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 Coil (40 CFR Part 63, Subpart SSSS) (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		Labor Rates
1. Applications	N/A									$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
2. Survey and Studies	N/A									$117.92	Technical
3. Reporting requirements										$57.02	Clerical
A. Familiarization with the regulatory requirements a	4	1	4	48	192	9.6	19.2	$25,150.46
B. Required activities
Initial oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Repeat oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Initial capture performance test, or review design criteria to ensure capture system meets design criteria for a permanent total enclsosure (PTE) c, d	8	0.07	0.56	0	0	0	0	$0
Repeat capture performance test c, d	8	0.07	0.56	0	0	0	0	$0
Add-on control performance test e	30	1	30	0	0	0	0	$0
Repeat add-on control performance test f	30	1	30	0	0	0	0	$0
Emission rate limit compliance determination	16	12	192	0	0	0	0	$0
Startup, shutdown, malfunction plan	32	1	32	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information g	60	1	60	0	0	0	0	$0
E. Write Report
Initial notification	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Performance test notification c, e, f	2	1	2	0	0	0	0	$0
Performance test report c, e, f	10	1	10	0	0	0	0	$0
Semiannual report of exceedances h	16	2	32	0	0	0	0	$0
Semiannual report of no exceedances i, j	8	2	16	0	0	0	0	$0
Startup, shutdown, malfunction report k	8	2	16	0	0	0	0	$0
Subtotal for Reporting Requirements					221			$25,150
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 4B
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system	N/A
E. Revise record systems due to SSM revisions l	8	1	8	48	384	19.2	38.4	$50,300.93
F. Become familiar with CEDRI for electronic filing of notifications and reports m	8	1	8	48	384	19.2	38.4	$50,300.93
G. Time to enter records of all information required by standards n	4	52	208	0	0	0	0	$0
H. Time to train personnel	N/A
I. Time to adjust existing ways to comply with previously applicable requirements	N/A
J. Time to transmit or disclose information o	0.25	2	0.5	0	0	0	0	$0
K. Time for audits	N/A
Subtotal for Recordkeeping Requirements					883			$100,602
Total Labor Burden and Cost (rounded) p					1,100			$126,000
Total Capital and O&M Cost (rounded) p								$0
GRAND TOTAL (rounded) p					1,100			$126,000
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. This ICR assumes each respondent will incur a burden to re-familiarize themselves with the regulatory requirements each year.
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 is a one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting. The one-time startup costs were annualized over the 15-year life of control equipment at 7 percent interest. The number of occurrences per respondent per year is annualized over the 15 year life of the control equipment. Because there are no new sources, no performance tests are expected to occur. It is assumed that the facility would contract out the performance testing costs, but some labor hours from facility staff would be involved with coordinating and observing the test and reviewing the results.
d We have assumed that emission capture systems meet the design criteria for a permanent total enclosure in EPA Method 204, so that capture efficiency does not need to be measured.
e Facilities that comply using emission capture systems and add-on controls 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. A permit review revealed that, of the 48 sources subject to Subpart SSSS, 30 add on control devices at 21 sources do not already have a permit testing requirement. 21 sources undergo testing of their control devices.
f It is assumed that 5 percent of respondents will have to repeat performance tests. (30 x 0.05 = 1.5 , rounded up to 2) 21 sources submit notifications and test reports, and 2 additional sources submit re-test notification and test reports, for a total of 23 notifications and 23 test reports.
g Based on comments we received from industry consultation, 60 hrs per respondent is required to gather and evaluate information in preparation of semiannual reports
h We have assumed that exceedances are reported semiannually. We have assumed that 10 percent of respondents will report exceedances (48 x 0.1 = 4.8, or 5 respondents, when rounded).
i Reports indicating no exceedances are required semiannually.
j We have assumed that 90 percent of respondents will report no exceedances (48 x 0.9 = 43.2, or 43 respondents, when rounded).
k We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction report semiannually (48 x 0.1 = 4.8, or 5 respondents, when rounded).
l 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.
m Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
n We have assumed that all information is entered on a weekly basis.
o We have assumed that each of the 48 respondents will take 15 minutes to transmit or disclose information twice a year.
p 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 1: Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Coil (40 CFR Part 63, Subpart SSSS) (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		Labor Rates
1. Applications	N/A									$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
2. Survey and Studies	N/A									$117.92	Technical
3. Reporting requirements										$57.02	Clerical
A. Familiarization with the regulatory requirements a	4	1	4	0	0	0	0	$0
B. Required activities
Initial oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Repeat oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Initial capture performance test, or review design criteria to ensure capture system meets design criteria for a permanent total enclsosure (PTE) c, d	8	0.07	0.56	0	0	0	0	$0
Repeat capture performance test c, d	8	0.07	0.56	0	0	0	0	$0
Add-on control performance test e	30	1	30	0	0	0	0	$0
Repeat add-on control performance test f	30	1	30	0	0	0	0	$0
Emission rate limit compliance determination	16	12	192	0	0	0	0	$0
Startup, shutdown, malfunction plan	32	1	32	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information g	60	1	60	0	0	0	0	$0
E. Write Report
Initial notification	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Performance test notification c, e, f	2	1	2	0	0	0	0	$0
Performance test report c, e, f	10	1	10	0	0	0	0	$0
Semiannual report of exceedances h	16	2	32	0	0	0	0	$0
Semiannual report of no exceedances i, j	8	2	16	0	0	0	0	$0
Startup, shutdown, malfunction report k	8	2	16	0	0	0	0	$0
Subtotal for Reporting Requirements					0			$0
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 4B
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system	N/A
E. Revise record systems due to SSM revisions l	8	1	8	0	0	0	0	$0
F. Become familiar with CEDRI for electronic filing of notifications and reports m	8	1	8	0	0	0	0	$0
G. Time to enter records of all information required by standards n	4	52	208	0	0	0	0	$0
H. Time to train personnel	N/A
I. Time to adjust existing ways to comply with previously applicable requirements	N/A
J. Time to transmit or disclose information o	0.25	2	0.5	0	0	0	0	$0
K. Time for audits	N/A
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Cost (rounded) p					0			$0
Total Capital and O&M Cost (rounded) p								$0
GRAND TOTAL (rounded) p					0			$0
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. This ICR assumes each respondent will incur a burden to re-familiarize themselves with the regulatory requirements each year.
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 is a one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting. The one-time startup costs were annualized over the 15-year life of control equipment at 7 percent interest. The number of occurrences per respondent per year is annualized over the 15 year life of the control equipment. Because there are no new sources, no performance tests are expected to occur. It is assumed that the facility would contract out the performance testing costs, but some labor hours from facility staff would be involved with coordinating and observing the test and reviewing the results.
d We have assumed that emission capture systems meet the design criteria for a permanent total enclosure in EPA Method 204, so that capture efficiency does not need to be measured.
e Facilities that comply using emission capture systems and add-on controls 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. A permit review revealed that, of the 48 sources subject to Subpart SSSS, 30 add on control devices at 21 sources do not already have a permit testing requirement. 21 sources undergo testing of their control devices.
f It is assumed that 5 percent of respondents will have to repeat performance tests. (30 x 0.05 = 1.5 , rounded up to 2) 21 sources submit notifications and test reports, and 2 additional sources submit re-test notification and test reports, for a total of 23 notifications and 23 test reports.
g Based on comments we received from industry consultation, 60 hrs per respondent is required to gather and evaluate information in preparation of semiannual reports
h We have assumed that exceedances are reported semiannually. We have assumed that 10 percent of respondents will report exceedances (48 x 0.1 = 4.8, or 5 respondents, when rounded).
i Reports indicating no exceedances are required semiannually.
j We have assumed that 90 percent of respondents will report no exceedances (48 x 0.9 = 43.2, or 43 respondents, when rounded).
k We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction report semiannually (48 x 0.1 = 4.8, or 5 respondents, when rounded).
