Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	144
Number of Respondents	57
Total Estimated Burden Hours	20,600
Total Estimated Costs	$2,470,000
Annualized Capital O&M	$4,800
Total Annual Responses	143
Form Number	5900-594

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for the Wood Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ) (Renewal)
					123.94	157.61	62.52
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 yeara	(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
1. Reporting requirements
a. Familiarize with rule requirements	4	1	4	57	228	11.4	22.8	$31,480.53
b. Process/review information	4	4	16	57	912	45.6	91.2	$125,922.12
c. Prepare for initial test performance test	24	1	24	0	0	0	0	$0
d. Write reports
i. Initial notification	2	1	2	0	0	0	0	$0
ii. Notification of compliance statusd	10	1	10	0	0	0	0	$0
iii. Notification of construction/reconstruction	2	1	2	0	0	0	0	$0.00
iv. Notification of actual startup	2	1	2	0	0	0	0	$0.00
v. Notification of performance test	2	1	2	0	0	0	0	$0.00
vi. Report of performance test (through ERT) e	10	1	10	0	0	0	0	$0.00
vii. Semiannual report	8	2	16	57	912	45.6	91.2	$125,922.12
viii. Excess emissions report	4	0.5	2	57	114	5.7	11.4	$15,740.27
Subtotal for Reporting Requirements					2,491			$299,065
2. Recordkeeping requirements
a. Familiarize with rule requirements	See 1A
b. Plan activities	12	1	12	57	684	34.2	68.4	$94,441.59
c. Implement activities	12	1	12	57	684	34.2	68.4	$94,441.59
d. Maintain record system for material used	20	1	20	57	1,140	57	114	$157,402.65
e. Time to enter information
i. Material purchase recordsc	4	1	4	23	92	4.6	9.2	$12,702.67
ii. Material usage recordsc	16	12	192	34	6,528	326.4	652.8	$901,337.28
iii. Compliance calculationsc	8	12	96	34	3,264	163.2	326.4	$450,668.64
f. Time to train personnelf	10	1	10	57	570	28.5	57	$78,701.33
g. Store, file, and maintain records	4	12	48	57	2,736	136.8	273.6	$377,766.36
h. Retrieve records/reports	2	12	24	57	57	2.85	5.7	$7,870.13
Subtotal for Recordkeeping Requirements					18,118			$2,175,332
TOTAL LABOR BURDEN AND COST (rounded) g					20,600			$2,470,000
Capital and O&M Cost g								$4,800
Grand TOTAL g								$2,470,000
Assumptions:									144	hr/resp
a There is an average of 57 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facilities will become subject to this regulation.
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 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We estimate that 40% of facilities are using the compliant material option to comply with the rule; therefore 40% of the 57 facilities (23 respondents) have to provide material purchase records and 60% of the 57 facilities (34 respondents) are tracking material usage and doing monthly compliance calculations.
d We estimate that it will take the respondent 10 hours to prepare the notification of compliance status.
e We estimate that it will take the respondent 10 hours to prepare and submit an initial performance test report.
f We estimate that it will take the respondent 10 hours once per year for initial training of personnel.
g 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 – NESHAP for the Wood Building Products Surface Coating Industry (40 CFR Part 63, Subpart QQQQ) (Renewal)
					52.37	70.56	28.34
Burden Item	(A) EPA Person-hours per activity	(B) No. of occurences per plant per year	(C) EPA person-hours per plant per year (C=AxB)	(D) Plants per yeara	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (D=Cx0.05)	(G) Clerical person-hours per year (E=Cx0.1)	(H) Annual costs ($)b
1. Initial performance test	24	0	0	0	0	0	0	$0
2. Repeat performance test	24	0	0	0	0	0	0	$0
3. Report review
a) Initial notification	8	0	0	0	0	0	0	$0
b) Notification of performance test	8	0	0	0	0	0	0	$0
c) Notification of compliance status	8	0	0	0	0	0	0	$0
d) Notification of construction/reconstruction	8	0	0	0	0	0	0	$0
e) Notification of actual startup	8	0	0	0	0	0	0	$0
f) Notification of performance test	8	0	0	0	0	0	0	$0
g) Report of performance test	8	0	0	0	0	0	0	$0
h) Semiannual report	12	2	24	57	1,368	68.4	136.8	$80,345
i) Excess emissions report	8	0.5	4	57	228	11.4	22.8	$13,391
Total Burden Hours and Costs c					1,840			$94,000
Assumptions:
a There is an average of 57 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facilities will become subject to this regulation.
b This cost is based on the following labor rates: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.17 + 60%). 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 percent to account for the benefit packages available to government employees.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital 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)
CPMS	$16,000	0	$0	$1,200	4	$4,800
Method 24/25A performance test	$14,000	0	$0	$0	0	$0
Method 326/NCASI Method ISS/FP A105.01/Method 320 performance test	$14,000	0	$0	$0	0	$0
Method 204 performance test	$8,000	0	$0	$0	0	$0		Total Capital/Startup vs. Operation and Maintenance (O&M) Costs
Totals (rounded) c			$0			$4,800		$4,800
a We estimate no new respondents will become subject to the standard in the next three years.
b We estimate 4 of the 57 respondents use add-on controls with a CPMS during the three-year period of this ICR.
c Totals have been rounded to 3 significant digits. 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
Initial Notification	0	1	0	0
Notification of compliance status	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	1.2	0	0
Report of performance test	0	1.2	0	0
Semiannual report	57	2	0	114
Excess emissions report	57	0.5	0	28.5
			Total	143
a There is an average of 57 respondents per year over the next three years of this ICR. In addition, we have assumed that no new facility will become subject to this regulation.

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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	57	0	0	57
2	0	57	0	0	57
3	0	57	0	0	57
Average	0	57	0	0	57
a New respondents include sources with constructed and reconstructed affected facilities.