Burden Calculations

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Overview

TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-SUMMARY
TBL5-YR1
TBL6-YR2
TBL7-YR3
TBL8-SUMMARY
Capital and O&M

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Sheet 1: TBL1-YR1

Table 1: Annual Respondent Burden and Cost – NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year 1
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences per year	(C) Person hrs per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Reporting requirements										Labor Rates:
a. Familiarization with the regulatory requirements	4	1	4	125	500	25	50	$65,496.00		Management	$147.40
b. Process/review information	4	4	16	0	0	0	0	$0		Technical	$117.92
c. Required activities										Clerical	$57.02
i. Add-on control performance test c	30	1	30	0	0	0	0	$0
ii. Repeat add-on control performance test c	30	1	30	0	0	0	0	$0
d. Write reports
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 initial performance test/add-on control performance test c,d	2	1	2	0	0	0	0	$0
vi. Report of initial performance test/add-on control performance test c,d	10	1	10	0	0	0	0	$0
vii. Semiannual report e	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 f	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					575			$65,496
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	See 1.a.
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. Time to enter information
i. Material usage g	0.5	365	182.5	0	0	0	0	$0
ii. Compliance calculation h	2	12	24	0	0	0	0	$0
f. Time to train personnel	10	1	10	0	0	0	0	$0
g. Store, file, and maintain records i	2	12	24	0	0	0	0	$0
h. Retrieve records/reports j	1	12	12	0	0	0	0	$0
i. Revise record systems due to SSM revisions k	8	1	8	125	1,000	50	100	$130,992.00
j. Become familiar with CEDRI for electronic filing of notifications and reports l	8	1	8	125	1,000	50	100	$130,992.00
Subtotal for Recordkeeping Requirements					2,300			$261,984
Total Labor Burden and Cost (rounded) m					2,880			$327,000
Total Capital and O&M Cost (rounded) m								$0
Grand Total (rounded) m								$327,000
Assumptions:
a We estimate that 125 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.
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 The performance test requirement will affect 3 facilities with add-on controls in the third year. The emission units with add-on controls at these 3 facilities do not already have a testing requirement in their permits. We assume a 5% failure and re-test rate (3 x 0.05 = 0.15). Since the fraction of re-tests (0.15) rounds down to zero, we assume no re-tests will be done.
d New sources have an initial testing requirement, but we assume no new sources will become subject during the three-year period of this ICR.
e We assume that each respondent will take 6 hours twice per year to write the semiannual report.
f It is estimated that 25 percent of facilities using add-on controls submit startup, shutdown, and malfunction report once per year.
g We assumed that each respondent will take 0.5 hours each day to enter daily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating.
h We have assumed that each respondent will take 2 hours once per month to enter compliance calculations.
i We have assumed that each respondent will take 2 hours once per month to store, file and maintain records.
j We have assumed that each respondent will take 1 hour once per month to retrieve records/reports.
k We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one.
l Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
m 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 Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year 2
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences per year	(C) Person hrs per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Reporting requirements										Labor Rates:
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0		Management	$147.40
b. Process/review information	4	4	16	0	0	0	0	$0		Technical	$117.92
c. Required activities										Clerical	$57.02
i. Add-on control performance test c	30	1	30	0	0	0	0	$0
ii. Repeat add-on control performance test c	30	1	30	0	0	0	0	$0
d. Write reports
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 initial performance test/add-on control performance test c,d	2	1	2	0	0	0	0	$0
vi. Report of initial performance test/add-on control performance test c,d	10	1	10	0	0	0	0	$0
vii. Semiannual report e	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 f	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					0			$0
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	See 1.a.
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. Time to enter information
i. Material usage g	0.5	365	182.5	0	0	0	0	$0
ii. Compliance calculation h	2	12	24	0	0	0	0	$0
f. Time to train personnel	10	1	10	0	0	0	0	$0
g. Store, file, and maintain records i	2	12	24	0	0	0	0	$0
h. Retrieve records/reports j	1	12	12	0	0	0	0	$0
i. Revise record systems due to SSM revisions k	8	1	8	0	0	0	0	$0
j. Become familiar with CEDRI for electronic filing of notifications and reports l	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Cost (rounded) m					0			$0
Total Capital and O&M Cost (rounded) m								$0
Grand Total (rounded) m								$0
Assumptions:
a We estimate that 125 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.
