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	79
Number of Respondents	77
Total Estimated Burden Hours	16,900
Total Estimated Costs	$3,330,000
Annualized Capital O&M	$1,200,000
Total Annual Responses	214
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR Part 60, Subpart VVV) (Renewal)
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. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarize with the regulatory requirements c	1	1	1	77	77	3.85	7.7	$11,165.73		Clerical	$65.71
B. Required activities
Initial performance test	280	1	280	5	1400	70	140	$203,013.30
Repeat performance test d	280	1	280	1	280	14	28	$40,602.66
Monthly compliance test e	90	12	1080	1	1080	54	108	$156,610.26
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/ reconstruction	2	1	2	5	10	0.5	1	$1,450.10
Notification of actual startup	2	1	2	5	10	0.5	1	$1,450.10
Notification of initial performance test	2	1	2	5	10	0.5	1	$1,450.10
Notification of VOC use at end of initial year f	2	1	2	1	2	0.1	0.2	$290.02
Report of performance test	See 3B
Report of monitoring exceedances and non-compliance periods g	16	4	64	15	960	48	96	$139,209.12
Report of no excess emissions h	8	2	16	62	992	49.6	99.2	$143,849.42
Report when 1st projected VOC use exceeds cutoff	2	1	2	2	4	0.2	0.4	$580.04
Report when 1st actual 12-month VOC use exceeds cutoff i	2	1	2	0	0	0	0	$0
Notification of changes j	4	1	4	5	20	1	2	$2,900.19
Subtotal for Reporting Requirements					5,572			$702,571
4. Recordkeeping requirements
A. Read instructions	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 startups, shutdowns, malfunctions, etc. k	1.5	25	37.5	77	2887.5	144.375	288.75	$418,714.93
Records of operating parameters l	0.25	350	87.5	77	6,737.50	336.875	673.75	$977,001.51
Records of semiannual projected VOC use estimate m	1	2	2	15	30	1.5	3	$4,350.29
Records of 12-month actual VOC use m	1	12	12	15	180	9	18	$26,101.71
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					11,310			$1,426,168		79	hr/response
Total Labor Burden and Costs (rounded) n					16,900			$2,130,000
Total Capital and O&M Cost (rounded) n								$1,200,000
GRAND TOTAL (rounded) n								$3,330,000
Assumptions:
a On average, EPA estimates 76 existing plants and one new plant per year will be subject to the NSPS over the next 3 years. This ICR assumes 4 existing plants per year will install new coating lines.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). 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 ICR assumes it will take each facility 1 hour per year to familiarize with regulatory requirements.
d This ICR assumes 20 percent of initial performance tests must be repeated due to failure (5 × 20% = 1).
e This ICR assumes one coating line per year will demonstrate compliance by the liquid material balance method, which requires monthly compliance testing.
f This ICR assumes one plant per year will be required to submit this notification.
g This ICR assumes 20 percent of existing and new plants will report monitoring exceedances or non-compliance periods on a quarterly basis (77×20% = 15, after rounding). These plants will comply though either the emission reduction, alternative, or coating mix preparation equipment standards.
h This ICR assumes 80 percent of existing and new plants will report no excess emissions (77×80% = 62, after rounding).
i This ICR assumes no coating lines at any existing or new plants will exceed the cutoff value.
j This burden applies to new plants and existing plants that modify or reconstruct coating operations or coating mix preparation equipment. Per footnote a, EPA estimates one new plant per year and 4 existing plants with new coating lines per year.
k This ICR assumes there will be one malfunction or shutdown every 2 weeks over 50 weeks per year, or 25 occurrences per year (50/2 = 25).
l This ICR assumes operating parameters will be recorded over 350 days per year.
m This assumes 20 percent of existing and new plants will record VOC use estimates (77×20% = 15, after rounding).
n 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: Annual Respondent Burden and Cost – NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR Part 60, Subpart VVV) (Renewal)
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
New facilities										Labor Rates
Notification of construction/ reconstruction	2	1	2	5	10	0.5	1	$611.33		Management	$73.46
Notification of actual startup	2	1	2	5	10	0.5	1	$611.33		Technical	$54.51
Notification of initial performance test	2	1	2	5	10	0.5	1	$611.33		Clerical	$29.50
Notification of VOC use at end of initial year	2	1	2	1	2	0.1	0.2	$122.27
Performance test results	8	1	8	5	40	2	4	$2,445.32
New and existing facilities
Report of monitoring exceedances and non-compliance periods c	8	4	32	15	492.8	24.64	49.28	$30,126.34
Report of no excess emissions d	2	2	4	62	246.4	12.32	24.64	$15,063.17
Report when 1st projected VOC use exceeds cutoff	2	1	2	2	4	0.2	0.4	$244.53
Report when 1st actual 12-month VOC use exceeds cutoff e	2	1	2	0	0	0.0	0	$0
Notification of changes f	2	1	2	5	10	0.5	1	$611.33
TOTAL (rounded) g					950			$50,400
Assumptions:
a On average, EPA estimates 76 existing plants and one new plant per year will be subject to the NSPS over the 3-year period of this ICR. This ICR assumes 4 existing plants per year will install new coating lines.
b This ICR uses the following labor rates: Managerial, $73.46 (GS-13, Step 5, $45.91 + 60%); Technical, $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (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 ICR assumes 20 percent of existing and new plants will report monitoring exceedances or non-compliance periods on a quarterly basis (77×20% = 15, after rounding). These plants will comply though either the emission reduction, alternative, or coating mix preparation equipment standards.
d This ICR assumes 80 percent of existing and new plants will report no excess emissions (77×80% = 62, after rounding).
e This ICR assumes no coating lines at any existing or new plants will exceed the cutoff value.
f This burden applies to new plants and existing plants that modify or reconstruct coating operations or coating mix preparation equipment. Per footnote a, EPA estimates one new plant per year and 4 existing plants with new coating lines per year.
g 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	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)			2008 CEPCI	2022 CEPCI
VOC Monitor	$56,726	1	$56,726	$12,054	76	$916,121			575.4	816
Temperature Monitor	$12,054	1	$12,054	$2,836	76	$215,558
Totals (rounded) a			$68,800			$1,130,000		$1,200,000
a Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.
b Costs have been increased from 2008 to 2022 $ using the CEPCI Equipment Cost Index.

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Sheet 5: Responses

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 construction/ reconstruction	5	1	0	5
Notification of actual startup	5	1	0	5
Notification of initial performance test	5	1	0	5
Notification of VOC use at end of initial year	1	1	0	1
Report of performance test	5	1	0	5
Report of repeat performance test	1	1	0	1
Report of monitoring exceedances and non-compliance periods	15.4	4	0	61.6
Report of no excess emissions	61.6	2	0	123.2
Report when 1st projected VOC use exceeds cutoff	2	1	0	2
Report when 1st actual 12-month VOC use exceeds cutoff	0	1	0	0
Notification of changes	5	1	0	5
			Total	214

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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	5	75	0	4	76
2	5	76	0	4	77
3	5	77	0	4	78
Average	5	76	0	4	77
a New respondents include sources with constructed and reconstructed affected facilities.