Burden Calculation Tables

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Overview

TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-SUMMARY
TBL5-YR1
TBL6-YR2
TBL7-YR3
TBL8-SUMMARY

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Sheet 1: TBL1-YR1

Table 1: Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year 1
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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year b
1. Reporting Requirements										Labor Rates ($2018)
a. Familiarization with the regulatory requirements	4	1	4	5	20	1	2	$2,619.84		$147.40	Managerial	These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
b. Compile and process data	4	4	16	0	0	0	0	$0		$117.92	Technical
c. Write reports					0	0	0	$0		$57.02	Clerical
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	2	0	0	0	0	$0
vi. Report of performance test c	10	1	10	0	0	0	0	$0
vii. Semiannual report	6	2	12	0	0	0	0	$0
viii. Excess emissions report	2	2	4	0	0	0	0	$0
ix. Startup, shutdown, malfunction report d	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					23			$2,620
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0
b. Plan activities	12	1	12	0	0	0	0	$0
c. Implement activities	12	1	12	0	0	0	0	$0
d. Maintain record system for material used	20	1	20	0	0	0	0	$0
e. Revise record systems due to SSM revisions e	8	1	8	5	40	2	4	$5,239.68
f. Become familiar with CEDRI for electronic filing of notifications and reports f	8	1	8	5	40	2	4	$5,239.68
g. Time to enter information
i. Material usage	0.5	365	182.5	0	0	0	0	$0
ii. Compliance calculation	2	12	24	0	0	0	0	$0
h. Time to train personnel	10	1	10	0	0	0	0	$0
i. Store, file, and maintain records	2	12	24	0	0	0	0	$0
j. Retrieve records/reports	1	12	12	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					92			$10,479
TOTAL LABOR BURDEN AND COST (rounded) g					115			$13,100
Total CAPITAL and O&M COST (rounded) g								$0
GRAND TOTAL (rounded) g					115			$13,100
Assumptions:
a. We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional 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% to account for the benefit packages available to those employed by private industry.
c. This ICR assumes a re-test rate of 5 percent. Because we are estimating only 1 facility needing to test as a result of these rule amendments, we are not estimating any re-tests.
d. This ICR assumes 25 percent of facilities use add-on controls and submit startup, shutdown, malfunction (SSM) reports once per year. This rule amendment will eliminate the SSM report requirement 181 days after publication of the final rule in the FR.
e. We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response.
f. Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: TBL2-YR2

Table 2: Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year 2
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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year b
1. Reporting Requirements										Labor Rates ($2018)
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0		$147.40	Managerial	These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
b. Compile and process data	4	4	16	0	0	0	0	$0		$117.92	Technical
c. Write reports					0	0	0	$0		$57.02	Clerical
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	2	0	0	0	0	$0
vi. Report of performance test c	10	1	10	0	0	0	0	$0
vii. Semiannual report	6	2	12	0	0	0	0	$0
viii. Excess emissions report	2	2	4	0	0	0	0	$0
ix. Startup, shutdown, malfunction report d	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					0			$0
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0
b. Plan activities	12	1	12	0	0	0	0	$0
c. Implement activities	12	1	12	0	0	0	0	$0
d. Maintain record system for material used	20	1	20	0	0	0	0	$0
e. Revise record systems due to SSM revisions e	8	1	8	0	0	0	0	$0
f. Time to enter information
i. Material usage	0.5	365	182.5	0	0	0	0	$0
ii. Compliance calculation	2	12	24	0	0	0	0	$0
g. Time to train personnel	10	1	10	0	0	0	0	$0
h. Store, file, and maintain records	2	12	24	0	0	0	0	$0
i. Retrieve records/reports	1	12	12	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
TOTAL LABOR BURDEN AND COST (rounded) f					0			$0
Total CAPITAL and O&M COST (rounded) f								$0
GRAND TOTAL (rounded) f					0			$0
Assumptions:
a. We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional 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% to account for the benefit packages available to those employed by private industry.
c. This ICR assumes a re-test rate of 5 percent. Because we are estimating only 1 facility needing to test as a result of these rule amendments, we are not estimating any re-tests.
d. This ICR assumes 25 percent of facilities use add-on controls and submit startup, shutdown, malfunction (SSM) reports once per year. This rule amendment will eliminate the SSM report requirement 181 days after publication of the final rule in the FR.
e. We are proposing the elimination of the Startup, Shutdown, & Malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response..
f. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: TBL3-YR3

