Burden Calculation 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	84
Number of Respondents	4
Total Estimated Burden Hours	811
Total Estimated Costs	$132,000
Annualized Capital O&M	$34,900
Total Annual Responses	10
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS)(Renewal)
Burden Items	(A) Person hours per occurrence	(B) Number of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Number of Respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Labor Costs per Year b
1. Applications	N/A										Labor Rates
2. Surveys and Studies	N/A										Management	$157.61
3. Reporting Requirements											Technical	$123.94
A. Familiarize with regulatory requirements c	0.87	1	0.87	4	3.48	0.17	0.35	$480.49			Clerical	$62.52
B. Required Activities
Initial performance test d	243.48	1	243.48	0	0	0	0	$0
Repeat of performance test e	243.48	0.2	48.70	0	0	0	0	$0
Method 24 Testing	78.26	12	939.12	0	0	0	0	$0
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report
Notification of construction/reconstruction/modification f	1.74	0	0	0	0	0	0	$0
Notification of phys/operational change	6.96	1	6.96	0	0	0	0	$0
Notification of actual startup	1.74	1	1.74	0	0	0	0	$0
Notification of initial performance test	1.74	1	1.74	0	0	0	0	$0
Notification of CMS	1.74	1	1.74	0	0	0	0	$0
Report of performance test	See 3B
Excess Emission Report g	13.91	4	55.64	0.8	44.51	2.23	4.45	$6,145.88
Report of No Excess Emissions h	6.96	2	13.92	3.2	44.54	2.23	4.45	$6,150.30
Report when Exceed Size Cutoff	1.74	1	1.74	0	0	0	0	$0
Subtotal for Reporting Requirements					106			$12,777
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B.  Plan Activities	See 4C
C. Implement Activities	See 3B
D.  Develop Record System	N/A
E.  Time to Enter Information
1) Records of startups, shutdowns, malfunctions, etc. i	1.3	50	65	4	260	13	26	$35,898.85
2) Records of control device operating parameters j	0.22	350	77	4	308	15.4	30.8	$42,526.33
3) Records of Projected/Actual Solvent Use k	6.96	2	13.92	0.8	11.14	0.56	1.11	$1,537.58
4) Records for Monthly Liquid Material Balance l	1.74	12	20.88	0.8	16.70	0.84	1.67	$2,306.36
5) Monthly Determination of Avg VOC Content m	1.74	12	20.88	0.8	16.70	0.84	1.67	$2,306.36
6) Records of periods when no emission control device is used	See 4E(2)
F.   Train Personnel	N/A
G.  Audits	N/A
Subtotal for Recordkeeping Requirements					704			$84,575
TOTAL LABOR BURDEN AND COST (rounded) n					811			$97,400	84	hrs/resp.
TOTAL CAPITAL AND O&M COST (rounded) n								$34,900
GRAND TOTAL (rounded) n								$132,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 4 existing sources, and no additional sources will become subject to the standard.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). 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 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 have assumed all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take each respondent 243.48 hours to perform initial performance test.
e We have assumed 20 percent of respondents will have to repeat performance tests.
f We have assumed that there will be no modification/reconstruction line over 5 years.
g We have assumed that 20 percent of sources will report excess emissions.
h We have assumed that 80 percent of sources will report no excess emissions.
i We have assumed that each respondent will take 1.3 hours 50 times per year to record SSM reports.
j We have assumed that each respondent will take 0.22 hours 350 times per year to record the control device operating parameters information.
k We have assumed that 20 percent of respondents will enter information on records of projected/actual solvent use two times per year.
l We have assumed that 20 percent of respondents will record liquid material balance 12 times per year.
m We have assumed that 20 percent of respondents will perform monthly VOC determination.
n Totals have been rounded to 3 significant figures. Figures may not add exatly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS) (Renewal)
Activity	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Plant per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Total Costs per Year ($) b
										Labor Rates
Initial Performance Tests c	20.87	1	20.87	0	0	0	0	$0		Management	$70.56
Repeat Performance Test d	20.87	0.2	4.17	0	0	0	0	$0		Technical	$52.37
Report Review										Clerical	$28.34
Notification of construction	1.74	1	1.74	0	0	0	0	$0
Notification of actual startup	0.43	1	0.43	0	0	0	0	$0
Notification of initial test e	0.43	1.2	0.52	0	0	0	0	$0
Review test results f	6.96	1.2	8.35	0	0	0	0	$0
Excess emission report g	6.96	4	27.84	0.8	22.27	1.11	2.23	$1,308.08
Report of no excess emissions h	1.74	2	3.48	3.2	11.14	0.56	1.11	$654.04
TOTAL LABOR BURDEN AND COST (rounded) i					38			$1,960
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 4 existing sources, and no additional sources will become subject to the standard.
b This cost is 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 Office of Personnel Management (OPM), 2022 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.
c We have assumed that it will take 20.87 hours to review each initial performance test.
d We have assumed that 20 percent of respondents will have to repeat performace tests.
e We have assumed that it will take 0.43 hours 1.2 times per year to review each initial test notification.
f We have assumed that it will take 6.96 hours 1.2 times per year to review test results.
g We have assumed that 20 percent of sources will report excess emissions.
h We have assumed that 80 percent of sources will report no excess emissions
i Totals have been rounded to 3 significant figures. Figures may not add exatly due to rounding.

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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 b	Total O&M, (E X F)
CEM a	$29,000	0	$0	$1,200	2.4	$2,880
Thermocouple	$2,300	0	$0	$8,000	4	$32,000
Totals (rounded) c			$0			$34,900		$34,900
a We assume there are 4 existing sources with no additional respondents per year.
b We assumed 60% of respondents installed CEMs requiring O&M costs.
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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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
Notification of construction/ reconstruction	0	0	0	0
Notification of physical /operational change	0	0	0	0
Notification of actual startup	0	0	0	0
Notification of initial performance test	0	0	0	0
Notification of CMS	0	0	0	0
Quarterly report of excess emission	0.8	4	0	3.2
Semiannual report of no excess emission	3.2	2	0	6.4
			Total	10

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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 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	4	0	0	4
2	0	4	0	0	4
3	0	4	0	0	4
Average	0	4	0	0	4
a New respondents include sources with constructed, reconstructed, and modified affected facilities.