Burden Calculation Tables

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Overview

TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-Summary
TBL5-YR1
TBL6-YR2
TBL7-YR3
TBL8-Summary
Capital O&M

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Sheet 1: TBL1-YR1

Table 1: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year 1
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 yeara	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Cost, $ b
1. Reporting Requirements
A. Familiarization with rule requirements	4	1	4	368	1472	73.6	147.2	$192,820.22		Labor Rates
B. Required Activities
Plan activities	8	1	8	0	0	0	0	$0		Manager	$147.40
Training	8	1	8	0	0	0	0	$0		Technical	$117.92
Create, test, and research and development	0	1	0	0	0	0	0	$0		Clerical	$57.02
Gather information and monitor	18	12	216	0	0	0	0	$0
Gather information and monitor - Magnet wire facilities c	36	12	432	0	0	0	0	$0
Process/Compile and Review	12	12	144	0	0	0	0	$0
Process/Compile and Review - Magnet wire facilities c	24	12	288	0	0	0	0	$0
Add-on control performance test d	30	1	30	0	0	0	0	$0
Repeat add-on control performance test d	30	1	30	0	0	0	0	$0
C. Write Reports
Semiannual Reports e	8	2	16	0	0	0	0	$0
Notification of performance test/re-test f	2	1	2	0	0	0	0	$0
Performance test/re-test report f	10	1	10	0	0	0	0	$0
Subtotal for Reporting Requirements					1,693			$192,820
2. Recordkeeping requirements
A. Record/disclose information g	4	2	8	0	0	0	0	$0
B. Store/File information g	4	2	8	0	0	0	0	$0
C. LDAR reporting and recordkeeping	0	0	0	0	0	0	0	$0
D. Revise record systems due to SSM revisions h	8	1	8	368	2944	147.2	294.4	$385,640.45
E. Become familiar with CEDRI for electronic filing of notifications and reports i	8	1	8	368	2944	147.2	294.4	$385,640.45
Subtotal for Recordkeeping Requirements					6,771			$771,281
Total Labor Burden and Cost (rounded) j						8,460		$964,000
Total Capital/O&M Costs (rounded) j								$0
Grand Total (rounded) j								$964,000
Assumptions:
a There are 368 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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 assumed that the four magnet wire facilities on average incorporate a higher number of processes that’s typical for the industry. The burden of gathering information, monitoring, and processing compiling, and reviewing has been estimated based on comments received from NEMA.
d The performance test requirement will affect 7 facilities in the third year. These are 7 facilities with add-on controls that do not already have a testing requirement in their permits. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
e We have assumed that each respondent will take eight hours twice per year to complete the semiannual reports.
f Assumes that the 7 facilities with add-on controls but without periodic testing requirements in their permits will do performance testing in year 3. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
g We have assumed that each respondent will take four hours twice per year to complete the task.
h We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one.
i Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: TBL2-YR2

Table 2: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year 2
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 yeara	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Cost, $ b
1. Reporting Requirements
A. Familiarization with rule requirements	4	1	4	0	0	0	0	$0		Labor Rates
B. Required Activities
Plan activities	8	1	8	0	0	0	0	$0		Manager	$147.40
Training	8	1	8	0	0	0	0	$0		Technical	$117.92
Create, test, and research and development	0	1	0	0	0	0	0	$0		Clerical	$57.02
Gather information and monitor	18	12	216	0	0	0	0	$0
Gather information and monitor - Magnet wire facilities c	36	12	432	0	0	0	0	$0
Process/Compile and Review	12	12	144	0	0	0	0	$0
Process/Compile and Review - Magnet wire facilities c	24	12	288	0	0	0	0	$0
Add-on control performance test d	30	1	30	0	0	0	0	$0
Repeat add-on control performance test d	30	1	30	0	0	0	0	$0
C. Write Reports
Semiannual Reports e	8	2	16	0	0	0	0	$0
Notification of performance test/re-test f	2	1	2	0	0	0	0	$0
Performance test/re-test report f	10	1	10	0	0	0	0	$0
Subtotal for Reporting Requirements					0			$0
2. Recordkeeping requirements
A. Record/disclose information g	4	2	8	0	0	0	0	$0
B. Store/File information g	4	2	8	0	0	0	0	$0
C. LDAR reporting and recordkeeping	0	0	0	0	0	0	0	$0
D. Revise record systems due to SSM revisions h	8	1	8	0	0	0	0	$0
E. Become familiar with CEDRI for electronic filing of notifications and reports i	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Cost (rounded) j						0		$0
Total Capital/O&M Costs (rounded) j								$0
Grand Total (rounded) j								$0
Assumptions:
a There are 368 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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 assumed that the four magnet wire facilities on average incorporate a higher number of processes that’s typical for the industry. The burden of gathering information, monitoring, and processing compiling, and reviewing has been estimated based on comments received from NEMA.
d The performance test requirement will affect 7 facilities in the third year. These are 7 facilities with add-on controls that do not already have a testing requirement in their permits. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
e We have assumed that each respondent will take eight hours twice per year to complete the semiannual reports.
f Assumes that the 7 facilities with add-on controls but without periodic testing requirements in their permits will do performance testing in year 3. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
g We have assumed that each respondent will take four hours twice per year to complete the task.
h We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one.
i Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: TBL3-YR3