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 The performance test requirement will affect 3 facilities with add-on controls in the third year. The emission units with add-on controls at these 3 facilities do not already have a testing requirement in their permits. We assume a 5% failure and re-test rate (3 x 0.05 = 0.15). Since the fraction of re-tests (0.15) rounds down to zero, we assume no re-tests will be done.
d New sources have an initial testing requirement, but we assume no new sources will become subject during the three-year period of this ICR.
e We assume that each respondent will take 6 hours twice per year to write the semiannual report.
f It is estimated that 25 percent of facilities using add-on controls submit startup, shutdown, and malfunction report once per year.
g We assumed that each respondent will take 0.5 hours each day to enter daily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating.
h We have assumed that each respondent will take 2 hours once per month to enter compliance calculations.
i We have assumed that each respondent will take 2 hours once per month to store, file and maintain records.
j We have assumed that each respondent will take 1 hour once per month to retrieve records/reports.
k We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one.
l Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
m 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 Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year 3
Burden Item	(A) Person hours per occurrence	(B) Number of occurrences per year	(C) Person hrs per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hrs per year (E=CxD)	(F) Manage-ment person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Reporting requirements										Labor Rates:
a. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0		Management	$147.40
b. Process/review information	4	4	16	0	0	0	0	$0		Technical	$117.92
c. Required activities										Clerical	$57.02
i. Add-on control performance test c	30	1	30	3	90	4.5	9.0	$11,789.28
ii. Repeat add-on control performance test c	30	1	30	0	0	0	0	$0
d. Write reports
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 initial performance test/add-on control performance test c,d	2	1	2	3	6	0.3	0.6	$785.95
vi. Report of initial performance test/add-on control performance test c,d	10	1	10	3	30	1.5	3.0	$3,929.76
vii. Semiannual report e	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 f	2	1	2	0	0.0	0	0	$0
Subtotal for Reporting Requirements					145			$16,505
2. Recordkeeping requirements
a. Familiarization with the regulatory requirements	See 1.a.
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. Time to enter information
i. Material usage g	0.5	365	182.5	0	0	0	0	$0
ii. Compliance calculation h	2	12	24	0	0	0	0	$0
f. Time to train personnel	10	1	10	0	0	0	0	$0
g. Store, file, and maintain records i	2	12	24	0	0	0	0	$0
h. Retrieve records/reports j	1	12	12	0	0	0	0	$0
i. Revise record systems due to SSM revisions k	8	1	8	0	0	0	0	$0
j. Become familiar with CEDRI for electronic filing of notifications and reports l	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Cost (rounded) m					145			$16,500
Total Capital and O&M Cost (rounded) m								$57,000
Grand Total (rounded) m								$73,500
Assumptions:
a We estimate that 125 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.
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 The performance test requirement will affect 3 facilities with add-on controls in the third year. The emission units with add-on controls at these 3 facilities do not already have a testing requirement in their permits. We assume a 5% failure and re-test rate (3 x 0.05 = 0.15). Since the fraction of re-tests (0.15) rounds down to zero, we assume no re-tests will be done.
d New sources have an initial testing requirement, but we assume no new sources will become subject during the three-year period of this ICR.
e We assume that each respondent will take 6 hours twice per year to write the semiannual report.
f It is estimated that 25 percent of facilities using add-on controls submit startup, shutdown, and malfunction report once per year.
g We assumed that each respondent will take 0.5 hours each day to enter daily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating.
h We have assumed that each respondent will take 2 hours once per month to enter compliance calculations.
i We have assumed that each respondent will take 2 hours once per month to store, file and maintain records.
j We have assumed that each respondent will take 1 hour once per month to retrieve records/reports.
k We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one.
l Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
m 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 Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	2,500	125	250	2,875	$327,000	$0	$327,000
2	0	0	0	0	$0	$0	$0
3	126	6	13	145	$16,500	$57,000	$73,500
Total	2,626	131	263	3,020	$344,000	$57,000	$401,000
Average	875	44	87.5	1,007	$115,000	$19,000	$134,000
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	125	375	575	2,300	2,875	8.0	23.0
2	125	0	0	0	0	-	0.0
3	125	9	145	0	145	16	1.2
Total	-	384	720	2,300	3,020	-	24.2
Average	125	128	240	767	1,007	7.9	8.1
Average annual additional costs per respondent:				$1,070
Average annual additional hours per respondent:				8.1
Average annual additional hours per response:				7.9