Table 3: Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year 3
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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year b
1. Reporting Requirements										Labor Rates ($2018)
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0		$147.40	Managerial	These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
b. Compile and process data	4	4	16	0	0	0	0	$0		$117.92	Technical
c. Write reports					0	0	0	$0		$57.02	Clerical
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	2	1	2	0.1	0.2	$262
vi. Report of performance test c	10	1	10	1	10	0.5	1	$1,310
vii. Semiannual report	6	2	12	0	0	0	0	$0
viii. Excess emissions report	2	2	4	0	0	0	0	$0
ix. Startup, shutdown, malfunction report d	2	1	2	0	0	0	0	$0
x. Add-on control performance test e	30	1	30	1	30	1.5	3	$3,929.76
Subtotal for Reporting Requirements					48			$5,502
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0
b. Plan activities	12	1	12	0	0	0	0	$0
c. Implement activities	12	1	12	0	0	0	0	$0
d. Maintain record system for material used	20	1	20	0	0	0	0	$0
e. Revise record systems due to SSM revisions f	8	1	8	0	0	0	0	$0
f. Time to enter information
i. Material usage	0.5	365	182.5	0	0	0	0	$0
ii. Compliance calculation	2	12	24	0	0	0	0	$0
g. Time to train personnel	10	1	10	0	0	0	0	$0
h. Store, file, and maintain records	2	12	24	0	0	0	0	$0
i. Retrieve records/reports	1	12	12	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
TOTAL LABOR BURDEN AND COST (rounded) g					48			$5,500
Total CAPITAL and O&M COST (rounded) g								$46,900
GRAND TOTAL (rounded) g					48			$52,400
Assumptions:
a. We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional 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% to account for the benefit packages available to those employed by private industry.
c. This ICR assumes a re-test rate of 5 percent. Because we are estimating only 1 facility needing to test as a result of these rule amendments, we are not estimating any re-tests.
d. This ICR assumes 25 percent of facilities use add-on controls and submit startup, shutdown, malfunction (SSM) reports once per year. This rule amendment will eliminate the SSM report requirement 181 days after publication of the final rule in the FR.
e. Facilities that comply using emission capture systems and add-on controls are required to conduct air emissions performance testing, within 3 years of the effective date of the revised standards. Labor totals include hours for the facility to obtain the testing contractor, plan and attend the test, review the test report, and load it to ERT. One facility has three add-on controls and is not already required to perform periodic testing by the facility's state-issued permit. The proposed RTR amendments will require this facility to do performance testing every five years.
f. We are proposing the elimination of the Startup, Shutdown, & Malfunction (SSM) exemption in this rule. Costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form. Two responses with 8 hours per response..
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: TBL4-SUMMARY

Table 4 - Summary of Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	100	5	10	115	$13,100	$0	$13,100
2	0	0	0	0	$0	$0	$0
3	42	2	4	48	$5,500	$46,900	$52,400
Total	142	7	14	163	$18,600	$46,900	$65,500
Average	47	2	4.7	54	$6,200	$15,633	$21,800
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	5	15	23	92	115	8	23
2	5	0	0	0	0	-	0
3	5	3	48	0	48	16	10
Total	5	18	71	92	163	-	33
Average	5	6.0	24	31	54	9.1	11

