Burden Calculation Tables

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Overview

Table 1a
Table 1b
Table 1c
Table 2

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Sheet 1: Table 1a

Table 1a: Annual Respondent Burden and Cost for Private Facilities – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal)
Burden Item	A	B	C	D	E	F	G	H		Note to OAQPS: Previous ICRs indicated that at least one facility is owned by the federal government. This was confirmed by reviewing the 2014 RTR facility list. The burden has been separated into into two tables to account for private labor rates for 11 facilities (mix of slabstock and molded/rebond sources), and federal labor rates for the 1 facility, which appears to be a molded/rebond source.
	Person Hours Per Occurrence	Number 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 (E x 0.05)	Clerical Person Hours Per Year (E x 0.10)	Total Costs Per Year ($) b
1. Applications	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A		Labor Rates
2. Survey and studies	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A		Management	$153.55
3. Acquisition, Installation, and Utilization of Tech. & Systems	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A		Technical	$122.20
4. Reporting Requirements										Clerical	$61.51
A. Familiarization with instructions	1	1	1	11	11	0.55	1.1	$1,496.31
B. Required Activities
Monitoring of Emissions Operations, Slabstock Facilities - Storage Tank Measurements c	1	12	12	6	72	3.6	7.2	$9,794.05
C. Create Information	Included in 4B and 5E
D. Gather Existing Information	Included in 4B and 5E
E. Write Report
Initial notification d	2	1	2	0	0	0	0	$0
Notification of modification/reconstruction d	2	1	2	0	0	0	0	$0
Notification of Special Compliance Requirements e	2	1	2	0	0	0	0	$0
Pre-compliance Report d	4	1	4	0	0	0	0	$0
Notification of Compliance Status d	16	1	16	0	0	0	0	$0
Semiannual Reports f	4	2	8	6	48	2.4	4.8	$6,529.37
Annual Compliance Certifications g	2	1	2	11	22	1.1	2.2	$2,992.63
Subtotal for Reporting Requirements	34	21	49		176			$20,812
5. Recordkeeping Requirements
A. Familiarization with instructions	Included in 4A
B. Plan activities	Included in 4B
C. Implement activities	Included in 4B
D. Develop record system	40	1	40	0	0	0	0	$0
E. Time to enter information: records of monitoring and operations a
Slabstock producers	8	12	96	6	576	28.8	57.6	$78,352.42
Molded/rebond facilities	4	1	4	5	20	1	2	$2,720.57
F. Train personnel	40	1	40	0	0	0	0	$0
G. Audits	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Subtotal for Recordkeeping Requirements	92	15	180		685			$81,073
TOTAL LABOR BURDEN AND COSTS (rounded) h					861			$101,900
TOTAL CAPITAL AND O&M COST (rounded) h								$0
GRAND TOTAL (rounded) h								$101,900
Assumptions:
a We have assumed that there are approximately 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 existing foam producers (i.e., respondents) that are major sources and subject to the NESHAP subpart III. We have further assumed that there will be no new foam producers commencing operations over the period of this ICR. Therefore, the average number of respondents per year for this ICR is estimated to be 12 and 11 of these facilities are private sector facilities.
b This ICR uses the following labor rates: Managerial $153.55 ($73.12+ 110%); Technical $122.20 ($58.19 + 110%); and Clerical $61.51 ($29.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c Molded/rebond foam producers only have recordkeeping and reporting requirements.
d We have assumed that all existing sources are in compliance with the initial rule requirements and no reconstructions will occur during this ICR renewal period.
e We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed.
f Only slabstock foam producers are required to submit semiannual reports.
g All respondents are required to submit annual compliance certifications.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 1b

