Burden Calculation Table

1712t11.xlsx

NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR part 63, subpart II) (Renewal)

Burden Calculation Table

OMB: 2060-0330

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Overview

Table 1a
Table 1b
table 1c
Table 2


Sheet 1: Table 1a

Table 1a: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal)(Private Sector)












121.46 148.45 60.23
Burden item (A) Person hours per occurrence (B) No. of occurrences per respondent per year (C) Person hours per respondent per year (C=AxB) (D) Respondents per year a (E) Technical person- hours per year (E=CxD) (F) Management person hours per year (Ex0.05) (G) Clerical person hours per year (Ex0.1) (H) Total Cost per year b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting Requirements







a. Familiarization with Regulatory Requirements 1 1 1 50 50 2.5 5 $6,745.28
b. Required Activities See 3e






c. Create Information See 3e






d. Gather Existing Information See 3e






e. Write Report







Notification of Construction/Reconstructionc 2 1 2 0 0 0 0 $0
Notification of Demonstration of CMSc N/A






Report of Performance Testc N/A






Initial Notification and Implementationc 14 1 14 0 0 0 0 $0
Semiannual Notification of Compliance Status 8 2 16 50 800 40 80 $107,924.40
Subtotal for Reporting Requirements



978 $114,670
4. Recordkeeping Requirements







a. Familiarization with Regulatory Requirements See 3a






b. Plan Activities N/A






c. Implement Activities 8 50 400 50 20,000 1,000 2,000 $2,698,110.00
d. Develop Record Systemc 8 1 8 0 0 0 0 $0
e. Train Personnel 28 1 28 50 1,400 70 140 $188,867.70
g. Audits N/A






Subtotal for Recordkeeping Requirements



24,610 $2,886,978
TOTAL LABOR BURDEN AND COST (rounded)d



25,600 $3,000,000
TOTAL CAPITAL AND O&M COST (rounded)d




$0
GRAND TOTAL (rounded)d



25,600 $3,000,000









Assumptions:







a Number of affected facilities per year is 56. We assume 90 percent of sources are in the private sector, or approximately 50 respondents. We have assumed that there will be no new growth over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates: $148.45 per hour for Executive, Administrative, and Managerial labor; $121.46 per hour for Technical labor, and $60.23 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2020, 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 this is a one-time-only cost.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 2: Table 1b

Table 1b: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal)(Public Sector)












50.72 68.37 27.46
Burden item (A) Person hours per occurrence (B) No. of occurrences per respondent per year (C) Person hours per respondent per year (C=AxB) (D) Respondents per year a (E) Technical person- hours per year (E=CxD) (F) Management person hours per year (Ex0.05) (G) Clerical person hours per year (Ex0.1) (H) Total Cost per year b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting Requirements







a. Familiarization with Regulatory Requirements 1 1 1 6 6 0.3 0.6 $341.31
b. Required Activities See 3e






c. Create Information See 3e






d. Gather Existing Information See 3e






e. Write Report







Notification of Construction/Reconstructionc 2 1 2 0 0 0 0 $0
Notification of Demonstration of CMSc N/A






Report of Performance Testc N/A






Initial Notification and Implementationc 14 1 14 0 0 0 0 $0
Semiannual Notification of Compliance Status 8 2 16 6 96 4.8 9.6 $5,460.91
Subtotal for Reporting Requirements



117 $5,802
4. Recordkeeping Requirements







a. Familiarization with Regulatory Requirements See 3a






b. Plan Activities N/A






c. Implement Activities 8 50 400 6 2,400 120 240 $136,522.80
d. Develop Record Systemc 8 1 8 0 0 0 0 $0
e. Train Personnel 28 1 28 6 168 8.4 16.8 $9,556.60
g. Audits N/A






Subtotal for Recordkeeping Requirements



2,953 $146,079
TOTAL LABOR BURDEN AND COST (rounded)d



3,100 $150,000
TOTAL CAPITAL AND O&M COST (rounded)d




$0
GRAND TOTAL (rounded)d



3,100 $150,000









Assumptions:







a Number of affected facilities per year is 56. We assume 10 percent of sources are in the public sector, or approximately 6 respondents. We have assumed that there will be no new growth over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 for Managerial (GS-13, Step 5, $42.73 x 1.6), $50.72 for Technical (GS-12, Step 1, $31.70 x 1.6) and $27.46 Clerical (GS-6, Step 3, $17.16 x 1.6). These rates are from the Office of Personnel Management (OPM) "2020 General Schedule" which excludes locality rates of pay.
c We have assumed this is a one-time-only cost.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 3: table 1c

Table 1c: Annual Respondent Burden and Cost Breakdown by Affected Sector– NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal)





Affected Sector Number of Responses Labor Hours Labor Cost Capital and O&M Cost
Reporting Recordkeeping Total
Private 50 978 24,610 25,600 $3,000,000 $0
Public (Federal) 6 117 2,953 3,070 $150,000 $0
Total a 56 1,100 28,700 $3,200,000 $0
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

















256 hrs/response

Sheet 4: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal)












50.72 68.37 27.46
Activity (A) EPA person-hours per occurrence (B) No. of occurrences per plant per year (C) EPA person hours per plant per year (AxB) (D) Plants per year a (E) Technical person-hours per year (CxD) (F) Management person-hours per year (Ex0.05) (G) Clerical person-hours per year (Ex0.1) (H) Cost, $ b
Initial Performance Testsc N/A






Repeat Performance Test N/A






Report Review







Notification of Constructionc 2 1 2 0 0 0 0 $0
Review of Initial Notification and Implementation Planc 2 1 2 0 0 0 0 $0
Review of Semiannual Notification of Compliance Status 2 2 4 56 224 11.2 22.4 $12,742
TOTAL ANNUAL BURDEN AND COST (rounded)d



258 $12,700









Assumptions:







a Number of affected facilities per year is 56.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 for Managerial (GS-13, Step 5, $42.73 x 1.6), $50.72 for Technical (GS-12, Step 1, $31.70 x 1.6) and $27.46 Clerical (GS-6, Step 3, $17.16 x 1.6). These rates are from the Office of Personnel Management (OPM) "2020 General Schedule" which excludes locality rates of pay.
c We have assumed this is a one-time-only cost.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







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