Burden Calculation Tables

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Overview

# Respondents
#Responses
Table 1 - Respondent Burden
Table 2 - Agency Burden
Capital-Start-up

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Sheet 1: # Respondents

NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces (40 CFR Part 60, Subpart QQQQ) (Renewal)
Number of Respondents That are Manufacturers
	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	50	0	0	50
2	0	50	0	0	50
3	0	50	0	0	50
Average	0	50	0	0	50
Assumptions
Assumes there are 32 hydronic heater manufacturers with 127 model lines, 7 forced-air furnace manufacturers with 19 model lines, and 11 laboratories acting as testing labs and/or third-party certifiers.
EPA-approved Test Labs and Third-party Certifying Entities for 2015 Residential Wood Heaters NSPS
Name	EPA-approved Test Lab			EPA-approved Third-Party Certifier			Expiration Date of EPA Aproval
	Wood Stove	Forced Air Furnace	Hydronic Heater	Wood Stove	Forced Air Furnace	Hydronic Heater
PFS-TECO	Yes	Yes	Yes	Yes	Yes	Yes	2/5/2023
Intertek	Yes	Yes	Yes	Yes	Yes	Yes	10/30/2020	<will need to obtain reapproval as test lab and certifier
OMNI	Yes	Yes	Yes	Yes	Yes	Yes	10/8/2020	<will need to obtain reapproval as test lab and certifier
Polytests Inc.	Yes	Yes	Yes	No	No	No	10/30/2020	<will need to obtain reapproval as test lab
PFS Corp.	No	No	No	Yes	Yes	Yes	11/4/2020	<will need to obtain reapproval as certifier
CSA Group	No	No	No	Yes	Yes	Yes	11/3/2020	<will need to obtain reapproval as certifier
UL, LLC	No	No	No	Yes	Yes	Yes	11/12/2020	<will need to obtain reapproval as certifier
Research Institutes of Sweden (RISE)	Yes	Yes	Yes	Yes	Yes	Yes	11/14/2022
ClearStak, LLC	Yes	Yes	Yes	No	No	No	11/7/2021
SZU	Yes	Yes	Yes	Yes	Yes	Yes	4/17/2022
Danish Technological Institute	Yes	Yes	Yes	No	No	No	11/22/2022
Source: U.S. Environmental Protection Agency. (April 10, 2018). EPA-approved Test Labs and Third-Party Certifiers for Residential Wood Heaters. Accessed December 7, 2018. Retrieved from https://www.epa.gov/burnwise/epa-approved-test-labs-and-third-party-certifiers-residential-wood-heaters. "epa_approved_labs_and_third_party_certifiers_11-15-17.pdf"

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Sheet 2: #Responses

NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces (40 CFR Part 60, Subpart QQQQ) (Renewal)
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
Manufacturers
Certification test notification a,b	39	1.25	N/A	48.7
Application for certification/re-certification b	39	1.25	N/A	48.7
Biennial reporting c	39	1.9	N/A	73
EPA compliance audit testing d	1	0.33	N/A	0
QA performance test results e	39	0.33	N/A	13
QA annual audit reports f	8	4.88	N/A	39
Review annual QA audit report g	39	0.33	N/A	13
Test Laboratories
Application for test lab approval - already has ISO accreditation h	5	0	N/A	0
Application for test lab approval - needs to obtain ISO accreditation h	3	1	N/A	3
Biennial proficiency testing and report development i	8	0.5	N/A	4
Third-Party Certifiers
Application for approval as a third-party certifier - already has ISO accreditation j	3	0	N/A	0
Application for approval as a third-party certifier - already has ISO accreditation j	5	1	N/A	5
Certification test, QA program report, credentials k	8	12	N/A	39
			Total	287
			hrs/response:	15
Assumptions:
a Assume there are 32 hydronic heater manufacturers with 127 model lines, 7 forced-air furnace manufacturers with 19 model lines, and 11 laboratories acting as testing labs and/or third-party certifiers.
b Over the next three years, assume a like number of existing models certified to 2015 standards are replaced with models certified to 2020 standards and certification testing is performed.
c Report every certified model 0.5 times per year
d One model gets audited in the three-year period
e 1 QA audit performance test per mfr. in the 3-year period.
f Assumes there will be three QA audits by third-party certifiers for each of the 39 manufacturers over the three-year ICR period and that each of these audit reports will be reviewed by the manufacturer (in all cases) and may require preparing a response to the audit (in cases where deficiencies are identified).
g Review the report of annual QA audit for each model line.
h All 8 testing labs are ISO accredited and certified by EPA. Three tests labs will require ISO re-accreditation in the three year period.
i 8 labs participate in proficiency testing every 2 years
j All 8 third-party certifiers are ISO accredited and certified by EPA. Five certifiers will require ISO re-accreditation in the three year period.
k All 8 third-party certifiers will file certification tests, QA program reports, and their credentials with EPA.

