Burden Calculation Tables

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Overview

Cover
Inputs
Current ICR
TBL1-ResY1
TBL2-ResY2
TBL3-ResY3
TBL4-ResSUM
TBL5-EPAY1
TBL6-EPAY2
TBL7-EPAY3
TBL8-EPA SUMMARY

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Sheet 1: Cover

ATTACHMENT 1

SUPPORTING STATEMENT

National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Fabricaiton Operations (40 CFR Part 63, Subpart MMMMM)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for theFlexible Polyurethane Foam Fabricaiton Operations NESHAP Residual Risk and Technology Review – Years 1-3

TABLE 4

Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Flexible Polyurethane Foam Fabricaiton Operations NESHAP Residual Risk and Technology Review

TABLES 5, 6, and 7

Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Flexible Polyurethane Foam Fabricaiton Operations NESHAP Residual Risk and Technology Review - Year 1-3

TABLE 8

Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Flexible Polyurethane Foam Fabricaiton Operations NESHAP Residual Risk and Technology Review

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Sheet 2: Inputs

Respondent Wages ($2019)
Category (1)	Hourly Mean Wage (2)	Loaded Wage (3)
Technical	$50.64	$106.35
Managerial	$65.58	$137.72
Clerical	$20.45	$42.95
Footnotes:
(1) The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2019 National Industry-Specific Occupational Employment and Wage Estimates NAICS 326000 - Plastics and Rubber Products Manufacturing," accessed December 1, 2020 and found here:
https://www.bls.gov/oes/current/naics3_326000.htm
(2) Selected "mean hourly wage" in the table referenced in footnote 1. These values are based on May 2019 data, and differ from previous ICR wage values that were based on 2018 data.
(3) Loaded Wage is the 2019 Wage increased by 110 percent to account for the benefit packages available to those employed by private industry.
EPA Wages ($2019)
Category (1)	Hourly Mean Wage (2)	Wage With Fringe & Overhead (3)
(GS- 12, step 1) - Technical	$30.90	$49.44
(GS- 13, step 5) - Managerial	$41.64	$66.63
(GS-6, step 3) - Clerical	$16.72	$26.76
Footnotes:
(1) The hourly mean wage for each category is based on 2019 wages, and are found here:
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/19Tables/html/GS_h.aspx
(2) This value differs from the wages used in the 2019 ICR amendments, which were based on 2018 rates of pay
(3) Wage with fringe and overhead is the hourly mean wage increased by 60 percent to account for the benefit packages available to government employees.

