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 Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. 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 (F=Ex0.05)	Clerical person hours per year (G=Ex0.1)	Total Annual Cost, $ b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Managerial	$149.84
3. Acquisition, installation and utilization of technology and systems	54	1	54	0	0	0	0	$0		Technical	$122.66
4. Reporting requirements										Clerical	$60.88
A. Familiarize with regulatory requirements c	4.5	1	4.5	2	9	0.45	0.9	$1,226.16
B. Required activities	See 4E
C. Create information	See 4E
D. Gather existing information	See 4E
E. Write Report
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Semiannual report of deviation d	9	2	18	0.3	5.4	0.27	0.54	$735.70
Semiannual report of no deviation e	8	2	16	1.7	27	1.4	2.7	$3,705.73
Subtotal for Reporting Requirements					48			$5,668
5. Recordkeeping requirements
A. Familiarize with regulatory requirements c	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information
Records of solvent weight measurements f	0.033	2,600	86	2	172	8.6	17	$23,378.78
Records of block average solvent weight g	2	52	104	2	208	10	21	$28,337.92
Copies of notifications/reports h	0.25	3	0.8	2	1.5	0.08	0.15	$204.36
F. Time to train personnel i	20	1	20	2	40	2	4	$5,449.60
G. Time to transmit or disclose information h	0.25	3	0.8	2	1.5	0.08	0.15	$204.36
H. Time to audit	N/A
Subtotals for Recordkeeping Requirements					486			$57,575		Responses	hr/response
Total Labor Burden and Costs (rounded) j					534			$63,200		4	134
Total Capital and O&M Cost (rounded) j								$544
GRAND TOTAL (rounded) j								$63,700
Assumptions:
a We have assumed that there are 2 existing sources, and that no additional new or reconstructed sources will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that 15 percent of respondents will report deviation(s).
e We have assumed that 85 percent of respondents will report no deviation.
f We have assumed that solvent weights are recorded once per hour (2 minutes [0.033 hr] per record) for 2,600 hours per year (industry average annual operating hours for solvent mixers).
g It is assumed that information would be entered once per week for 52 weeks per year.
h We have assumed that a typical plant transmits the deviation report once a year and no deviation report semiannually for a total of three times per year.
i We have assumed that it will take 20 hours per plant once a year to train personnel.
j 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 Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person-hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost, $ b
1. Excess emissions enforcement activities c	48	1	48	0.1	4.8	2.4	0.48	$424.91		Labor Rates
2. Report review										Managerial	$69.04
Notification of applicability	2	1	2	0	0	0	0	$0		Technical	$51.23
Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0		Clerical	$27.73
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	40	1	40	0	0	0	0	$0
Semiannual report of deviation d	20	2	40	0.3	12	6	1.2	$1,062.28
Semiannual report of no deviation e	2	2	4	1.7	6.8	3.4	0.68	$601.96
TOTAL (rounded) f					38			$2,090
Assumptions:
a We have assumed that there are 2 existing sources, and that no additional new or reconstructed sources will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $51.23 (technical), $69.04 (managerial), and $27.73 (clerical). 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 5 percent of plants will be involved in excess emissions enforcement activities.
d We have assumed that 15 percent of respondents will report a deviation.
e We have assumed that 85 percent of respondents will report no deviation.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

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	Total O&M, (E x F)
Monitoring Control Device	$2,139	0	$0	$272	2	$544
					Total	$544
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	2	0	0	2
2	0	2	0	0	2
3	0	2	0	0	2
Average	0	2	0	0	2
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
Notification of applicability	0	1	N/A	0
Notification of construction/reconstruction	0	1	N/A	0
Notification of anticipated startup	0	1	N/A	0
Notification of actual startup	0	1	N/A	0
Notification of compliance status	0	1	N/A	0
Semiannual report of deviation	0.3	2	N/A	0.6
Semiannual report with no deviation	1.7	2	N/A	3.4
			Total	4