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Sheet 5: TBL5-YR1

Table 5: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year 1
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 (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial performance test	24	1	24	0	0	0	0	$0		Labor Rates
2. Repeat performance test	24	1	24	0	0	0	0	$0		$65.71	Managerial	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
3. Report review										$48.75	Technical
a. Initial notification	8	1	8	0	0	0	0	$0		$26.38	Clerical
b. Notification of performance test c	8	1.2	10	0	0	0	0	$0
c. Notification of compliance status	8	1	8	0	0	0	0	$0
d. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
e. Notification of actual startup	8	1	8	0	0	0	0	$0
f. Report of performance test d	8	1.2	10	0	0	0	0	$0
g. Semiannual report	12	2	24	0	0	0	0	$0
h. Excess emissions report	4	2	8	0	0	0	0	$0
i. Startup, shutdown, reporte	8	1	8	0	0	0	0	$0
j. Review record systems due to SSM revisions f	2	2	4	5	20	1	2	$1,093.47
TOTAL (rounded) g					23			$1,090
Assumptions:
a.   We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional 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: 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 four hours to review the notification of the test and the test plan for each respondent.
d.   We have assumed that it will take eight hours to review the test report for each respondent.
e.   We have assumed that 25 percent of respondents will submit a startup, shutdown, malfunction report.
f. These are costs associated with evaluating new SSM record systems in year one.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: TBL6-YR2

Table 6: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year 2
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 (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial performance test	24	1	24	0	0	0	0	$0		Labor Rates
2. Repeat performance test	24	1	24	0	0	0	0	$0		$65.71	Managerial	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
3. Report review										$48.75	Technical
a. Initial notification	8	1	8	0	0	0	0	$0		$26.38	Clerical
b. Notification of performance test c	8	1.2	9.6	0	0	0	0	$0
c. Notification of compliance status	8	1	8	0	0	0	0	$0
d. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
e. Notification of actual startup	8	1	8	0	0	0	0	$0
f. Report of performance test d	8	1.2	9.6	0	0	0	0	$0
g. Semiannual report	12	2	24	0	0	0	0	$0
h. Excess emissions report	4	2	8	0	0	0	0	$0
i. Startup, shutdown, report e	8	1	8	0	0	0	0	$0
j. Review record systems due to SSM revisions f	2	2	4	0	0	0	0	$0
TOTAL (rounded) g					0			$0
Assumptions:
a.   We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional 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: 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 four hours to review the notification of the test and the test plan for each respondent.
d.   We have assumed that it will take eight hours to review the test report for each respondent.
e.   We have assumed that 25 percent of respondents will submit a startup, shutdown, malfunction report.
f. These are costs associated with evaluating new SSM record systems in year one.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: TBL7-YR3

Table 7: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year 3
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 (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial performance test	24	1	24	1	24	1.2	2.4	$1,312		Labor Rates
2. Repeat performance test	24	1	24	0	0	0	0	$0		$65.71	Managerial	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
3. Report review										$48.75	Technical
a. Initial notification	8	1	8	0	0	0	0	$0		$26.38	Clerical
b. Notification of performance test c	8	1	8	1	8	0.4	0.8	$437.39
c. Notification of compliance status	8	1	8	0	0	0	0	$0
d. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
e. Notification of actual startup	8	1	8	0	0	0	0	$0
f. Report of performance test d	8	1	8	1	8	0.4	0.8	$437.39
g. Semiannual report	12	2	24	0	0	0	0	$0
h. Excess emissions report	4	2	8	0	0	0	0	$0
i. Startup, shutdown, reporte	8	1	8	0	0	0	0	$0
j. Review record systems due to SSM revisions f	2	2	4	0	0	0	0	$0
TOTAL (rounded) g					46			$2,190
Assumptions:
a.   We have assumed that the average number of respondents that will be subject to the rule will be 5 existing sources. There will be no additional 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: 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 four hours to review the notification of the test and the test plan for each respondent.
d.   We have assumed that it will take eight hours to review the test report for each respondent.
e.   We have assumed that 25 percent of respondents will submit a startup, shutdown, malfunction report.
f. These are costs associated with evaluating new SSM record systems in year one.
g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: TBL8-SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost - NESHAP for Surface Coating of Metal Cans (40 CFR Part 63, Subpart KKKK) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	20	1	2	23	$1,090	$0	$1,090
2	0	0	0	0	$0	$0	$0
3	40	2	4	46	$2,190	$0	$2,190
Total	60	3.0	6.0	69	$3,280	$0	$3,280
Average	20.0	1.0	2.0	23.0	$1,090	$0	$1,090
Year	Number of Responses	Total Hours
1	10	23
2	0	0
3	2	46
Total	12	69
Average	4.0	23.0
Average annual hours per respondent:			5.8