Burden Calculation Tables

0658t14.xlsx

NSPS for Pressure Sensitive Tape and Label Surface Coating (40 CFR part 60, subpart RR) (Renewal)

Burden Calculation Tables

OMB: 2060-0004

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents


Sheet 1: Summary

ICR Summary Information
Hours per Response 26
Number of Respondents 48
Total Estimated Burden Hours 4,530
Total Estimated Costs $636,000
Annualized Capital O&M $93,400
Total Annual Responses 177
Form Number Not Applicable

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal)



























$123.94 $157.61 $62.52



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) Total costs per Year b


1. Applications N/A









2. Survey and Studies N/A









3. Reporting Requirements










A. Familiarization with the regulatory requirements c 0.87 1 0.87 48 41.76 2.09 4.18 $5,765.91


B. Required activities










Initial performance test 52.17 1 52.17 1 52.17 2.61 5.22 $7,203.24


Repeat performance test d 52.17 1 52.17 0.2 10.43 0.52 1.04 $1,440.65


C. Create information See 3B



D. Gather existing information See 3E



E. Write report










Notification of construction/reconstruction 1.74 1 1.74 1 1.74 0.09 0.17 $240.25


Notification of actual startup 1.74 1 1.74 1 1.74 0.09 0.17 $240.25


Notification of initial performance test 1.74 1 1.74 1 1.74 0.09 0.17 $240.25


Report of performance test See 3B



Excess emission reports










VOC emission reports e 4.35 2 8.7 48 417.6 20.88 41.76 $57,659.08


Temperature reports f 3.48 2 6.96 38 267.264 13.36 26.73 $36,901.81


Subtotal for Reporting Requirements



914 $109,691.42


4. Recordkeeping Requirements










A. Familiarization with the regulatory requirements See 3A



B.  Plan activities See 4C



C. Implement activities See 3B



Monthly performance test g 0.87 12 10.44 48 501.12 25.056 50.112 $69,190.89


D. Develop record system N/A









D.  Develop record system N/A









E.  Time to enter information










Records of operating parameters h 0.22 250 55 48 2,640 132 264 $364,511.40


F.   Train personnel N/A









G.  Audits N/A









Subtotal for Recordkeeping Requirements



3,612 $433,702.29


TOTAL LABOR BURDEN AND COST (rounded) i 4,530 $543,000
4,530
TOTAL CAPITAL AND O&M COSTS (rounded)i






$93,400


GRAND TOTAL (rounded): i






$636,000
26 hr/resp*
























Assumptions:










a We have assumed that the average number of respondents potentially subject to this rule is 48. There will be one additional new source per year over the three-year period of this ICR.


b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, 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 We have assumed that it will take 0.87 hours for a new respondent to read instructions.










d We have assumed that 20 percent of respondents will have to repeat performance tests because of failure.










e We have assumed that each source submits one excess emission report every year, in addition to the required semiannual report.










f We have assumed that 80 percent of sources will use incineration to control emissions.










g We assume that each respondent will take 0.87 hours once per month to record performance test.










h We assume that each respondent will take 0.22 hours 250 time per year to record operating parameters.










i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.











Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal)





















52.37 70.56 28.34
Activity (A) EPA person-hours per occurrence (B) No. of occurrences per plant per year (C) EPA person-hours per plant per year (C=AxB) (D) Plants 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) Total Cost, $ b
New facility







Initial performance test 20.87 1 20.87 1 20.87 1.04 2.09 $1,225.74
Repeat performance test/observed 20.87 1 20.87 0.2 4.17 0.21 0.42 $245.15
Review reports c







Notification of construction 1.74 1 1.74 1 1.74 0.09 0.17 $102.19
Notification of initial startup 0.43 1 0.43 1 0.43 0.02 0.04 $25.25
Notification of actual startup 0.43 1 0.43 1 0.43 0.02 0.04 $25.25
Notification of initial performance test 0.43 1 0.43 1 0.43 0.02 0.04 $25.25
Review test results 6.96 1 6.96 1 6.96 0.35 0.70 $408.77
Existing plant







VOC emission reports d 1.74 2 3.48 48 167.04 8.35 16.70 $9,810.59
Temperature reports e, f 1.74 2 3.48 38 133.63 6.68 13.36 $7,848.47
TOTAL ANNUAL LABOR BURDEN AND COSTS (rounded) g



386 $19,700









Assumptions:







a We have assumed that the average number of respondents potentially subject to this rule is 48. There will be one additional new source per year over the three-year period of this ICR.
b Labor rates for Federal agency personnel were applied to State/Local agencies, and are based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 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 OPM, 2021 General Schedule, which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit packages available to government employees.
c We assume that each of the new facilities will submit initial notifications.







d We assume that each source submits one excess emission report every year, in addition to the required semiannual report.







e We assume that 80 percent of sources use incineration.







f We assume that temperature reports are conducted two times per year.







g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








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 a 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)


Temperature $7,000 1 $7,000 $1,800 48 $86,400
Total Capital/O&M Costs
Totals (rounded) a

$7,000

$86,400
$93,400









a Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.


Sheet 5: Responses

Total Annual Responses
(A) (B) (C) (D) (E)
Information Collection Activity Number of Respondents a 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 1 1 N/A 1
Notification of actual startup 1 1 N/A 1
Notification of initial performance test 1 1 N/A 1
Report of performance test and repeat performance test 1.2 1 N/A 1.2
VOC Emission Reports 48 2 N/A 96
Temperature Reports 38 2 N/A 77



Total 177






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 1 46 0 N/A 47
2 1 47 0 N/A 48
3 1 48 0 N/A 49
Average 1 47 0 N/A 48
a New respondents include sources with constructed and reconstructed affected facilities.




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