l 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.
m Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
n We have assumed that all information is entered on a weekly basis.
o We have assumed that each of the 48 respondents will take 15 minutes to transmit or disclose information twice a year.
p 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 1: Annual Respondent Burden and Cost - NESHAP for Surface Coating of Metal Coil (40 CFR Part 63, Subpart SSSS) (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		Labor Rates
1. Applications	N/A									$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
2. Survey and Studies	N/A									$117.92	Technical
3. Reporting requirements										$57.02	Clerical
A. Familiarization with the regulatory requirements a	4	1	4	0	0	0	0	$0
B. Required activities
Initial oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Repeat oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Initial capture performance test, or review design criteria to ensure capture system meets design criteria for a permanent total enclsosure (PTE) c, d	8	0.07	0.56	0	0	0	0	$0
Repeat capture performance test c, d	8	0.07	0.56	0	0	0	0	$0
Add-on control performance test e	30	1	30	21	630	31.5	63	$82,524.96
Repeat add-on control performance test f	30	1	30	2	60	3	6	$7,859.52
Emission rate limit compliance determination	16	12	192	0	0	0	0	$0
Startup, shutdown, malfunction plan	32	1	32	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information g	60	1	60	0	0	0	0	$0
E. Write Report
Initial notification	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Performance test notification c, e, f	2	1	2	23	46	2.3	4.6	$6,026
Performance test report c, e , f	10	1	10	23	230	11.5	23	$30,128
Semiannual report of exceedances h	16	2	32	0	0	0	0	$0
Semiannual report of no exceedances i, j	8	2	16	0	0	0	0	$0
Startup, shutdown, malfunction report k	8	2	16	0	0	0	0	$0
Subtotal for Reporting Requirements					1,111			$126,538
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 4B
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system	N/A
E. Revise record systems due to SSM revisions l	8	1	8	0	0	0	0	$0
F. Become familiar with CEDRI for electronic filing of notifications and reports m	8	1	8	0	0	0	0	$0
G. Time to enter records of all information required by standards n	4	52	208	0	0	0	0	$0
H. Time to train personnel	N/A
I. Time to adjust existing ways to comply with previously applicable requirements	N/A
J. Time to transmit or disclose information o	0.25	2	0.5	0	0	0	0	$0
K. Time for audits	N/A
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Cost (rounded) p					1,100			$130,000
Total Capital and O&M Cost (rounded) p								$558,000
GRAND TOTAL (rounded) p					1,100			$690,000
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. This ICR assumes each respondent will incur a burden to re-familiarize themselves with the regulatory requirements each year.
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 is a one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting. The one-time startup costs were annualized over the 15-year life of control equipment at 7 percent interest. The number of occurrences per respondent per year is annualized over the 15 year life of the control equipment. Because there are no new sources, no performance tests are expected to occur. It is assumed that the facility would contract out the performance testing costs, but some labor hours from facility staff would be involved with coordinating and observing the test and reviewing the results.
d We have assumed that emission capture systems meet the design criteria for a permanent total enclosure in EPA Method 204, so that capture efficiency does not need to be measured.
e Facilities that comply using emission capture systems and add-on controls 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. A permit review revealed that, of the 48 sources subject to Subpart SSSS, 30 add on control devices at 21 sources do not already have a permit testing requirement. 21 sources undergo testing of their control devices.
f It is assumed that 5 percent of respondents will have to repeat performance tests. (30 x 0.05 = 1.5, rounded up to 2) 21 sources submit notifications and test reports, and 2 additional sources submit re-test notification and test reports, for a total of 23 notifications and 23 test reports.
g Based on comments we received from industry consultation, 60 hrs per respondent is required to gather and evaluate information in preparation of semiannual reports
h We have assumed that exceedances are reported semiannually. We have assumed that 10 percent of respondents will report exceedances (48 x 0.1 = 4.8, or 5 respondents, when rounded).
i Reports indicating no exceedances are required semiannually.