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Sheet 3: Table 1 - Respondent Burden

Table 1: Annual Respondent Burden and Cost - NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces (40 CFR Part 60, Subpart QQQQ) (Renewal)
Burden Item	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per year	(E) Technical hours per year (E=CxD)	(F) Management hours per yeara (F=Ex0.05)	(G) Clerical person-hours per yeara (G=Ex0.1)	(H) Total Cost per year,$ b
Reporting Requirements
Manufacturers
1. Certification test notification c	2	1.25	2	39	97.3	4.9	9.7	$12,750.08
2. Application for certification c	8	1.25	10	39	389.3	19.5	38.9	$51,000.33		Labor Rates		Notes:
3. Biennial reporting d	2	1.9	4	39	146.0	7.3	14.6	$19,125.12		Management	$147.40	Updated 12/3/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
4. EPA compliance audit testing e	8	0.33	2.7	1	2.7	0.1	0.3	$348.97		Technical	$117.92	Updated 12/3/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
5. QA performance test results f	2	0.33	1	39	26.0	1.3	2.6	$3,402.44		Clerical	$57.04	Updated 12/3/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
6. QA annual audit reports g, h	20	4.88	97.5	8	780.0	39.0	78.0	$102,175.32
7. Review annual QA audit report g	4	0.33	1.3	39	52.0	2.6	5.2	$6,811.69
Test Laboratories
1. Application for test lab approval h
a. Already has ISO accreditation	20	0	0	5	0.0	0.0	0.0	$0
b. Needs to obtain ISO accreditation	80	1	80	3	240.0	12.0	24.0	$31,439
2. Biennial profiency testing and report development i	150	0.5	75	8	600.0	30.0	60.0	$78,596.40
Third-Party Certifier
1. Application for approval as a third-party certifier j
a. Already has ISO accreditation	20	0	0	3	0.0	0.0	0.0	$0
b. Needs to obtain ISO accreditation	80	1	80	5	400.0	20.0	40.0	$52,398
2. Certification test, QA program report, credentials k	2	12	23	8	185.3	9.3	18.5	$24,278	<-- new line item, includes submittal of certification,QA audit reports, and credentials.
Subtotal for Reporting Requirements					3,356			$382,324.07
Recordkeeping Requirements
Manufacturers
1. Test and re-certification documentation l	1	1.25	1	39	48.7	2.4	4.9	$6,375.04
2. QA parameter inspections m	2	4	8	39	312.0	15.6	31.2	$40,870.13
3. Retained (sealed) stoves n	1	1.25	1	39	48.7	2.4	4.9	$6,375.04
Test Laboratories
1. Certification test, proficiency test, and audit test results o	2	12	24	8	192.0	9.6	19.2	$25,150.85
Third-Party Certifier
1. Certification test, QA program inspection and audit tests p	2	12	24	8	192.0	9.6	19.2	$25,150.85
Subtotal for Recordkeeping Requirements					912			$103,922.00
TOTAL Labor Burden and Costs (rounded) q					4,270			$486,000
TOTAL Capital and O&M Cost (rounded) q								$4,280,000
GRAND TOTAL (rounded) q								$4,770,000
Footnotes:
a Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
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% to account for the benefit packages available to those employed by private industry.
c Assume there are 32 hydronic heater manufacturers with 127 model lines and 7 forced-air furnace manufacturers with 19 model lines. Over the next three years, assume a like number of existing models certified to 2015 standards are replaced with models certified to 2020 standards and certification testing is performed.
d Manufacturers submit a report for every certified model 0.5 times per year, at 2 hours per report.
e Assumes that one of the manufacturers will be required to undergo an EPA compliance audit test for one of their models during the three-year ICR period.
f Assumes that there will be one QA audit performance test per manufacturer under the QA program during the 3-year period.
g 40 CFR 60.5475(m) requires an annual audit of the QA plan for each model line. Assumes there will be three QA audits by third-party certifiers for each of the 39 manufacturers over the three-year ICR period and each of these audit reports will be reviewed by the manufacturer (in all cases) and may require preparing a response to the audit (in cases where deficiencies are identified).
h Assume that there are 11 laboratories acting as testing labs and/or third-party certifiers, including 8 testing labs. The 8 testing labs are currently certified by EPA; 3 testing labs are certified through the end of 2020 and would be anticipated to reapply for re-accreditation in the three-year period.
i Assume 8 testing labs participate in proficiency testing every 2 years. 40 CFR 5479(b) requires that each approved test laboratory submit accreditation credentials and all proficiency test results to the Administrator.
j Assume 8 third-party certifiers are ISO accredited and currently certified by EPA; 5 third-party certifiers are certified through the end of 2020 and would be anticipated to reapply for re-accreditation in the three-year period.
k 40 CFR 63.5479(b) requires that each third-party certifier must submit each certification test, quality assurance program inspection report and ISO-IEC accreditation credentials to the Administrator.
l Assumes that manufacturers will spend one hour per certification test and recertification to keep the required records.
m Quality parameter inspections are part of the existing safety inspections program. Assume that all manufacturers (39) will spend 2 hours per quarter to document results for each certified model.
n Assumes that one stove is sealed and retained for each certification test. Assumes all stoves certified to 2015 standard and all stoves certified to 2020 standard are stored for the 3-year period.
o Proficiency testing is required every two years for each lab. Assume that test laboratories will spend 2 hours per month to maintain the required records.
p Quality assurance program inspections are performed annually for each certified model. Assume that third-party certifiers will spend 2 hours per month to maintain the required records.
q Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 4: Table 2 - Agency Burden