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Sheet 3: Current ICR

Table: Annual Respondent Burden and Cost – Flexible Polyurethane Foam Fabrication NESHAP (40 CFR Part 63, Subpart MMMMM) (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			2019 ICR Wages
1. Familiarize with regulatory requirements	4	1	4	0	0	0	0	$0		Technical	$106.35
2. Gather information	4	1	4	3	12	0.6	1.2	$1,410		Managerial	$137.72
3. Reports
a. Initial notification	2	1	2	0	0	0	0	$0		Clerical	$42.95
b. Application for construction/ reconstruction	2	1	2	0	0	0	0	$0
c. Notification of performance test	2	1	2	1	2	0.1	0.2	$235
d. Notification of compliance status	20	1	20	3	60	3	6	$7,052
e. Initial compliance report
i. Flame lamination facilities	8	1	8	0	0	0	0	$0
ii. Loop slitter facilities	8	1	8	0	0	0	0	$0
f. Annual compliance report c	2	1	2	0	0	0	0	$0
g. Semiannual compliance report	4	2	8	0	0	0	0	$0
Reporting Subtotal					85			$8,697.29
4. Recordkeeping requirements
a. Plan activities	10	1	10	1	10	1	1	$1,175
b. Implement activites for flame lamination
i. Conduct performance test	50	2	100	0	0	0	0	$0
ii. Record CPMS calibration and maintenance	2	2	4	0	0	0	0	$0
iii. CPMS calibration and maintenance e	4	2	8	0	0	0	0	$0
c. Implement activities for loop slitters
i. Record adhesives used and suppliers	1	1	1	3	3	0	0	$353
ii. Conduct Method 311 test	4	1	4	0	0	0	0	$0
d. Develop record system
i. CPMS maintenance plan	20	1	20	0	0	0	0	$0
e. Time to train personnel
i. CPMS acquisition and installation	20	1	20	0	0	0	0	$0
ii. CPMS inspection and monitoring	4	1	4	0	0	0	0	$0
f. Store, file, and maintain all records f	1	12	12	3	36	2	4	$4,231
g. Retrieve records/reports g	1	12	12	3	36	2	4	$4,231
Subtotal for Recordkeeping Requirements					12			$1,175
TOTAL ANNUAL BURDEN AND COST (ROUNDED)					100			$10,000
Capital and O&M Cost (see Section 6(b)(iii))								$800
GRAND TOTAL (rounded)n								$10,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $137.72 per hour for Executive, Administrative, and Managerial labor; $106.35 per hour for Technical labor, and $42.95 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2019 National Industry-Specific Occupational Employment and Wage Estimates NAICS 326000 - Plastics and Rubber Products Manufacturing,, have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c Applies to loop slitter adhesive facilities only
d We have assumed that there will be no new sources expected over the three-year period of this ICR.
e EPA assumes each respondent will implement CPMS calibration and maintenance activities 50 times per year.
f We have assumed that one respondent will request to return to semiannual compliance reporting.
g EPA assumes each respondent will retrieve records/reports 12 times per year.
Table: Average Annual EPA Burden and Cost – NESHAP for Flexible Polyurethane Foam Fabrication Operations NESHAP (40 CFR Part 63, Subpart MMMMM) (Residual Risk and Technology Review)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year b
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)
Review initial notification for existing sources	4	1	4	2	8	0.4	0.8	$574		Managerial	$66.63
Review application for construction/reconstruction	4	1	4	0	0	0	0	$0		Technical	$49.44
Review notification of performance test	4	1	4	2	8	0.4	0.8	$574		Clerical	$26.76
Review notification of compliance status	20	1	20	2	40	2	4	$2,871
Review initial compliance report					0	0	0	$0
Flame lamination facilities	20	1	20	2	40	2	4	$2,871
Loop slitter facilities	2	1	2	0	0	0	0	$0
Review annual compliance report c		1	30	3	90	4.5	9	$6,460
Review semiannual compliance report	20	1	20	0	0	0	0	$0
TOTAL LABOR BURDEN AND COST (rounded)d					220			$13,400
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b This cost is based on the labor rates as described in "Inputs!B8"
c Applies to Loop Slitter Facilities only
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 4: TBL1-ResY1

Table 1 : Annual Respondent Burden and Cost Year One – Flexible Polyurethane Foam Fabrication NESHAP (40 CFR Part 63, Subpart MMMMM) (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			2019 ICR Wages
1. Applications	N/A									Technical	$106.35
2. Surveys and studies	N/A									Managerial	$137.72
3. Familiarize with regulatory requirements	4	1	4	3	12	0.6	1.2	$1,410		Clerical	$42.95
4. Required activities for sources with add-on control devices	N/A
a. Initial performance test and report	50	1	50	2	100	5	10	$11,753
b. Establish operating parameters	N/A
5. Required activities for sources using pollution prevention measures	N/A
a. Develop recordkeeping system	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
c. Work practice requirements	N/A
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					129			$13,163
8. Notification requirements
a. Initial notification that existing sources are subject to the standard	N/A
b. Notification for new major sources	N/A
c. Request for compliance extension	N/A
d. Notification of special compliance requirements	N/A
e. Notification of performance tests	2	1	2	2	4	0.2	0.4	$470
f. Notification of compliance status	20	1	20	3	60	3	6	$7,052
9. Reporting requirements
a. Semiannual compliance reports for all sources c	8	2	16	3	48	2.4	4.8	$5,641
b. Additional reports for sources with add-on control devices	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	4	1	4	3	12	0.6	1.2	$1,410
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	3	18	0.9	1.8	$2,116
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10.a.
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					163			$16,689
TOTAL LABOR BURDEN AND COST					292			$29,853
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)d								$30,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2019 National Industry-Specific Occupational Employment and Wage Estimates NAICS 326000 - Plastics and Rubber Products Manufacturing," accessed December 1, 2020 and found here: https://www.bls.gov/oes/current/naics3_326000.htm. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
cWe have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 5: TBL2-ResY2