Table 3: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year 3
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 yeara	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Cost, $ b
1. Reporting Requirements
A. Familiarization with rule requirements	4	1	4	0	0	0	0	$0		Labor Rates
B. Required Activities
Plan activities	8	1	8	0	0	0	0	$0		Manager	$147.40
Training	8	1	8	0	0	0	0	$0		Technical	$117.92
Create, test, and research and development	0	1	0	0	0	0	0	$0		Clerical	$57.02
Gather information and monitor	18	12	216	0	0	0	0	$0
Gather information and monitor - Magnet wire facilities c	36	12	432	0	0	0	0	$0
Process/Compile and Review	12	12	144	0	0	0	0	$0
Process/Compile and Review - Magnet wire facilities c	24	12	288	0	0	0	0	$0
Add-on control performance test d	30	1	30	7	210	10.5	21	$27,508.32
Repeat add-on control performance test d	30	1	30	0	0	0	0	$0
C. Write Reports
Semiannual Reports e	8	2	16	0	0	0	0	$0
Notification of performance test/re-test f	2	1	2	7	14	0.7	1.4	$1,833.89
Performance test/re-test report f	10	1	10	7	70	3.5	7	$9,169.44
Subtotal for Reporting Requirements					338			$38,512
2. Recordkeeping requirements
A. Record/disclose information g	4	2	8	0	0	0	0	$0
B. Store/File information g	4	2	8	0	0	0	0	$0
C. LDAR reporting and recordkeeping	0	0	0	0	0	0	0	$0
D. Revise record systems due to SSM revisions h	8	1	8	0	0	0	0	$0
E. Become familiar with CEDRI for electronic filing of notifications and reports i	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Cost (rounded) j						338		$38,500
Total Capital/O&M Costs (rounded) j								$133,000
Grand Total (rounded) j								$172,000
Assumptions:
a There are 368 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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 assumed that the four magnet wire facilities on average incorporate a higher number of processes that’s typical for the industry. The burden of gathering information, monitoring, and processing compiling, and reviewing has been estimated based on comments received from NEMA.
d The performance test requirement will affect 7 facilities in the third year. These are 7 facilities with add-on controls that do not already have a testing requirement in their permits. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
e We have assumed that each respondent will take eight hours twice per year to complete the semiannual reports.
f Assumes that the 7 facilities with add-on controls but without periodic testing requirements in their permits will do performance testing in year 3. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
g We have assumed that each respondent will take four hours twice per year to complete the task.
h We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one.
i Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: TBL4-Summary

Table 4 - Summary of Annual Respondent Burden and Cost - NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	7,360	368	736	8,464	$964,000	$0	$964,000
2	0	0	0	0	$0	$0	$0
3	294	15	29	338	$38,500	$133,000	$171,500
Total	7,654	383	765	8,802	$1,000,000	$133,000	$1,140,000
Average	2,551	128	255.1	2,930	$334,000	$44,000	$379,000
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	368	1,104	1,693	6,771	8,464	8.0	23.0
2	368	0	0	0	0	-	0.0
3	368	21	338	0	338	16	0.9
Total	-	1,125	2,031	6,771	8,802	-	23.9
Average	368	375	677	2,257	2,930	7.8	8.0
Average annual additional costs per respondent:				$1,030
Average annual additional hours per respondent:				8.0
Average annual additional hours per response:				7.8