Table 2: Average Annual EPA Burden and Cost - NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces (40 CFR Part 60, Subpart QQQQ) (Renewal)
Burden Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per year	(C) EPA person-hours per year (C=AxB)	(D) Respondents per year	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours a per year (F=Ex0.05)	(G) Clerical person-hours a per year (G=Ex0.1)	(H) Total Cost per year,$ b
1. Review certification test notification c	0.5	1.25	0.6	39	24.3	1.2	2.4	$1,330.39		Labor Rates		Notes:
2. Observe certification test d	20.0	1	20.0	8	160.0	8.0	16.0	$8,747.76		Management	$65.71	Updated 12/3/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
3. Review application for certification of model line c	8.0	1.25	10.0	39	389.3	19.5	38.9	$21,286.22		Technical	$48.75	Updated 12/3/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
4. Biennial reporting for certified models e	1.0	1.9	1.9	39	73.0	3.7	7.3	$3,991.17		Clerical	$26.38	Updated 12/3/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
5. Review and approval of test lab credentials f	4.0	0	0	3	0.0	0.0	0.0	$0.00
6. Review test lab biennial proficiency test reports g	10.0	0.5	5.0	8	40.0	2.0	4.0	$2,186.94
7. Review QA performance test results h	2.0	0.33	0.7	39	26.0	1.3	2.6	$1,420.09
8. Review QA audit report i	2.0	5	9.8	8	78.0	3.9	7.8	$4,264.53
9. EPA Compliance Audit j	40.0	0.33	13.3	1	13.3	0.7	1.3	$728.25
10. Review and approval of third-party certifier credentials k	8.0	0	0	5	0.0	0.0	0.0	$0
TOTAL (rounded) l					925			$44,000
Footnotes:
a Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (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.
c Assume there are 32 hydronic heater manufacturers with 127 model lines, 7 forced-air furnace manufacturers with 19 model lines. Over the next three years, assume a like number of existing models certified to 2015 standards are replaced with models certified to 2020 standards and certification testing is performed.
d Assumes that EPA will observe 20 percent of certification tests (5.3/year x 0.2) conducted during the ICR reporting period, which is rounded to 1 test per year.
e Assumes that the EPA will receive one biennial report for each of the certified model lines over the 3-year ICR period.
f Assumes 8 testing labs are currently approved by EPA; 3 testing labs are certified through the end of 2020 and would be anticipated to reapply for re-accreditation in the three-year period.
g Assumes that each testing lab conducts a laboratory proficiency test every two years.
h Assumes that there will be one QA audit performance test per manufacturer under the QA program during the 3-year period.
i Assumes that EPA will review the QA audits performed by the third-party certifiers on each certified model line over the three-year ICR period.
j Assumes that one model line for one of the manufacturers will be audited by the EPA during the ICR three-year period.
k Assumes 8 third-party certifiers are currently certified by EPA; 5 third-party certifiers are certified through the end of 2020 and would be anticipated to reapply for re-accreditation in the three-year period.
l Totals have been rounded to three significant values. Figures may not add exactly due to rounding.

