2294.07 Burden 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	22
Number of Respondents	2900
Total Estimated Burden Hours	67,700
Total Estimated Costs	$9,270,000
Annualized Capital O&M	Not Applicable
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost - NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart WWWWWW) (Renewal)
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 year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year b
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Familiarization with Regulatory Requirements c	1	1	1	2,900	2,900	145	290	$456,768.85
B. Required activities											Labor Rates
Initial Notification of applicability d	2	1	2	0	0	0	0	$0			Technical	$141.75
Notification of Compliance Status e	4	1	4	0	0	0	0	$0			Management	$172.41
Annual Compliance Certification f	2	1	2	2,900	5,800	290	580	$913,537.70			Clerical	$71.36
Annual Report of Deviations g	2	1	2	145	290	14.5	29	$45,676.89
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Reporting Subtotal					10,339			$1,415,983
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information	N/A
Records of all information required by standards h	0.33	52	17.16	2,900	49,764	2,488.2	4,976.4	$7,838,153.47
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information i	0.25	1	0.25	290	72.5	3.63	7.25	$11,419.22
I. Time for audits	N/A
Recordkeeping Subtotal					57,312			$7,849,572.69
TOTAL LABOR BURDEN AND COST (rounded)j					67,700			$9,270,000
TOTAL CAPITAL AND O&M COST (rounded)j								$0
GRAND TOTAL (rounded)j								$9,270,000
										22	hours per response
Assumptions
a There are an estimated 2,900 existing plating and polishing plants and no new facilities are expected.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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 assume that each source subject to the standard will have to familiarize with the regulatory requirements each year.
d Each of the 2,900 existing plants noted above would have already submitted an initial notification. Since there are no new facilities expected, the number of respondents required to submit an initial notification is 0.
e Each of the 2,900 existing plants noted above would have already submitted a notification of compliance status by the appropriate compliance date. Since there are no new facilities expected, the number of respondents required to submit a notification of compliance status is 0.
f The 2,900 existing plants would be required to prepare an annual compliance certification every year. They would only submit the certifications if a deviation occurred; assuming that 5 percent of the plants experience a deviation, the number of compliance certifications submitted will be (2,900*0.05) = 145.
g Assumes that 5% of existing facilities would have to submit a report of deviations starting in Year 3 of the ICR clearance period, or (2,900 * 0.05) = 145 facilities.
h It is assumed that 0.33 hr (20 minutes) per week will be required per facility for recordkeeping.
i Annual transmittals would include submission of annual compliance certifications (145) and reports of deviations (145) for 5% of one-third of 2,900 facilities, so (2,900* 0.05) *2 = 145 *2 = 290 respondents.
j 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 Plating and Polishing Operations (40 CFR Part 63, Subpart WWWWWW) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Person-hours per occurrence	No. of occurrences per respondent per year	EPA Person-hours per plant per year (A) x (B)	Plants per year	Technical person-hours (C) x (D)	Managerial person-hours (E) x 0.05	Clerical person-hours (E) x 0.10	Cost, $ a
Report Review:										Labor Rates
Initial Notification of applicability b	1	1	1	0	0	0	0	$0		Technical	$57.07
Notification of Compliance Status c	2	1	2	0	0	0	0	$0		Management	$76.91
Annual Compliance Certification d	2	1	2	145	290	14.5	29	$18,561.02		Clerical	$30.88
Annual Report of Deviations e	2	1	2	145	290	14.5	29	$18,561.02
TOTAL ANNUAL BURDEN AND COST (rounded)f					667			$37,100
Assumptions
a This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 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.
b Assumes no new plants in the next three years.
c Each of the 2,900 existing plants noted above would have already submitted a notification of compliance status by the appropriate compliance date. Since there are no new facilities expected, the number of respondents required to submit a notification of compliance status is 0.
d The 2,900 existing plants would be required to prepare an annual compliance certification; any plant that experiences a deviation will have to submit the compliance certification; assuming 5 percent of the plants experience a deviation during the three year ICR period, the number of submittals would be (2,900 * 0.05) =145.
e Assumes that 5% of existing facilities would have to submit a report of deviations in the three-year ICR period, or (2,900 * 0.05) = 145.
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

Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities required by the subject standards are labor costs. There are no capital/startup or operation and maintenance costs.

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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
Initial Notification of Applicability	0	1	N/A	0
Notification of Compliance Status	0	1	N/A	0
Annual Compliance Certification	145	1	2755	2900
Annual Report of Deviations	145	1	N/A	145
		Total		3045

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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 1 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	145	2755	0	2900
2	0	145	2755	0	2900
3	0	145	2755	0	2900
Average	0	145	2755	0	2900
1 a New respondents include sources with constructed, reconstructed and modified affected facilities.