Burden Calculation Tables

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Overview

Table 1
Table 2
Capital & O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost - NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (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	ERG Notes	Labor Rates
1. Applications	N/A									149.35	Managerial
2. Survey and Studies	N/A									112.98	Technical
3. Reporting requirements										54.81	Clerical
A. Familiarization with the regulatory requirementsa	4	1	4	48	192	9.6	19.2	$24,178.27	added respondents to estimate burden for this requirement.
B. Required activities
Initial oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Repeat oxidizer performance test c	30	0.07	2.1	0	0	0	0	$0
Initial capture performance test, or review design criteria to ensure capture system meets design criteria for a permanent total enclsosure (PTE) c, l	8	0.07	0.56	0	0	0	0	$0
Repeat capture performance test c, l	8	0.07	0.56	0	0	0	0	$0
Emission rate limit compliance determination	16	12	192	0	0	0	0	$0
Startup, shutdown, malfunction plan	32	1	32	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information k	60	1	60	48	2,880	144	288	$362,674.08
E. Write Report
Initial notification	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0	This is no longer required in the General Provisions, it has been reserved and removed, so removed from this table.
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of compliance status	4	1	4	0	0	0	0	$0
Performance test notification c	2	0.07	0.14	0	0	0	0	$0
Performance test report c	40	0.07	2.8	0	0	0	0	$0
Semiannual report of exceedances d, e	16	2	32	5	160	8	16	$20,148.56
Semiannual report of no exceedances f, g	8	2	16	43	688	34.4	68.8	$86,638.81
Startup, shutdown, malfunction report h	8	2	16	5	80	4	8	$10,074.28
Subtotal for Reporting Requirements					4,600			$503,714.00
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 4B
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards i	4	52	208	48	9,984	499.2	998.4	$1,257,270.14
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 j	0.25	2	0.5	48	24	1.2	2.4	$3,022.28
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					11,509			$1,260,292
TOTAL LABOR BURDEN AND COST (rounded)m					16,100			$1,760,000
Total CAPITAL and O&M COST (rounded)m								$57,600		# responses	Hrs/Respondent
GRAND TOTAL (rounded)m					16,100			$1,820,000		106	152
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. 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: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 This is a one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting. The one-time startup costs were annualized over the 15-year life of control equipment at 7 percent interest. The number of occurrences per respondent per year is annualized over the 15 year life of the control equipment. Because there are no new sources, no performance tests are expected to occur. It is assumed that the facility would contract out the performance testing costs, but some labor hours from facility staff would be involved with coordinating and observing the test and reviewing the results.
d We have assumed that exceedances are reported semiannually.
e We have assumed that 10 percent of respondents will report exceedances (48 x 0.1 = 4.8, or 5 respondents, when rounded).
f Reports indicating no exceedances are required semiannually.
g We have assumed that 90 percent of respondents will report no exceedances (48 x 0.9 = 43.2, or 43 respondents, when rounded).
h We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction report semiannually (48 x 0.1 = 4.8, or 5 respondents, when rounded).
i We have assumed that all information is entered on a weekly basis.
j We have assumed that each of the 48 respondents will take 15 minutes to transmit or disclose information twice a year.
k Based on comments we received from industry consultation, 60 hrs per respondent is required to gather and evaluate information in preparation of semiannual reports
l We have assumed that emission capture systems meet the design criteria for a permanent total enclosure in EPA Method 204, so that capture efficiency does not need to be measured.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost - NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b		Labor Rates
Initial performance test	48	0	0	0	0	0	0	$0		64.8	Managerial
Repeat performance test-retesting preparation	4	0	0	0	0	0	0	$0		48.08	Technical
Repeat performance-retesting	48	0	0	0	0	0	0	$0		26.02	Clerical
Excess emissions enforcement activities	120	1	120	0	0	0	0	$0
Review reports
Notification of applicability	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of compliance status	2	1	2	0	0	0	0	$0
Review of initial performance test report	8	1	8	0	0	0	0	$0
Review of repeat performance test report	8	1	8	0	0	0	0	$0
Semiannual report of excess emissions c, d	8	2	16	5	80	4	8	$4,313.76
Semiannual report of no excess emissions e, f	2	2	4	43	172	8.6	17.2	$9,274.58
Review of NESHAP waiver application	N/A
Review startup, shutdown, malfunction report g	2	2	4	5	20	1	2	$1,078.44
TOTAL (rounded)h					313			$14,700
Assumptions:
a We have assumed that there are approximately 48 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Because there are no new sources, no performance tests are expected to occur.
b This cost is based on the following hourly labor rates increased by 60 percent to account for the benefit packages available to government employees: $64.80 for Managerial (GS-13, Step 5, $40.50 + 60%), $48.08 for Technical (GS-12, Step 1, $30.05 + 60%) and $26.02 Clerical (GS-6, Step 3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c It is assumed that 10 percent of respondents will report excess emissions (48 x 0.1 = 4.8, or 5 respondents, when rounded).
d It is assumed that reports of excess emissions are required semiannually.
e We have assumed that 90 percent of respondents will report no excess emissions (48 x 0.9 = 43.2, or 43 respondents, when rounded).
f It is assumed that reports of no excess emissions are required semiannually.
g We have assumed that 10 percent of respondents will submit startup, shutdown, malfunction reports to be reviewed (48 x 0.1 = 4.8, or 5 respondents, when rounded).
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital & O&M

Assumption: Monitoring Devices
According to industry consultation comment received, the O&M cost to maintain continuous temperature measuring monitor is $1,200 per respondent. The cost covers replacement of temperature sensor each calendar year.
Facility	Number of Lines	Monitoring Device	Cost ($)	Total Cost ($)
48	1	Continuous temperature monitor	$1,200	$57,600
Assumption: Stack Testing (Method 25 or 25A)
Costs included for a one-time initial performance test using Method 25 or Method 25A for facilities with control devices. It is assumed that all of the existing facilities have conducted an initial performance test.
Facility	Stacks per Facility	Tests Per Year	Cost ($)	EAC w/ 7% Discount (15-year)	Total Cost ($)
0	1	1	Tracy Curtis: Emissions compliance testing capital costs were annualized at 7 percent interest over the 15-year lifespan of the control. The one-time estimated costs per add-on control range from $18,500 to $18,750 for Method 25 and or 25A, and assumes that emissions are measured simultaneously at the inlet and outlet of the device to measure destruction efficiency. These costs also assume that emission capture systems meet the design criteria for a permanent total enclosure in EPA Method 204, so that capture efficiency does not need to be measured. $18,750	$2,058.65	$0