j We have assumed that 90 percent of respondents will report no exceedances (48 x 0.9 = 43.2, or 43 respondents, when rounded).
k We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction report semiannually (48 x 0.1 = 4.8, or 5 respondents, when rounded).
l 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.
m Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
n We have assumed that all information is entered on a weekly basis.
o We have assumed that each of the 48 respondents will take 15 minutes to transmit or disclose information twice a year.
p 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 Coil (40 CFR Part 63, Subpart SSSS) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	960	48	96	1,104	$126,000	$0	$126,000
2	0	0	0	0	$0	$0	$0
3	966	48	97	1,111	$130,000	$558,000	$688,000
Total	1,926	96	193	2,215	$256,000	$558,000	$814,000
Average	642	32	64.2	738	$85,000	$186,000	$271,000
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	48	144	221	883	1,104	8.0	23
2	48	0	0	0	0	-	0
3	48	69	1,111	0	1,111	16	23
Total	-	213	1,332	883	2,215	-	46
Average	48	71	444	294	738	10.4	15
Average annual additional costs per respondent:				$5,650

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Sheet 5: TBL5-YR1

Table 2: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Coil (40 CFR Part 63, Subpart SSSS) (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
Initial performance test a	48	0	0	0	0	0	0	$0		Labor Rates
Repeat performance test-retesting preparation	4	0	0	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.
Repeat performance-retesting	48	0	0	0	0	0	0	$0		48.75	Technical
Excess emissions enforcement activities	120	1	120	0	0	0	0	$0		26.38	Clerical
Review reports
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of compliance status	2	1	2	0	0	0	0	$0
Notification of peformance test c	4	1	4	0	0	0	0	$0
Review of initial performance test report d	8	1	8	0	0	0	0	$0
Review of repeat performance test report d	8	1	8	0	0	0	0	$0
Semiannual report of excess emissions e, f	8	2	16	0	0	0	0	$0
Semiannual report of no excess emissions g, h	2	2	4	0	0	0	0	$0
Review of NESHAP waiver application	N/A
Review startup, shutdown, malfunction report i	2	2	4	0	0	0	0	$0
Review record systems due to SSM revisions j	2	2	4	48	192	9.6	19.2	$10,497.31
TOTAL (rounded) k					221			$10,500
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Because there are no new sources, no initial performance tests for new sources are expected to occur.
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 It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.
d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. 21 facilities utilize 30 add-on VOC/HAP control devices and would require testing. Assuming a 5% failure rate, two control devices would need to be re-tested. (30 x 0.05 = 1.5, rounded up to 2)
e It is assumed that 10 percent of respondents will report excess emissions (48 x 0.1 = 4.8, or 5 respondents, when rounded).
f It is assumed that reports of excess emissions are required semiannually.
g We have assumed that 90 percent of respondents will report no excess emissions (48 x 0.9 = 43.2, or 43 respondents, when rounded).
h It is assumed that reports of no excess emissions are required semiannually.
i We have assumed that 10 percent of respondents will submit startup, shutdown, malfunction reports to be reviewed (48 x 0.1 = 4.8, or 5 respondents, when rounded).
j These are costs associated with evaluating new SSM record systems in year one.
k 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 2: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Coil (40 CFR Part 63, Subpart SSSS) (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
Initial performance test a	48	0	0	0	0	0	0	$0		Labor Rates
Repeat performance test-retesting preparation	4	0	0	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.
Repeat performance-retesting	48	0	0	0	0	0	0	$0		48.75	Technical
Excess emissions enforcement activities	120	1	120	0	0	0	0	$0		26.38	Clerical
Review reports
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of compliance status	2	1	2	0	0	0	0	$0
Notification of peformance test c	4	1	4	0	0	0	0	$0
Review of initial performance test report d	8	1	8	0	0	0	0	$0
Review of repeat performance test report d	8	1	8	0	0	0	0	$0
Semiannual report of excess emissions e, f	8	2	16	0	0	0	0	$0
Semiannual report of no excess emissions g, h	2	2	4	0	0	0	0	$0
Review of NESHAP waiver application	N/A
Review startup, shutdown, malfunction report i	2	2	4	0	0	0	0	$0
Review record systems due to SSM revisions j	2	2	4	0	0	0	0	$0
TOTAL (rounded) k					0			$0
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Because there are no new sources, no initial performance tests for new sources are expected to occur.
