Burden Calculation Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost - NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person‑Hours per occurrence	Number of occurrences per year	Person‑Hours per respondent per year (C=A*B)	Respondents per year a	Technical person‑hours per year (E=C*D)	Management person‑hours per year (F=E*0.05)	Clerical person‑hours per year (G=E*0.1)	Annual costs ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$153.55
3. Initial performance testing (new sources) c										Technical	$122.20
A. Initial notification	2	1	2	0	0	0	0	$0		Clerical	$61.51
B. Notification of performance test	2	1	2	0	0	0	0	$0
C. Notification of compliance status	2	1	2	0	0	0	0	$0
D. Initial performance test report and CPMS performance evaluation	2	1	2	0	0	0	0	$0
4. Reporting requirements
A. Familiarization with regulatory requirements d	4	1	4	10	40	2	4	$5,441.14
B. Plan activities e	8	1	8	10	80	4	8	$10,882.28
C. Training e	8	1	8	10	80	4	8	$10,882.28
D. Gather information, monitor, and inspect f	12	12	144	10	1,440	72	144	$195,881.04
E. Process/compile and review g	8	12	96	10	960	48	96	$130,587.36
F. Periodic add-on control performance test report h	30	1	30	0	0	0	0	$0
Repeat performance test h	30	0.05	1.5	0	0	0	0	$0
G. Complete semiannual report i	8	2	16	10	160	8	16	$21,764.56
Subtotal for Reporting Requirements					3,174			$375,439
5. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B									Hours per Response
C. Implement activities	See 3B									4380	# hours
D. Develop record system										20	# responses
i. Record/disclose j	2	52	104	10	1,040	52	104	$141,469.64		219	hr/resp
ii. Store/file	0.25	2	0.5	10	5	0.25	0.5	$680.14
E. Time to enter information
F. Audits	N/A
Subtotal for Recordkeeping Requirements					1,202			$142,150
Total Labor Burden and Costs (rounded) k					4,380			$518,000
Total Capital and O&M Cost (rounded): k								$6,350
GRAND TOTAL (rounded): k								$524,000
Assumptions:
a We have assumed that there are 10 respondents subject to the rule, 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 that a new source will use an add-on control device to comply with the rule. Sources using an add-on control will use a CPMS to verify compliance with the rule. Because there are no new sources, no initial performance tests are expected to occur.
d We have assumed that it will take 4 hours for existing respondents to refamiliarize themselves with rule requirements.
e We have assumed that it will take eight hours for each respondent to plan activities and eight hours for training.
f We have assumed that each respondent will take twelve hours twelve times per year to complete task.
g We have assumed that each respondent will take eight hours twelve times per year to complete task.
h Facilities that comply using emission capture systems and add-on controls conduct air emissions performance testing before March 15, 2022. 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. We assume 5% of tests will fail and have to re-test. Permits indicate that nine of the ten facilities are using the compliant materials option or the emission rate without add-on controls option to demonstrate compliance and one facility using add-on controls is required to perform testing as part of their 40 CFR part 70 operating permit renewal. Therefore, the periodic testing requirement from the 2019 RTR amendment does not add any new testing burden.
i We have assumed that each respondent will take eight hours twice per year to complete reports.
j We have assumed that each respondent will take two hours each week to record and disclose information.
k Totals have been rounded to three significant digits. 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 the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person‑hours per activity	Number of occurrences per year	Person hours per respondent per year (C = A*B)	Respondents per yeara	Technical person‑hours per year (E=C*D)	Management person‑hours per year (F=E*0.05)	Clerical person‑hours per year (G=E*0.1)	Annual Costs ($/yr) b
1. Initial add-on control performance test c	24	0	0	0	0	0	0	$0		Labor Rates
2. Repeat add-on control performance test c	24	0	0	0	0	0	0	$0		Management	$69.04
3. Review notifications and reports - new sources d										Technical	$51.23
A. Initial notification	4	1	4	0	0	0	0	$0		Clerical	$27.73
B. Notification of performance test	8	1	8	0	0	0	0	$0
C. Notification of compliance status	8	1	8	0	0	0	0	$0
D. Performance test report and CPMS evaluation	8	1	8	0	0	0	0	$0
3. Periodic Testing e
A. Review notification of performance test	4	1	4	0	0	0	0	$0
B. Review add-on control performance test report	8	1	8	0	0	0	0	$0
4. Semiannual report review f	12	2	24	10	240	12	24	$13,789.20
TOTAL (rounded) g					276			$13,800
Assumptions:
a We have assumed that there are 10 respondents subject to the rule, 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 are expected to occur.
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 There are no new sources. Therefore, no initial performance tests are expected to occur.
d Based on Agency experience, we assume that it will take four hours to review the initial notification, 8 hours to review the notification of the test, 8 hours to review the notification of compliance status, and 8 hours to review the performance test report and CPMS evaluation.
e Based on Agency experience, we assume that it will take four hours to review the notification of the test and 8 hours to review the performance test report.
f We have assumed that it will take the Agency 12 hours to review the semiannual report for each respondent.
g Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	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	10	0	0	10
2	0	10	0	0	10
3	0	10	0	0	10
Average	0	10	0	0	10
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 performance test	0	1	0	0
Notification of compliance status	0	1	0	0
Initial performance test report and CMS evaluation	0	1	0	0
Periodic add-on control performance test report	0	1	0	0
Repeat performance test	0	0.05	0	0
Semiannual report	10	2	0	20
Total				20
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 a	Number of Respondents with O&M b	Total O&M, (E X F)
Continuous Monitoring Device	$16,000	0	$0	$6,354	1	$6,354
Total (rounded) c			$0			$6,350
a Comments received from Whirlpool Corporation during industry consultation suggested that annual O&M cost can vary from 24 to 80 hours at a technician’s pay grade. To calculate annual O&M costs, an average of 52 hours was assumed and multiplied by the technical labor rate of $122.20.
b Permit data indicates that only one affected source uses an emission control device to comply with the NESHAP.
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.