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Sheet 5: TBL5-YR1

Table 5: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year 1
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Initial performance and test	N/A	0	0	0	0	0	0	$0		Labor Rates
2. Repeat performance test	N/A	0	0	0	0	0	0	$0		Manager	$65.71
3. Review of Notifications/Reports										Technical	$48.75
a) Initial notification	8	0	0	0	0	0	0	$0		Clerical	$26.38
b) Notification of performance test c	2	1	2	0	0	0	0	$0
c) Performance test/retest report c	8	1	8	0	0	0	0	$0
d) Notification of compliance status	12	0	0	0	0	0	0	$0
e) Semiannual report d	12	2	24	0	0	0	0	$0
TOTAL (rounded) e					0			$0
Assumptions:
a There are 368 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This cost is based on the following labor rates: $65.71 for Managerial (GS-13, Step 5, $41.07 + 60%), $48.75 for Technical (GS-12, Step 1, $30.47+ 60%), and $26.38 Clerical (GS-6, Step 3, $16.49+ 60%). These rates are from the Office of Personnel Management (OPM), 2018 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. Assumes that the 7 facilities with add-on controls but without periodic testing requirements in their permits will do performance testing in year 3. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
d We have assumed that each respondent will take 12 hours twice a year to complete semiannual report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: TBL6-YR2

Table 6: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year 2
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Initial performance and test	N/A	0	0	0	0	0	0	$0		Labor Rates
2. Repeat performance test	N/A	0	0	0	0	0	0	$0		Manager	$65.71
3. Review of Notifications/Reports										Technical	$48.75
a) Initial notification	8	0	0	0	0	0	0	$0		Clerical	$26.38
b) Notification of performance test c	2	1	2	0	0	0	0	$0
c) Performance test/retest report c	8	1	8	0	0	0	0	$0
d) Notification of compliance status	12	0	0	0	0	0	0	$0
e) Semiannual report d	12	2	24	0	0	0	0	$0
TOTAL (rounded) e					0			$0
Assumptions:
a There are 368 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This cost is based on the following labor rates: $65.71 for Managerial (GS-13, Step 5, $41.07 + 60%), $48.75 for Technical (GS-12, Step 1, $30.47+ 60%), and $26.38 Clerical (GS-6, Step 3, $16.49+ 60%). These rates are from the Office of Personnel Management (OPM), 2018 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. Assumes that the 7 facilities without periodic testing requirements in their permits will do performance testing in year 3. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
d We have assumed that each respondent will take 12 hours twice a year to complete semiannual report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: TBL7-YR3

Table 7: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year 3
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Initial performance and test	N/A	0	0	0	0	0	0	$0		Labor Rates
2. Repeat performance test	N/A	0	0	0	0	0	0	$0		Manager	$65.71
3. Review of Notifications/Reports										Technical	$48.75
a) Initial notification	8	0	0	0	0	0	0	$0		Clerical	$26.38
b) Notification of performance test c	2	1	2	7	14	0.7	1.4	$765.43
c) Performance test/retest report c	8	1	8	7	56	2.8	5.6	$3,061.72
d) Notification of compliance status	12	0	0	0	0	0	0	$0
e) Semiannual report d	12	2	24	0	0	0	0	$0
TOTAL (rounded) e					81			$3,830
Assumptions:
a There are 368 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This cost is based on the following labor rates: $65.71 for Managerial (GS-13, Step 5, $41.07 + 60%), $48.75 for Technical (GS-12, Step 1, $30.47+ 60%), and $26.38 Clerical (GS-6, Step 3, $16.49+ 60%). These rates are from the Office of Personnel Management (OPM), 2018 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. Assumes that the 7 facilities without periodic testing requirements in their permits will do performance testing in year 3. We assume a 5% failure and re-test rate (7 x 0.05 = 0.35). Since the fraction of re-tests (0.35) rounds down to zero, we assume no re-tests will be done.
d We have assumed that each respondent will take 12 hours twice a year to complete semiannual report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: TBL8-Summary

Table 8 - Summary of Annual Agency Burden and Cost - NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	0	0	0	0	$0	$0	$0
2	0	0	0	0	$0	$0	$0
3	70	4	7	81	$3,830	$0	$3,830
Total	70	3.5	7.0	81	$3,830	$0	$3,830
Average	23.3	1.2	2.3	27	$1,280	$0	$1,280
Year	Number of Responses	Total Hours
1	0	0
2	0	0
3	14	81
Total	14	81
Average	5	27
Average annual hours per response:		5.8

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Sheet 9: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Performance Testing	Capital Startup Cost for One Performance Test	Number of Respondents Doing Testing	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)
Performance Testing	$19,000	7	$133,000	$0	0	$0
Totals (rounded)			$133,000			$0	Total	$133,000
Note: In year 3, seven sources test one control device each at a cost of $19,000. We assume a 5% failure rate for the test. Since the fraction of re-tests (0.35) rounds down to zero, we assume no cost for re-tests. Totals have been rounded to three significant figures.