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 It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.
d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. 21 facilities utilize 30 add-on VOC/HAP control devices and would require testing. Assuming a 5% failure rate, two control devices would need to be re-tested. (30 x 0.05 = 1.5, rounded up to 2)
e It is assumed that 10 percent of respondents will report excess emissions (48 x 0.1 = 4.8, or 5 respondents, when rounded).
f It is assumed that reports of excess emissions are required semiannually.
g We have assumed that 90 percent of respondents will report no excess emissions (48 x 0.9 = 43.2, or 43 respondents, when rounded).
h It is assumed that reports of no excess emissions are required semiannually.
i We have assumed that 10 percent of respondents will submit startup, shutdown, malfunction reports to be reviewed (48 x 0.1 = 4.8, or 5 respondents, when rounded).
j These are costs associated with evaluating new SSM record systems in year one.
k 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 2: Average Annual EPA Burden and Cost - NESHAP for Surface Coating of Metal Coil (40 CFR Part 63, Subpart SSSS) (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
Initial performance test a	48	0	0	0	0	0	0	$0		Labor Rates
Repeat performance test-retesting preparation	4	0	0	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.
Repeat performance-retesting	48	0	0	0	0	0	0	$0		48.75	Technical
Excess emissions enforcement activities	120	1	120	0	0	0	0	$0		26.38	Clerical
Review reports
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of compliance status	2	1	2	0	0	0	0	$0
Notification of peformance test c	4	1	4	23	92	4.6	9.2	$5,029.96
Review of initial performance test report d	8	1	8	21	168	8.4	16.8	$9,185.15
Review of repeat performance test report d	8	1	8	2	16	0.8	1.6	$874.78
Semiannual report of excess emissions e, f	8	2	16	0	0	0	0	$0
Semiannual report of no excess emissions g, h	2	2	4	0	0	0	0	$0
Review of NESHAP waiver application	N/A
Review startup, shutdown, malfunction report i	2	2	4	0	0	0	0	$0
Review record systems due to SSM revisions j	2	2	4	0	0	0	0	$0
TOTAL (rounded) k					317			$15,100
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Because there are no new sources, no initial performance tests for new sources are expected to occur.
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 It is assumed that it will take four hours to review the notification of the test and the test plan for each respondent.
d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing, within 3 years of the effective date of the revised standards. 21 facilities utilize 30 add-on VOC/HAP control devices and would require testing. Assuming a 5% failure rate, two control devices would need to be re-tested. (30 x 0.05 = 1.5, rounded up to 2)
e It is assumed that 10 percent of respondents will report excess emissions (48 x 0.1 = 4.8, or 5 respondents, when rounded).
f It is assumed that reports of excess emissions are required semiannually.
g We have assumed that 90 percent of respondents will report no excess emissions (48 x 0.9 = 43.2, or 43 respondents, when rounded).
h It is assumed that reports of no excess emissions are required semiannually.
i We have assumed that 10 percent of respondents will submit startup, shutdown, malfunction reports to be reviewed (48 x 0.1 = 4.8, or 5 respondents, when rounded).
j These are costs associated with evaluating new SSM record systems in year one.
k 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 Coil (40 CFR Part 63, Subpart SSSS) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	192	10	19	221	$10,500	$0	$10,500
2	0	0	0	0	$0	$0	$0
3	276	14	28	317	$15,100	$0	$15,100
Total	468	23.4	46.8	538	$25,600	$0	$25,600
Average	156.0	7.8	15.6	179	$8,530	$0	$8,530
Year	Number of Responses	Total Hours
1	96	221
2	0	0
3	46	317
Total	142	538
Average	47.3	179
Average annual hours per respondent:			3.8