Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital and O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	16
Number of Respondents	42
Total Estimated Burden Hours	1,340
Total Estimated Costs	$545,000
Annualized Capital O&M	$385,000
Total Annual Responses	85
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)
					123.94	157.61	62.52
Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year	Management hours per year	Clerical hours per year	Total cost per year
			(AxB)		(CxD)	(Ex0.05)	(Ex0.10)	($) b
1. Applications	N/A
2. Survey and Studies	N/A											New Sources	0.33
3. Reporting Requirements												Existing Sources	42
A. Familiarize with rule requirement c	1	1	1	42	42	2.10	4.20	$5,799.05
B. Required Activities
New Sources
Initial performance test d	280	1	280	0.33	92.4	4.62	9.24	$12,757.90
Repeat performance test d, e	280	0.2	56	0.33	18.48	0.92	1.85	$2,551.58
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Report
New Sources
Notification of construction/reconstruction f	2	1	2	0.33	0.66	0.03	0.07	$91.13
Notification of initial performance test e, g	2	1.2	2.4	0.33	0.792	0.04	0.08	$109.35
Report of initial performance test	See 3B
Existing Sources
Semiannual report h	4	2	8	42	336	17	34	$46,392.36
Subtotal for Reporting Requirements					564			$67,701.37
4. Recordkeeping Requirements
A. Familiarize with rule requirement	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Time to Enter Information
Records of startup, shutdown, and malfunctions i	1.5	2	3	42	126	6.30	12.60	$17,397.14
Records of VOC, temperature, and CMS maintenance j	0.25	52	13	42	546	27.30	54.60	$75,387.59
F. Audits	N/A
Subtotal for Recordkeeping Requirements					773			$92,784.72
TOTAL LABOR BURDEN AND COSTS (rounded) k					1,340			$160,000		1,340
TOTAL CAPITAL AND O&M COST (rounded) k								$385,000
GRAND TOTAL k								$545,000		16	hr/response
Assumptions:
a We estimate that there are an average of 42 existing respondents, and it is estimated that 1 additional source will become subject over the next three years of this ICR.
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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% to account for the benefit packages available to those employed by private industry.
c We estimate it will take one hour to read and familiarize with the rule. This burden item applies to all sources.
d We estimate each performance test will take 280 hours to complete.
e We estimate 20 percent of respondents will need to repeat the initial performance test.
f We estimate it will take 2 hours to prepare the notification of construction/reconstruction.
g We estimate it will take 2 hours to prepare the notification of initial performance test.
h We estimate it will take 4 hours to compile data for semiannual reports.
i We estimate it will take 1.5 hours to record startups, shutdowns, and malfunctions.
j We estimate it will take 0.25 hours to record VOCs, temperatures, and CMS maintenance.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)
					52.37	70.56	28.34
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	Respondents per year a	Technical person hours per year	Management person-hours per year	Clerical person-hours per year	Total cost per year
			(C=AxB)		(CxD)	(Ex0.05)	(Ex0.10)	($) b
Required Activities
New Sources
Initial performance tests c	24	1	24	0.33	7.92	0.40	0.79	$465.16
Repeat performance tests c, d	24	0.2	4.8	0.33	1.58	0.08	0.16	$93.03
Report Review
New Sources
Notification of construction/reconstruction e	2	1	2	0.33	0.66	0.03	0.07	$38.76
Notification of initial startup f	0.5	1	0.5	0.33	0.17	0.01	0.02	$9.69
Notification of actual startup g	0.5	1	0.5	0.33	0.17	0.01	0.02	$9.69
Notification of initial test d, h	0.5	1.2	0.6	0.33	0.20	0.01	0.02	$11.63
Review test results d, i	0.5	1.2	0.6	0.33	0.20	0.01	0.02	$11.63
Existing Sources
Semiannual reports j	2	2	4	42	168	8.40	16.80	$9,866.98
TOTAL COST (rounded)k					206			$10,510
Assumptions:
a We estimate that an average of 42 existing respondents, and it is estimated that 1 additional source will become subject over the next three years of this ICR.
b This ICR uses the following labor rates: $70.56 per hour for Managerial labor; $52.37 per hour for Technical labor, and $28.34 per hour for Clerical labor. These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees.
c We estimate it will take 24 hours to participate with each performance test.
d We estimate 20 percent of respondents will need to repeat the initial performance test.
e We estimate it will take 2 hours to review construction/reconstruction notifications.
f We estimate it will take 0.5 hours to review initial startup notifications.
g We estimate it will take 0.5 hours to review actual startup notifications.
h We estimate it will take 0.5 hours to review initial test notifications.
i We estimate it will take 0.5 hours to review test results.
j We estimate it will take 2 hours to review each semiannual report twice annually.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital and 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 a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M b	Total O&M, (E X F)
Temperature or feed rate monitor	$20,000	0.33	$6,600	9000	42	$378,000
Total (rounded)			$6,600			$378,000		$385,000
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/ reconstruction	0.33	1	0	0.33
Notification of initial performance test	0.33	1.2	0	0.40
Semiannual Reports	42	2	0	84
			Total	85

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	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	0.33	41	0	0	41.33
2	0.33	41.33	0	0	41.66
3	0.33	41.66	0	0	42
Average	0.33	41.33			41.66
a New respondents include sources with constructed and reconstructed affected facilities.