Table 2 : Annual Respondent Burden and Cost Year Two – Flexible Polyurethane Foam Fabrication NESHAP (40 CFR Part 63, Subpart MMMMM) (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			2013 ICR Wages
1. Applications	N/A									Technical	$106.35
2. Surveys and studies	N/A									Managerial	$137.72
3. Familiarize with regulatory requirements	0	1	0	3	0	0	0	$0		Clerical	$42.95
4. Required activities for sources with add-on control devices
a. Initial performance test and report	N/A
b. Establish operating parameters	N/A
c. Re-evaluating startup, shutdown, and amlfucntion requirements	0	1	0	3	0	0	0	$0
5. Required activities for sources using pollution prevention measures
a. Develop recordkeeping system	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
	4	12	48	0	0	0	0	$0
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					0			$0.00
8. Notification requirements
a. Initial notification that existing sources are subject to the standard	N/A
b. Notification for new major sources	N/A
c. Request for compliance extension	N/A
d. Notification of special compliance requirements	N/A
e. Notification of performance tests	N/A
f. Notification of compliance status	N/A
9. Reporting requirements
a. Semiannual compliance reports for all sources c	8	2	16	3	48	2.4	4.8	$5,641
b. Additional reports for sources with add-on control devices	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	0	1	0	3	0	0	0	$0
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	3	18	0.9	1.8	$2,116
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10.a.
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					76			$7,757
TOTAL LABOR BURDEN AND COST					76			$7,757
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)d								$8,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2019 National Industry-Specific Occupational Employment and Wage Estimates NAICS 326000 - Plastics and Rubber Products Manufacturing," accessed December 1, 2020 and found here: https://www.bls.gov/oes/current/naics3_326000.htm. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
cWe have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 6: TBL3-ResY3

Table 3 : Annual Respondent Burden and Cost Year Three – Flexible Polyurethane Foam Fabrication NESHAP (40 CFR Part 63, Subpart MMMMM) (Amendments)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			2019 ICR Wages
1. Applications	N/A									Technical	$106.35
2. Surveys and studies	N/A									Managerial	$137.72
3. Familiarize with regulatory requirements	0	1	0	3	0	0	0	$0		Clerical	$42.95
4. Required activities for sources with add-on control devices
a. Initial performance test and report	N/A
b. Establish operating parameters	N/A
c. Re-evaluating startup, shutdown, and amlfucntion requirements	0	1	0	3	0	0	0	$0
5. Required activities for sources using pollution prevention measures
a. Develop recordkeeping system	See 10.a.
b. Enter information into recordkeeping system	See 5.c.
	N/A
6. Create information	See 5.c.
7. Gather information	See 5.c.
Subtotal for Reporting Requirements					0			$0.00
8. Notification requirements
a. Initial notification that existing sources are subject to the standard	N/A
b. Notification for new major sources	N/A
c. Request for compliance extension	N/A
d. Notification of special compliance requirements	N/A
e. Notification of performance tests	N/A
f. Notification of compliance status	N/A
9. Reporting requirements
a. Semiannual compliance reports for all sources c	8	2	16	3	48	2.4	4.8	$5,641
b. Additional reports for sources with add-on control devices	N/A
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	0	1	0	3	0	0	0	$0
b. Plan and develop record system	See 10.a.
c. Record information	6	1	6	3	18	0.9	1.8	$2,116
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10.a.
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					76			$7,757
TOTAL LABOR BURDEN AND COST					76			$7,757
Capital and O&M Cost (see Section 6(b)(iii))								$0
GRAND TOTAL (rounded)d								$8,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b The Wage categories "Technical," "Clerical," and "Managerial" refer to the labor category codes 11-3051, 43-6010, and 11-1021, respectively, in the United States Department of Labor, Bureau of Labor Statistics table titled "May 2019 National Industry-Specific Occupational Employment and Wage Estimates NAICS 326000 - Plastics and Rubber Products Manufacturing," accessed December 1, 2020 and found here: https://www.bls.gov/oes/current/naics3_326000.htm. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
cWe have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 7: TBL4-ResSUM

