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 Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS)(Renewal)
					120.27	141.06	58.67
Burden Items	(A) Person hours per occurrence	(B) Number of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Number of Respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Labor Costs per Year b
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	0.87	1	0.87	6	5.22	0.26	0.52	$695.25
B. Required Activities
Initial performance test d	243.48	1	243.48	2	486.96	24.35	48.70	$64,858.20
Repeat of performance test e	243.48	0.2	48.70	2	97.39	4.87	9.74	$12,971.64
Method 24 Testing	78.26	12	939.12	0.1	93.91	4.70	9.39	$12,508.14
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report
Notification of construction/reconstruction/modification f	1.74	1	1.74	1	1.74	0.09	0.17	$231.75
Notification of phys/operational change	6.96	1	6.96	2	13.92	0.70	1.39	$1,854.00
Notification of actual startup	1.74	1	1.74	2	3.48	0.17	0.35	$463.50
Notification of initial performance test	1.74	1	1.74	2	3.48	0.17	0.35	$463.50
Notification of CMS	1.74	1	1.74	2	3.48	0.17	0.35	$463.50
Report of performance test	See 3B
Excess Emission Report g	13.91	4	55.64	1.2	66.77	3.34	6.68	$8,892.83
Report of No Excess Emissions h	6.96	2	13.92	4.8	66.82	3.34	6.68	$8,899.22
Report when Exceed Size Cutoff	1.74	1	1.74	0	0	0	0	$0
Subtotal for Reporting Requirements					970			$112,302
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B.  Plan Activities	See 4C
C. Implement Activities	See 3B
D.  Develop Record System	N/A
E.  Time to Enter Information
1) Records of startups, shutdowns, malfunctions, etc. i	1.3	50	65	6	390	19.5	39	$51,944.10
2) Records of control device operating parameters j	0.22	350	77	6	462	23.1	46.2	$61,533.78
3) Records of Projected/Actual Solvent Use k	6.96	2	13.92	1.2	16.70	0.84	1.67	$2,224.81
4) Records for Monthly Liquid Material Balance l	1.74	12	20.88	1.2	25.06	1.25	2.51	$3,337.21
5) Monthly Determination of Avg VOC Content m	1.74	12	20.88	1.2	25.06	1.25	2.51	$3,337.21
6) Records of periods when no emission control device is used	See 4E(2)
F.   Train Personnel	N/A
G.  Audits	N/A
Subtotal for Recordkeeping Requirements					1,057			$122,377
TOTAL LABOR BURDEN AND COST (rounded) n					2,030			$235,000	88	hrs/resp.
TOTAL CAPITAL AND O&M COST (rounded) n								$86,400
GRAND TOTAL (rounded) n								$321,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 6 existing sources, and no additional sources will become subject to the standard. However, we assume that two coating lines per year will be constructed at existing sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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 all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take each respondent 243.48 hours to perform initial performance test.
e We have assumed 20 percent of respondents will have to repeat performance tests.
f We have assumed that there will be one modification/reconstruction line over 5 years.
g We have assumed that 20 percent of sources will report excess emissions.
h We have assumed that 80 percent of sources will report no excess emissions.
i We have assumed that each respondent will take 1.3 hours 50 times per year to record SSM reports.
j We have assumed that each respondent will take 0.22 hours 350 time per year to record the control device operating parameters information.
k We have assumed that 20 percent of respondents will enter information on records of projected/actual solvent use two times per year.
l We have assumed that 20 percent of respondents will record liquid material balance 12 times per year.
m We have assumed that 20 percent of respondents will perform monthly VOC determination.
n Totals have been rounded to 3 significant figures. Figures may not add exatly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS) (Renewal)
					49.44	66.62	26.75
Activity	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Plant per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Total Costs per Year ($) b
Initial Performance Tests c	20.87	1	20.87	2	41.74	2.09	4.17	$2,314.32
Repeat Performance Test d	20.87	0.2	4.17	2	8.35	0.42	0.83	$462.86
Report Review
Notification of construction	1.74	1	1.74	1	1.74	0.09	0.17	$96.48
Notification of actual startup	0.43	1	0.43	2	0.86	0.04	0.09	$47.68
Notification of initial test e	0.43	1.2	0.52	2	1.03	0.05	0.10	$57.22
Review test results f	6.96	1.2	8.35	2	16.70	0.84	1.67	$926.17
Excess emission report g	6.96	4	27.84	1.2	33.41	1.67	3.34	$1,852.34
Report of no excess emissions h	1.74	2	3.48	4.8	16.70	0.84	1.67	$926.17
TOTAL LABOR BURDEN AND COST (rounded) i					139			$6,680
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 6 existing sources, and no additional sources will become subject to the standard. However, we assume that two coating lines per year will be constructed at existing sources 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: $66.62 Managerial rate (GS-13, Step 5, $41.64 x 1.6), $49.44 Technical rate (GS-12, Step 1, $30.90 x 1.6), and $26.75 Clerical rate (GS-6, Step 3, $16.72 x 1.6). These rates are from the Office of Personnel Management (OPM) “2019 General Schedule”, which excludes locality rates of pay.
c We have assumed that it will take 20.87 hours to review each initial performance test.
d We have assumed that 20 percent of respondents will have to repeat performace tests.
e We have assumed that it will take 0.43 hours 1.2 times per year to review each initial test notification.
f We have assumed that it will take 6.96 hours 1.2 times per year to review test results.
g We have assumed that 20 percent of sources will report excess emissions.
h We have assumed that 80 percent of sources will report no excess emissions
i Totals have been rounded to 3 significant figures. Figures may not add exatly due to rounding.