Burden Calculation Tables

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Overview

Table 1
Table 2
Capital and O&M

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Sheet 1: Table 1

					117.92	147.4	57.02
Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year	Management hours per year	Clerical hours per year	Total cost per year
			(AxB)		(CxD)	(Ex0.05)	(Ex0.10)	($) b
1. Applications	N/A
2. Survey and Studies	N/A											New Sources	0.33
3. Reporting Requirements												Existing Sources	41
A. Familiarize with rule requirement c	1	1	1	41	41	2.05	4.10	$5,370.67
B. Required Activities
New Sources
Initial performance test d	280	1	280	0.33	92.4	4.62	9.24	$12,103.66
Repeat performance test d, e	280	0.2	56	0.33	18.48	0.92	1.85	$2,420.73
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Report
New Sources
Notification of construction/reconstruction f	2	1	2	0.33	0.66	0.03	0.07	$86.45
Notification of initial performance test e, g	2	1.2	2.4	0.33	0.792	0.04	0.08	$103.75
Report of initial performance test	See 3B
Existing Sources
Semiannual report h	4	2	8	41	328	16	33	$42,965.38
Subtotal for Reporting Requirements					554			$63,050.64
4. Recordkeeping Requirements
A. Familiarize with rule requirement	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Time to Enter Information
Records of startup, shutdown, and malfunctions i	1.5	2	3	41	123	6.15	12.30	$16,112.02
Records of VOC, temperature, and CMS maintenance j	0.25	52	13	41	533	26.65	53.30	$69,818.74
F. Audits	N/A
Subtotal for Recordkeeping Requirements					754			$85,930.75
TOTAL LABOR BURDEN AND COSTS (rounded) k					1,310			$149,000
TOTAL CAPITAL AND O&M COST (rounded) k								$376,000
GRAND TOTAL k								$525,000		16	hr/response
Assumptions:
a We estimate that there are an average of 41 existing respondents, and it is estimated that one additional source will become subject over the next three years of this ICR.
b. This ICR uses the following labor rates: $117.92 for technical, $147.40 for managerial, and $57.02 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 estimate it will take one hour to read and familiarize with the rule. This burden item applies to all sources.
d. We estimate each performance test will take 280 hours to complete.
e. We estimate 20 percent of respondents will need to repeat the initial performance test.
f. We estimate it will take 2 hours to prepare the notification of construction/reconstruction.
g. We estimate it will take 2 hours to prepare the notification of initial performance test.
h. We estimate it will take 4 hours to compile data for semiannual reports.
i. We estimate it will take 1.5 hours to record startups, shutdowns, and malfunctions.
j. We estimate it will take 0.25 hours to record VOCs, temperatures, and CMS maintenance.
k 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 Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)
					48.75	65.71	26.38
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 per year
			(C=AxB)		(CxD)	(Ex0.05)	(Ex0.10)	($) b
Required Activities
New Sources
Initial performance tests c	24	1	24	0.33	7.92	0.40	0.79	$433.01
Repeat performance tests c, d	24	0.2	4.8	0.33	1.58	0.08	0.16	$86.60
Report Review
New Sources
Notification of construction/reconstruction e	2	1	2	0.33	0.66	0.03	0.07	$36.08
Notification of initial startup f	0.5	1	0.5	0.33	0.17	0.01	0.02	$9.02
Notification of actual startup g	0.5	1	0.5	0.33	0.17	0.01	0.02	$9.02
Notification of initial test d, h	0.5	1.2	0.6	0.33	0.20	0.01	0.02	$10.83
Review test results d, i	0.5	1.2	0.6	0.33	0.20	0.01	0.02	$10.83
Existing Sources
Semiannual reports j	2	2	4	41	164	8.20	16.40	$8,966.45
TOTAL COST (rounded)k					201			$9,560
Assumptions:
a We estimate that an average of 41 existing respondents, and it is estimated that one additional source will become subject over the next three years of this ICR.
b This ICR uses the following labor rates: $48.75 for technical, $65.71 for managerial, and $26.38 for clerical labor. These rates are from the Office of Personnel Management (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 We estimate it will take 24 hours to participate with each performance test.
d We estimate 20 percent of respondents will need to repeat the initial performance test.
e We estimate it will take 2 hours to review construction/reconstruction notifications.
f We estimate it will take 0.5 hours to review initial startup notifications.
g We estimate it will take 0.5 hours to review actual startup notifications.
h We estimate it will take 0.5 hours to review initial test notifications.
i We estimate it will take 0.5 hours to review test results.
j We estimate it will take 2 hours to review each semiannual report twice annually.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and O&M

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)
Temperature or feed rate monitor	$20,000	0.33	$6,600	$9,000	41	$369,000
						$376,000