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Sheet 5: Capital-Start-up

NSPS for New Residential Hydronic Heaters and Forced-Air Furnaces (40 CFR Part 60, Subpart QQQQ) (Renewal)
(A)	(B)	(C)	(D)
Data Collection Device	Capital/Start-Up for One Respondent/Unit	Number of New Respondents/Models per Year	Total Capital/Start-Up Cost (B x C)
Certification Test a	$55,000 per model	49 models	$2,695,000	<-- adjusted formula to round # of models tested per year
Cost of Permanent Label b	$1,250 per model	49 models	$61,250	<-- adjusted formula to round # of models tested per year
QA Performance Test c	$55,000 per respondent	13 respondents	$715,000	<-- adjusted formula to round # of respondents per year
EPA Compliance Audit Test d	$63,564 per model	0.33 model	$20,976	<-- adjusted formula to round # of respondents per year
Owners Manual e	$3,750 per model	49 models	$183,750	<-- adjusted formula to round # of models tested per year
ISO Accreditation-Test Laboratories f	$75,000 per respondent	3 respondents	$225,000
ISO Accreditation-Third-Party Certifiers g	$75,000 per respondent	5 respondents	$375,000
Annual Totals h			$4,280,000
a We assume that manufacturers will test approximately 49 new models per year (127 hydronic heater models + 19 forced-air furnace models / 3 years = 48.667 models or 49 models) at a cost of $55,000 per test (includes EPA testing ($30,000), confirmation safety testing or full safety testing ($22,500), and shipping of prototype(s)($2,500) costs)) and apply to meet Step 2 emission standards during the three year ICR period.
b Total costs of permanent labels are estimated to be $1,250 per model.
c Assumes each of the manufacturers will be required to test one of their models under their QA program during the period covered by this ICR (2019-2021) at $55,000 per test ( includes EPA testing ($30,000), confirmation safety testing or full safety testing ($22,500), and shipping of prototype(s)($2,500) costs) (39 manufacturers * 1 model / 3 years = 13 manufacturers/model/year).
d Assumes one model line will be audited by EPA during the three-year ICR period (2019 – 2021). Costs assume the cost of one appliance (based on the average cost of three appliances: 1 outdoor ($11,571) and 1 indoor ($11,543) hydronic heater and 1 forced-air furnace ($2,579)) plus the cost of testing at $55,000 (assumes EPA testing costs of $30,000, full safety cost of $22,500 and $2,500 in shipping costs).
e Assumes an average fixed cost of $3,750 for owner's manual (revised or new, possibly bilingual) per model certified.
f 8 testing labs are ISO-accredited. 8 labs are currently certified by EPA, and 3 labs would require recertification following 2020. We assume an average cost to obtain ISO accreditation is $75,000 based on cost estimates provided by manufacturers.
g 8 third-party certifiers are ISO accredited. 8 are currently certified by EPA and 5 would require recertification following 2020. We assume an average cost to obtain ISO accreditation is $75,000 based on cost estimates provided by manufacturers.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.