliance status c	4	1	4	0	0	0	0	$0
Notification of performance test c	1	1	1	0	0	0	0	$0
Review test results c	8	1	8	0	0	0	0	$0
Existing sources
Semiannual excess emissions and CMS performance report d	2	2	4	76	304	15.2	30.4	$16,620.74
Periodic startup, shutdown, malfunction report e	2	1	2	30	60	3	6	$3,280.41
TOTAL ANNUAL BURDEN AND COST (rounded) f					419			$20,000
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 352. Of the 352 facilities, 152 are major sources, and 200 are area sources. There will be no additional new sources over the three-year period of this ICR.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical, and $26.38 Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We have assumed that there will be no new sources during the three-year period of this ICR.
d We have assumed that 46 facilities are fitted with CMS control, and an additional 30 facilities that may encounter excess emissions.
e We have assumed that 20 percent of 152 major sources (30 facilities) will be required to submit periodic startup, shutdown, malfunction report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	152	200	0	352
2	0	152	200	0	352
3	0	152	200	0	352
Average					352

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Sheet 4: Total Annual

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Notification of initial and HAP usage	0	1	0	0
Notification of compliance status	0	1	0	0
Notification of performance test	0	1	0	0
Report of performance test	0	1	0	0
Startup/shutdown/malfunction report	30	2	0	60
Semiannual excess emission and CMS performance report	76	2	0	152
Records of HAP usage (area source)	200	2	0	400
			Total	612