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Flexible Polyurethane Foam Fabrication NESHAP (40 CFR Part 63, Subpart MMMMM) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	254	13	25	292	$29,853	$0	$30,000
2	66	3	7	76	$7,757	$0	$8,000
3	66	3	7	76	$7,757	$0	$8,000
Total	386	19	39	444	$45,367	$0	$46,000
Average	129	6	13	148	$15,100	$0	$15,000

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Sheet 8: TBL5-EPAY1

Table 5: Average Annual EPA Burden and Cost Year One – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Amendments)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2019 ICR Wages
1. Read instructions	N/A									Technical	$49.44
2. Enter and update information into agency recordkeeping system c	4	1	4	3	12	0.6	1.2	$665.37		Managerial	$66.63
3. Notification review d										Clerical	$26.76
a. Review initial notification for existing sources	N/A
b. Notification for new major sources e	N/A
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	4	1	4	2	8	0.4	0.8	$443.58
f. Review compliance status f	2	1	2	3	6	0.3	0.6	$332.69
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	3	24	1.2	2.4	$1,330.74
TOTAL LABOR BURDEN AND COST (rounded)h					60			$2,800
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $66.63 Managerial rate, $49.44 Technical rate, and $26.76 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2019 General Schedule”, which excludes locality rates of pay.
c We have assumed that it will take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in year one.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 9: TBL6-EPAY2

Table 6: Average Annual EPA Burden and Cost Year Two – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Amendments)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2019 ICR Wages
1. Read instructions	N/A									Technical	$49.44
2. Enter and update information into agency recordkeeping system c	4	1	4	3	12	0.6	1.2	$665.37		Managerial	$66.63
3. Notification review d										Clerical	$26.76
a. Review initial notification for existing sources	N/A
b. Notification for new major sources e	N/A
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	N/A
f. Review compliance status f	2	1	2	3	6	0.3	0.6	$332.69
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	3	24	1.2	2.4	$1,330.74
TOTAL LABOR BURDEN AND COST (rounded)h					50			$2,400
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $66.63 Managerial rate, $49.44 Technical rate, and $26.76 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2019 General Schedule”, which excludes locality rates of pay.
c We have assumed that it will take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in year one.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 10: TBL7-EPAY3

Table 7: Average Annual EPA Burden and Cost Year Three – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Amendments)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per occurrence	No of occurrences per year	EPA hours per year	Facilities per year a	Technical hours per year	Managerial hours per year	Clerical hours per year	Total Cost per Year a
			(C=AxB)		(E=CxD)	(E x 0.05)	(E x 0.1)			2019 ICR Wages
1. Read instructions	N/A									Technical	$49.44
2. Enter and update information into agency recordkeeping system c	4	1	4	3	12	0.6	1.2	$665.37		Managerial	$66.63
3. Notification review d										Clerical	$26.76
a. Review initial notification for existing sources	N/A
b. Notification for new major sources e	N/A
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	N/A
f. Review compliance status f	2	1	2	3	6	0.3	0.6	$332.69
g. Area sources not subject to standard	N/A
h. Review waiver application	N/A
4. Reporting requirements
a. Semiannual compliance reports for all sources g	4	2	8	3	24	1.2	2.4	$1,330.74
TOTAL LABOR BURDEN AND COST (rounded)h					50			$2,400
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 3 existing sources. There will be no additional sources over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $66.63 Managerial rate, $49.44 Technical rate, and $26.76 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2019 General Schedule”, which excludes locality rates of pay.
c We have assumed that it will take 4 hours to enter and update information into agency recordkeeping system.
d We have assumed that all existing sources will be in compliance in year one.
e We have assumed that there will be not new sources over the three-year period of this ICR.
f We have assumed that it will take 2 hours to review the compliance status notification.
g We have assumed that it will take four hours two times per year to review the semiannual compliance report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 11: TBL8-EPA SUMMARY

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Flexible Polyurethane Foam Fabrication NESHAP (40 CFR Part 63, Subpart MMMMM) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	50	3	5	58	$2,800	$0	$2,800
2	42	2	4	48	$2,400	$0	$2,400
3	42	2	4	48	$2,400	$0	$2,400
Total	134	7	13	154	$7,600	$0	$7,600
Average	45	2	4	51	$2,500	$0	$2,500