Burden Calculation Tables

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Overview

Table 1
Table 2
Additional

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences per year	(C) Person hrs per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Reporting requirements										Labor Rates:
a. Familiarization with the regulatory requirements	8	1	8	223	1,784	89.2	178.4	$233,689.73		Management	$147.40
b. Process/review information	4	4	16	223	3,568	178.4	356.8	$467,379.46		Technical	$117.92
c. Write reports										Clerical	$57.02
i. Initial notification	2	1	2	0	0	0	0	$0
ii. Notification of compliance status	2	1	2	0	0	0	0	$0
iii. Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
iv. Notification of actual startup	2	1	2	0	0	0	0	$0
v. Notification of performance test c	2	1.05	2.1	0	0	0	0	$0
vi. Report of performance test c	10	1.05	10.5	0	0	0	0	$0
vii. Semiannual report d	6	2	12	223	2,676	133.8	267.6	$350,534.59
viii. Excess emissions report	2	2	4	223	892	44.6	89.2	$116,844.86
ix. Startup, shutdown, malfunction report e	2	1	2	56	112.0	5.6	11.2	$14,671.10
Subtotal for Reporting Requirements					10,387			$1,183,120
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	See 1.a.
b. Plan activities	12	1	12	223	2,676	133.8	267.6	$350,534.59
c. Implement activities	12	1	12	223	2,676	133.8	267.6	$350,534.59
d. Maintain record system for material used	20	1	20	223	4,460	223	446	$584,224.32
e. Time to enter information
i. Material usage f	0.5	365	182.5	223	40,698	2,034.9	4,070	$5,331,046.92
ii. Compliance calculation g	2	12	24	223	5,352	267.6	535.2	$701,069.18
f. Time to train personnel	10	1	10	223	2,230	111.5	223	$292,112.16
g. Store, file, and maintain records h	2	12	24	223	5,352	267.6	535.2	$701,069.18
h. Retrieve records/reports i	1	12	12	223	2,676	133.8	267.6	$350,534.59
Subtotal for Recordkeeping Requirements					76,037			$8,661,126		948	# responses
Total Labor Burden and Cost (rounded) j					86,400			$9,840,000		91	hr per resp
Total Capital and O&M Cost (rounded) j								$66,900
Grand Total (rounded) j								$9,910,000
Assumptions:
a We have assumed that there are approximately 223 respondents, with no additional new sources becoming subject to the rule 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% to account for the benefit packages available to those employed by private industry.
c We have assumed that 5 percent of respondents will repeat the initial performance test due to failure.
d We assume that each respondent will take 6 hours twice per year to write the semiannual report.
e It is estimated that 25 percent of facilities using add-on controls submit startup, shutdown, and malfunction report once per year.
f We assumed that each respondent will take 0.5 hours each day to enter daily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating.
g We have assumed that each respondent will take 2 hours once per month to enter compliance calculations.
h We have assumed that each respondent will take 2 hours once per month to store, file and maintain records.
i We have assumed that each respondent will take 1 hour once per month to retrieve records/reports.
j 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: Average Annual EPA Burden and Cost - NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)
Burden Item	(A) EPA Person hours per occurrence	(B) Number of occurrences per year	(C) EPA Person hrs per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Initial performance test	24	1	24	0	0	0	0	$0		Labor Rates:
2. Repeat performance test	24	0.2	4.8	0	0	0	0	$0		Management	$65.71
3. Report review										Technical	$48.75
a. Initial notification	8	1	8	0	0	0	0	$0		Clerical	$26.38
b. Notification of compliance status	8	1	8	0	0	0	0	$0
c. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
d. Notification of actual startup	8	1	8	0	0	0	0	$0
e. Notification of performance test	8	1.05	8.4	0	0	0	0	$0
f. Report of performance test	8	1.05	8.4	0	0	0	0	$0
g. Semiannual report c	12	2	24	223	5,352	267.6	535.2	$292,612.57
h. Excess emissions report d	4	2	8	223	1,784	89.2	178.4	$97,537.52
i. Startup, shutdown, malfunction report	8	1	8	56	448	22.4	44.8	$24,493.73
Total (rounded): e					8,720			$415,000
Assumptions:
a We have assumed that there are approximately 223 respondents, with no additional new sources becoming subject to the rule 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: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We have assumed that it will take 12 hours two times per year to review the semiannual report.
d We have assumed that it will take 4 hours two times per year to review the excess emissions report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Additional

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
CEMS a	$16,000	0	$0	$1,200	55.75	$66,900
Total b			$0			$66,900
a We assume that 25 percent of existing facilities use add-on controls. (223 x 0.25 = 55.75)
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
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	223	0	0	223
2	0	223	0	0	223
3	0	223	0	0	223
Average	0	223	0	0	223
1 New respondents include sources with constructed, reconstructed and modified affected facilities.
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial notification	0	0	0	0
Notification of compliance status	0	0	0	0
Notification of construction/reconstruction	0	0	0	0
Notification of actual startup	0	0	0	0
Notification of performance test	0	0	0	0
Report of performance test	0	0	0	0
Semiannual report	223	2	0	446
Excess emissions report	223	2	0	446
Startup, shutdown, malfunction report	56	1	0	56
			Total	948