Burden Calculation Tables

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Overview

Table 1
Table 2
Capital O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost - NESHAP for for Surface Coating of Metal Furniture (40 CFR Part 63, Subpart RRRR) (Renewal)
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) Management person‑hrs. per year (F=Ex0.05)	(G) Clerical person‑hrs. per year (G=Ex0.1)	(H) Annual costs ($) b		Labor Rates
1. Reporting requirements										Management	$153.55
A. Familiarize with rule requirements	4	1	4	16	64	3.2	6.4	$8,705.82		Technical	$122.20
B. Process/review information	4	4	16	16	256	12.8	25.6	$34,823.30		Clerical	$61.51
C. Plan Activities - Training c	10	1	10	16	160	8	16	$21,764.56
D. Add-on Control Performance Test d	8	1	8	0	0	0	0	$0
E. Write reports
i. Initial notification	2	1	2	0	0	0	0	$0
ii. Notification of initial compliance	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 d	2	1	2	0	0	0	0	$0
vi. Report of performance test d	16	1	16	0	0	0	0	$0
vii. Excess emissions report	4	0.5	2	16	32	1.6	3.2	$4,353
viii. Semiannual report e	8	2	16	16	256	12.8	25.6	$34,823.30
Subtotal for Reporting Requirements					883			$104,470
2. Recordkeeping requirements
A. Familiarize with rule requirements	See 1.A
B. Plan activities	See 1.C
C. Implement activities	See 1.C
D. Maintain record system for material used	20	1	20	16	320	16	32	$43,529.12
E Time to enter information
i. Material usage f	2	52	104	16	1,664	83.2	166.4	$226,351.42
ii. Compliance calculation g	2	12	24	16	384	19.2	38.4	$52,234.94
F. Time to train personnel	See 1.C
G. Store, file, and maintain records	2	12	24	16	384	19.2	38.4	$52,234.94
H Retrieve records/reports	1	12	12	16	192	9.6	19.2	$26,117.47
Subtotal for Recordkeeping Requirements					3,386			$400,468		107	hr/resp
Total Labor Burden and Costs (rounded) h					4,270			$505,000
Total Capital and O&M Cost (rounded) h								$0
GRAND TOTAL h								$505,000
Assumptions:
a We have assumed that there are approximately 16 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
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.
c We assume each respondent will take ten hours, once per year to plan activities and train staff.
d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing. There are no Surface Coating of Metal Furniture facilities (Subpart RRRR) using add-on controls to comply. We do not anticipate any facilities in this industry to have performance testing costs.
e We have assumed that each respondent will take eight hours twice per year to complete the semiannual report. The semiannual report includes all compliance reports for that period.
f We have assumed that each respondent will take 1 hour twice per week to enter information.
g We have assumed that each respondent will have to calculate compliance once per month. Compliance reports for the six-month period are filed with the semiannual report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost - NESHAP for for Surface Coating of Metal Furniture (40 CFR Part 63, Subpart RRRR) (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
1. Initial performance test c, d	24	1	24	0	0	0	0	$0		Labor Rates
2. Repeat performance test d	24	0.2	4.8	0	0	0	0	$0		Management	$69.04
3. Report review										Technical	$51.23
a) Initial notification	4	1	4	0	0	0	0	$0		Clerical	$27.73
b) Notification of performance test e	4	1	4	0	0	0	0	$0
c) Notification of initial compliance	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
g) Report of performance test f	8	1	8	0	0	0	0	$0
h) Excess emissions report	8	0.5	4	16	64	3.2	6.4	$3,677
i) Semiannual report and compliance reports g	12	2	24	16	384	19.2	38.4	$22,062.72
Total (rounded) h					515			$25,700
Assumptions:
a We have assumed that there are approximately 16 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
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 The current ICR assumes it will take 24 hours to complete the task for each respondent.
d Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing. No sources use emission capture systems and add-on controls.
e We assume it will take four hours to review the notification of the test and the test plan for each respondent.
f We assume it will take eight hours to review the test report for each respondent.
g We assume it will take twelve hours to review the semiannual reports for each respondent. The semiannual reports include the monthly compliance reports for that period.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital O&M

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents a	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	16	0	0	16
2	0	16	0	0	16
3	0	16	0	0	16
Average	0	16	0	0	16
a New respondents include sources with constructed, reconstructed and modified affected facilities.
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial notification	0	1	0	0
Notification of initial compliance	0	1	0	0
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of performance test	0	1	0	0
Report of performance test	0	1	0	0
Excess emissions report	16	0.5	0	8
Semiannual report	16	2	0	32
			Total	40
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M a	Total O&M (E X F)
Testing for Add-on Control Device	$19,000	0	$0
CEM				$1,200	0	$0
Total			$0			$0
a No respondents use add-on controls or monitoring devices to establish compliance with the emission standards.