Table 1b: Annual Respondent Burden and Cost for Federal Facilities – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal)
										Note to OAQPS: Previous ICRs indicated that at least one facility is owned by the federal government. This was confirmed by reviewing the 2014 RTR facility list. The burden has been separated into into two tables to account for private labor rates for 11 facilities (mix of slabstock and molded/rebond sources), and federal labor rates for the 1 facility, which appears to be a molded/rebond source.
Burden Item	A	B	C	D	E	F	G	H		Labor Rates
	Person Hours Per Occurrence	Number 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 (E x 0.05)	Clerical Person Hours Per Year (E x 0.10)	Total Costs Per Year ($) b		Management	$69.04
1. Applications	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A		Technical	$51.23
2. Survey and studies	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A		Clerical	$27.73
3. Acquisition, Installation, and Utilization of Tech. & Systems	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
4. Reporting Requirements
A. Familiarization with instructions	1	1	1	1	1	0.05	0.1	$57.46
B. Required Activities
Monitoring of Emissions Operations, Slabstock Facilities - Storage Tank Measurements c	1	12	12	0	0	0	0	$0
C. Create Information	Included in 4B and 5E
D. Gather Existing Information	Included in 4B and 5E
E. Write Report
Initial notification d	2	1	2	0	0	0	0	$0
Notification of modification/reconstruction d	2	1	2	0	0	0	0	$0
Notification of Special Compliance Requirements e	2	1	2	0	0	0	0	$0
Pre-compliance Report d	4	1	4	0	0	0	0	$0
Notification of Compliance Status d	16	1	16	0	0	0	0	$0
Semiannual Reports f	4	2	8	0	0	0	0	$0
Annual Compliance Certifications g	2	1	2	1	2	0.1	0.2	$114.91
Subtotal for Reporting Requirements	34	21	49		3			$172
5. Recordkeeping Requirements
A. Familiarization with instructions	Included in 4A
B. Plan activities	Included in 4B
C. Implement activities	Included in 4B
D. Develop record system	40	1	40	0	0	0	0	$0
E. Time to enter information: records of monitoring and operations a
Slabstock producers	8	12	96	0	0	0	0	$0
Molded/rebond facilities	4	1	4	1	4	0.2	0.4	$229.82
F. Train personnel	40	1	40	0	0	0	0	$0
G. Audits	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Subtotal for Recordkeeping Requirements	92	15	180		5			$230
TOTAL LABOR BURDEN and COSTS (rounded) h					8			$400
TOTAL CAPITAL AND O&M COST (rounded) h								$0
GRAND TOTAL (rounded) h								$400
Assumptions:
a We have assumed that there are approximately 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 existing foam producers (i.e., respondents) that are major sources and subject to the NESHAP subpart III. We have further assumed that there will be no new foam producers commencing operations over the period of this ICR. Therefore, the average number of respondents per year for this ICR is estimated to be 12 and 1 of these facilities is a federal government facility. This federal facility is assumed to be a molded/rebond source.
b This cost is based on the average hourly labor rate as follows: Managerial $69.04 (GS-13, Step 5, $43.15 + 60%); Technical $51.23 (GS-12, Step 1, $32.02 + 60%); and Clerical $27.73 (GS-6, Step 3, $17.33 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Molded/rebond foam producers only have recordkeeping and reporting requirements.
d We have assumed that all existing sources are in compliance with the initial rule requirements.
e We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed.
f Only slabstock foam producers are required to submit semiannual reports.
g All respondents are required to submit annual compliance certifications.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1c

Table 1c: Annual Respondent Burden and Cost Breakdown by Affected Sector – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal)
Affected Sector	Number of Responses	Labor Hours			Labor Cost	Capital and O&M Cost
		Reporting	Recordkeeping	Total
Private	23	176	685	861	$101,900	$0
Public (Federal)	1	3	5	8	$400	$0
Total (rounded)	24	179	690	869	$102,000	$0
				36	hrs/response

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Sheet 4: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal)
Burden Item	A	B	C	D	E	F	G	H
	EPA Hours per Occurrence	Number of Occurrences Per Year	EPA Person Hours Per Year (A x B)	Plants Per Year a	Technical Hours Per Year (C x D)	Management Hours Per Year (E x 0.05)	Clerical Hours Per Year (E x 0.10)	Total Cost Per Year ($) b
Initial Notification c	2	0	0	0	0	0	0	$0		Labor Rates
Notification of Reconstruction/Modification c	2	1	2	0	0	0	0	$0		Management	$69.04
Pre-compliance Report c	2	1	2	0	0	0	0	$0		Technical	$51.23
Notification of Special Compliance Requirements d	2	1	2	0	0	0	0	$0		Clerical	$27.73
Notification of Compliance Status c	2	1	2	0	0	0	0	$0
Semiannual Reports e	2	2	4	6	24	1.2	2.4	$1,378.92
Annual Compliance Certifications f	2	1	2	12	24	1.2	2.4	$1,378.92
TOTAL (rounded) g					55			$2,760
Assumptions:
a We have assumed that there are approximately 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 existing foam producers (i.e., respondents) that are major sources and subject to the NESHAP subpart III. We have further assumed that there will be no new foam producers commencing operations over the period of this ICR. Therefore, the average number of respondents per year for this ICR is estimated to be 12.
b This cost is based on the average hourly labor rate as follows: Managerial $69.04 (GS-13, Step 5, $43.15 + 60%); Technical $51.23 (GS-12, Step 1, $32.02 + 60%); and Clerical $27.73 (GS-6, Step 3, $17.33 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that all existing sources are in compliance with the initial rule requirements.
d We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed.
e Only slabstock foam producers are required to submit semiannual reports.
f All respondents are required to submit annual compliance certifications.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.