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Sheet 5: TBL5-YR1

Table 5: Average Annual EPA Burden and Cost - NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year 1
Burden Item	(A) EPA Person hours per occurrence	(B) Number of occurrences per year	(C) EPA Person hrs per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person hrs per year (E=CxD)	(F) Management person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Initial performance test c	24	1	24	0	0	0	0	$0		Labor Rates:
2. Repeat performance test c	24	0.05	1.2	0	0	0	0	$0		Management	$65.71
3. Report review										Technical	$48.75
a. Initial notification	8	1	8	0	0	0	0	$0		Clerical	$26.38
b. Notification of compliance status	8	1	8	0	0	0	0	$0
c. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
d. Notification of actual startup	8	1	8	0	0	0	0	$0
e. Notification of performance test/add-on control performance test d	8	1	8	0	0	0	0	$0
f. Report of performance test/add-on control performance test d	8	1	8	0	0	0	0	$0
g. Semiannual report e	12	2	24	0	0	0	0	$0
h. Excess emissions report f	4	2	8	0	0	0	0	$0
i. Startup, shutdown, malfunction report	8	1	8	0	0	0	0	$0
Total (rounded): g					0			$0
Assumptions:
a We estimate that 125 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.
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 assume it will take 24 hours to complete the initial performance test review. Assume a 5% failure and re-test rate.
d Assumes that the 3 facilities without periodic testing requirements in their permits will do performance testing of the emission units with add-on controls in year 3. We assume a 5% failure and re-test rate (3 x 0.05 = 0.15). Since the fraction of re-tests (0.15) rounds down to zero, we assume no re-tests will be done.
e We have assumed that it will take 12 hours two times per year to review the semiannual report.
f We have assumed that it will take 4 hours two times per year to review the excess emissions report.
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 Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year 2
Burden Item	(A) EPA Person hours per occurrence	(B) Number of occurrences per year	(C) EPA Person hrs per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person hrs per year (E=CxD)	(F) Management person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Initial performance test c	24	1	24	0	0	0	0	$0		Labor Rates:
2. Repeat performance test c	24	0.05	1.2	0	0	0	0	$0		Management	$65.71
3. Report review										Technical	$48.75
a. Initial notification	8	1	8	0	0	0	0	$0		Clerical	$26.38
b. Notification of compliance status	8	1	8	0	0	0	0	$0
c. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
d. Notification of actual startup	8	1	8	0	0	0	0	$0
e. Notification of performance test/add-on control performance test d	8	1	8	0	0	0	0	$0
f. Report of performance test/add-on control performance test d	8	1	8	0	0	0	0	$0
g. Semiannual report e	12	2	24	0	0	0	0	$0
h. Excess emissions report f	4	2	8	0	0	0	0	$0
i. Startup, shutdown, malfunction report	8	1	8	0	0	0	0	$0
Total (rounded): g					0			$0
Assumptions:
a We estimate that 125 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.
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 assume it will take 24 hours to complete the initial performance test review. Assume a 5% failure and re-test rate.
d Assumes that the 3 facilities without periodic testing requirements in their permits will do performance testing of the emission units with add-on controls in year 3. We assume a 5% failure and re-test rate (3 x 0.05 = 0.15). Since the fraction of re-tests (0.15) rounds down to zero, we assume no re-tests will be done.
e We have assumed that it will take 12 hours two times per year to review the semiannual report.
f We have assumed that it will take 4 hours two times per year to review the excess emissions report.
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 Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year 3
Burden Item	(A) EPA Person hours per occurrence	(B) Number of occurrences per year	(C) EPA Person hrs per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person hrs per year (E=CxD)	(F) Management person hrs per year (F=Ex0.05)	(G) Clerical person hrs per year (G=Ex0.1)	(H) Cost per year ($) b
1. Initial performance test c	24	1	24	0	0	0	0	$0		Labor Rates:
2. Repeat performance test c	24	0.05	1.2	0	0	0	0	$0		Management	$65.71
3. Report review										Technical	$48.75
a. Initial notification	8	1	8	0	0	0	0	$0		Clerical	$26.38
b. Notification of compliance status	8	1	8	0	0	0	0	$0
c. Notification of construction/reconstruction	8	1	8	0	0	0	0	$0
d. Notification of actual startup	8	1	8	0	0	0	0	$0
e. Notification of performance test/add-on control performance test d	8	1	8	3	24	1.2	2.4	$1,312.16
f. Report of performance test/add-on control performance test d	8	1	8	3	24	1.2	2.4	$1,312.16
g. Semiannual report e	12	2	24	0	0	0	0	$0
h. Excess emissions report f	4	2	8	0	0	0	0	$0
i. Startup, shutdown, malfunction report	8	1	8	0	0	0	0	$0
Total (rounded): g					55			$2,620
Assumptions:
a We estimate that 125 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.
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 assume it will take 24 hours to complete the initial performance test review. Assume a 5% failure and re-test rate.
d Assumes that the 3 facilities without periodic testing requirements in their permits will do performance testing of the emission units with add-on controls in year 3. We assume a 5% failure and re-test rate (3 x 0.05 = 0.15). Since the fraction of re-tests (0.15) rounds down to zero, we assume no re-tests will be done.
e We have assumed that it will take 12 hours two times per year to review the semiannual report.
f We have assumed that it will take 4 hours two times per year to review the excess emissions report.
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 Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	0	0	0	0	$0	$0	$0
2	0	0	0	0	$0	$0	$0
3	48	2	5	55	$2,620	$0	$2,620
Total	48	2.4	4.8	55	$2,620	$0	$2,620
Average	16.0	0.8	1.6	18	$870	$0	$870
Year	Number of Responses	Total Hours
1	0	0
2	0	0
3	6	55
Total	6	55
Average	2	18
Average annual hours per response:		9.2

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Sheet 9: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Performance Testing	Capital Startup Cost for One Performance Test	Number of Respondents Doing Testing	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)
Performance Testing	$19,000	3	$57,000	$0	0	$0
Totals (rounded)			$57,000			$0	Total	$57,000
Note: In year 3, three sources test one control device each at a cost of $19,000. We assume a 5% failure rate for the test. Since the fraction of re-tests (0.15) rounds down to zero, we assume no cost for re-tests. Totals have been rounded to three significant figures.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	125	0	0	125
2	0	125	0	0	125
3	0	125	0	0	125
Average	0	125	0	0	125
1 New respondents include sources with constructed, reconstructed and modified affected facilities.