Burden Calculations Table

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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	39
Number of Respondents	158
Total Estimated Burden Hours	16,200
Total Estimated Costs	$2,200,000
Annualized Capital O&M	$151,000
Total Annual Responses	411
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)
Burden item	(A) Person-hours per occurrence	(B) Annual occurrences per respondent	(C) Person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarization with regulatory requirementsa	1	1	1	158	158	8	16	22,911.50		Clerical	$65.71
B. Required activities
Initial performance test c	30	0.07	2	0	0	0	0	0.00
Repeat performance test c	30	0.07	2	0	0	0	0	0.00
C. Gather existing information	See 3B
D. Write report
Notification of construction/reconstructionc	2	1	2	0	0	0	0	0.00
Notification of actual startupc	2	1	2	0	0	0	0	0.00
Notification of CMS demonstration date	2	1	2	0	0	0	0	0.00
Report of performance testc	See 3B
VOC emissions reportd	5	2	10	142	1,420	71	142	205,913.49
Excess emissions reportd	5	4	20	16	320	16	32	46,403.04
Temperature variance report e	4	0.5	2	126	252	12.6	25.2	36,542.39
Subtotal for Reporting Requirements					2,473			311,770
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities
Monthly VOC weighted average calculationsf	1	12	12	32	384	19.2	38.4	55,683.65
D. Develop record system
Records of temperaturee	0.25	365	91.25	126	11,498	575	1,150	1,667,246.73
Records of data used to support monthly VOC calculationsf	0.25	12	3.0	32	96	4.8	9.6	13,920.91		hrs/response	39
Subtotal for Recordkeeping Requirements					13,774			1,736,851
TOTAL ANNUAL BURDEN AND COST (ROUNDED)g					16,200			2,050,000
Total CAPITAL and O&M COST (rounded)g								151,000
GRAND TOTAL (rounded)g					16,200			2,200,000
a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR. This ICR assumes each respondent will incur a burden to re-familiarize themselves with the regulatory requirements each year.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 This is a one-time requirement and does not apply since no new sources are estimated. EPA assumes 20% of new sources must repeat performance testing due to failure.
d EPA assumes 10% of respondents have excess VOC emissions and must report quarterly instead of semi-annually. The remaining 90% of sources report semi-annually.
e EPA assumes 80% of facilities will use incineration, and will file a temperature variance report every other year. These facilities will also have to maintain daily temperature records of incinerator combustion temperature (for therm incineration) or gas temperature (for catalytic incineration)
f EPA assumes the remaining 20% of sources do not have control devices will comply using the monthly weighted average VOC calculation approach.
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 – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)
Burden item	(A) EPA person-hours per occurrence	(B) Annual occurrences per respondent	(C) EPA person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b
Initial performance test										Labor Rates
New plantc	24	0.07	2	0	0	0	0	0		Management	$73.46
Repeat performance test										Technical	$54.51
New plant c	24	1	24	0	0	0	0	0		Clerical	$29.50
Report review
New plantc
Notification of construction/reconstruction	2	1	2	0	0	0	0	0
Notification of actual startup	0.5	1	0.5	0	0	0	0	0
Notification of CMS demonstration date	0.5	1	0.5	0	0	0	0	0
Review test results	8	1	8	0	0	0	0	0
Existing plant
VOC emissions reportd	2	2	4	142	568	28.4	56.8	34,724
Excess emissions reportd	2	4	8	16	128	6.4	12.8	7,825
Temperature variance report e	2	0.5	1	126	126	6.3	12.6	7,703
TOTAL ANNUAL BURDEN AND COST (ROUNDED)f					945			50,300
a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR.
b The cost is based on the following labor rates: Managerial rate of $73.456 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.512 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.504 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 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 This is a one-time requirement and does not apply since no new sources are expected.
d EPA assumes 10% of sources will have excess emissions and will file a quarterly report instead of the semi-annual frequency submitted from the other 90% of sources.
e EPA assumes 80% of facilities will use incineration, and will file a temperature variance report every other year.
f 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)
Temperature Monitoring System	N/A	N/A	$0	$1,200a	126	$151,200
Method 25 Performance Test	$18,750b	0	$0	N/A	N/A	$0
Total (Rounded)c			$0			$151,000		$151,000
a According to industry consultation comment received on an ICR for a related rulemaking (40 CFR part 63 subpart SSSS), the O&M cost to maintain continuous temperature measuring monitor is $1,200 per respondent. The cost covers replacement of temperature sensor each calendar year. This cost is applied to the 80 percent of respondents assumed to use an incinerator to comply with the requirements.
b Costs included to contract out for a one-time initial performance test using Method 25 or Method 25A for facilities with control devices. It is assumed that all existing facilities have conducted an initial performance test.
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) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of CMS demonstration date	0	1	0	0
Notification of performance test	0	1	0	0
VOC emissions report	142	2	0	284
Excess emissions report	16	4	0	64
Temperature variance report	126	0.5	0	63
			Total	411

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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	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	158	0	0	158
2	0	158	0	0	158
3	0	158	0	0	158
Average	0	158	0	0	158
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.