Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)
					117.92	147.4	57.02
Burden Item	(A)Person hours per occurrence	(B)Number of occurrences per respondent per Year	(C) Person hours per respondent per year (AxB)	(D) Number of respondents per Year a	(E) Technical person hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Labor Costs per Year b
1. Applications a	17.4	1	17.4	2	34.8	1.74	3.48	$4,558.52
2. Survey and studies	116.5	1	116.5	2	233	11.65	23.3	$30,521.14
3. Reporting requirements
A. Familiarization with the regulatory requirements	8.7	1	8.7	72	626.4	31.32	62.64	$82,053.39
B. Required activities
Initial performance test c	2,434.8	1	2,434.8	2	4,869.60	243.48	486.96	$637,878.64
Demonstration of CMS	N/A
Repeat performance test c, d	573.9	1	573.9	0.4	229.56	11.478	22.956	$30,070.52
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
Notification of construction/reconstruction	1.7	1	1.7	2	3.4	0.17	0.34	$445.37
Notification of actual startup	1.7	1	1.7	2	3.4	0.17	0.34	$445.37
Notification of initial performance test	35.7	1	35.7	2	71.4	3.57	7.14	$9,352.83
Report of performance test	See 3B
Excess emission reports
VOC emission reports	8.7	4	34.8	72	2,505.6	125.28	250.56	$328,213.56
Temperature reports	26.1	2	52.2	72	3,758.4	187.92	375.84	$492,320.33
Subtotal for Reporting Requirements					14,186			$1,615,859.68
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	8.7	1	8.7	72	626.4	31.32	62.64	$82,053.39
B.  Plan activities	17.4	1	17.4	72	1,252.8	62.64	125.28	$164,106.78
C. Implement activities
Monthly performance test	1,669.6	1	1669.6	72	120,211.2	6010.56	12021.12	$15,746,705.51
D.  Develop record system	4,347.8	1	4347.8	2	8,695.6	434.78	869.56	$1,139,054.04
E.  Time to enter information
Records of temperature	417.4	1	417.4	72	30,052.8	1,502.64	3005.28	$3,936,676.38
F.   Train personnel	34.8	1	34.8	72	2,505.6	125.28	250.56	$328,213.56
G.  Audits	17.4	1	17.4	72	1,252.8	62.64	125.28	$164,106.78
5. Equipment and analytical evaluation expense
A. Continuous monitoring & evaluation	34.8	1	34.8	72	2,505.6	125.28	250.56	$328,213.56
B. Routine testing and maintenance	52.2	1	52.2	72	3,758.4	187.92	375.84	$492,320.33
C. Systems of manage data	34.8	1	34.8	72	2,505.6	125.28	250.56	$328,213.56
Subtotal for Recordkeeping Requirements					199,372			$22,709,664
TOTAL LABOR BURDEN AND COST (rounded) e					214,000			$24,300,000
TOTAL CAPITAL AND O&M COSTS (rounded): e								$128,000
GRAND TOTAL (rounded): e								$24,400,000		489	hr/resp
Assumptions
a We have assumed that there are approximately 70 existing respondents, with 2 new respondents per year over the next 3 years 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 It is assumed the EPA Reference Method 24 test performed on the coatings used by the respondents is generally done by the coatings manufacturers, who provide the test results to the respondents. It is further assumed that the coatings manufacturers routinely perform an EPA Method 24 analysis on their coatings as a quality control measure, so there will be no additional cost incurred by the coatings manufacturers.
d Rate of failed performance tests is 20 percent.
e 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 – NSPS for Automobile and Light Duty Truck Surface Coating Operations (40 CFR Part 60, Subpart MM) (Renewal)
					48.75	65.71	26.38
Burden Items	(A) Person hours per occurrence	(B) Number of occurrences per Plant per Year	(C) EPA hours per respondent per year (AxB)	(D) Plants per Year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical Hours per Year (Ex0.1)	(H) Total costs per year b
Initial performance test
New Plant	20.9	1.2	25.08	2	50.16	2.51	5.02	$2,742.42
Report review
New Plant
Notification of construction	1.7	1	1.7	2	3.4	0.17	0.34	$185.89
Notification of initial startup	0.4	1	0.4	2	0.8	0.04	0.08	$43.74
Notification of actual startup	0.4	1	0.4	2	0.8	0.04	0.08	$43.74
Notification of initial performance test c	0.4	1.2	0.48	2	0.96	0.05	0.10	$52.49
Review test results c	7	1.2	8.4	2	16.8	0.84	1.68	$918.51
Existing Plant
VOC emission reports	1.7	4	6.8	72	489.6	24.48	48.96	$26,768.15
Temperature reports	1.7	2	3.4	72	244.8	12.24	24.48	$13,384.07
TOTAL COST (rounded) d					928			$44,100
Assumptions
a We have assumed that there are approximately 70 existing respondents, with 2 new respondents per year over the next 3 years 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 for Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c Rate of failed performance tests is 20 percent.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.