1712t12

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Overview

Summary
Table 1a
Table 1b
Table 1c
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	256
Number of Respondents	56
Total Estimated Burden Hours	28,700
Total Estimated Costs	$3,390,000
Annualized Capital O&M	$0
Form Number	Not Applicable

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Sheet 2: Table 1a

Table 1a: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal) (Private Sector)
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) Cost, $ b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$163.17
3. Reporting Requirements										Technical	$130.28
a. Familiarization with Regulatory Requirements	1	1	1	50	50	2.5	5	$7,250.48		Clerical	$65.71
b. Required Activities	See 3e
c. Create Information	See 3e
d. Gather Existing Information	See 3e
e. Write Report
Notification of Construction/Reconstructionc	2	1	2	0	0	0	0	$0
Notification of Demonstration of CMSc	N/A
Report of Performance Testc	N/A
Initial Notification and Implementationc	14	1	14	0	0	0	0	$0
Semiannual Notification of Compliance Status	8	2	16	50	800	40	80	$116,007.60
Subtotal for Reporting Requirements					978			$123,258.08
4. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 3e
b. Plan Activities	N/A
c. Implement Activities	8	50	400	50	20000	1000	2000	$2,900,190.00
d. Develop Record Systemc	8	1	8	0	0	0	0	$0
e. Train Personnel	28	1	28	50	1400	70	140	$203,013.30
g. Audits	N/A
Subtotal for Recordkeeping Requirements					24,610			$3,103,203
Total Labor Burden and Costs (rounded) d					25,600			$3,230,000
Total Capital and O&M Cost (rounded) d								$0
GRAND TOTAL (rounded) d								$3,230,000
Assumptions:
a Number of affected facilities per year is 56. We assume 90 percent of sources are in the private sector, or approximately 50 respondents. We have assumed that there will be no new growth over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 this is a one-time-only cost.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1b

Table 1b: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal) (Public Sector)
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) Cost, $ b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$73.46
3. Reporting Requirements										Technical	$54.51
a. Familiarization with Regulatory Requirements	1	1	1	6	6	0.3	0.6	$366.80		Clerical	$29.50
b. Required Activities	See 3e
c. Create Information	See 3e
d. Gather Existing Information	See 3e
e. Write Report
Notification of Construction/Reconstructionc	2	1	2	0	0	0	0	$0
Notification of Demonstration of CMSc	N/A
Report of Performance Testc	N/A
Initial Notification and Implementationc	14	1	14	0	0	0	0	$0
Semiannual Notification of Compliance Status	8	2	16	6	96	4.8	10	$5,868.77
Subtotal for Reporting Requirements					117			$6,235.57
4. Recordkeeping Requirements
a. Familiarization with Regulatory Requirements	See 3e
b. Plan Activities	N/A
c. Implement Activities	8	50	400	6	2400	120	240	$146,719.20
d. Develop Record Systemc	8	1	8	0	0	0	0	$0
e. Train Personnel	28	1	28	6	168	8.4	16.8	$10,270.34
g. Audits	N/A
Subtotal for Recordkeeping Requirements					2,953			$156,990
Total Labor Burden and Costs (rounded) d					3,070			$163,000
Total Capital and O&M Cost (rounded) d								$0
GRAND TOTAL (rounded) d								$163,000
Assumptions:
a Number of affected facilities per year is 56. We assume 10 percent of sources are in the public sector, or approximately 6 respondents. We have assumed that there will be no new growth over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 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), 2023 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 this is a one-time-only cost.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 1c

Table 1c: Annual Respondent Burden and Cost Breakdown by Affected Sector – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal)
Affected Sector	Number of Responses	Labor Hours			Labor Cost	Capital and O&M Cost
		Reporting	Recordkeeping	Total
Private	50	978	24,610	25,600	$3,230,000	$0
Public (Federal)	6	117	2,953	3,070	$163,000	$0
Total a	56	1,090	27,600	28,700	$3,390,000	$0		256	hr/response
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal)
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) Cost, $ b
Initial Performance Testsc	N/A									Labor Rates
Repeat Performance Test	N/A									Management	$73.46
Report Review										Technical	$54.51
Notification of Constructionc	2	1	2	0	0	0	0	$0.00		Clerical	$29.50
Review of Initial Notification and Implementation Planc	2	1	2	0	0	0	0	$0.00
Review of Semiannual Notification of Compliance Status	2	2	4	56	224	11.2	22.4	$13,693.79
TOTAL (rounded) d					258			$13,700
Assumptions:
a Number of affected facilities per year is 56.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 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), 2023 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 this is a one-time-only cost.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: Capital O&M

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

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Sheet 7: 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
Semiannual Report/Notification	56	2	0	112
			Total	112

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Sheet 8: 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	56	0	0	56
2	0	56	0	0	56
3	0	56	0	0	56
Average	0	56	0	0	56
a New respondents include sources with constructed and reconstructed affected facilities.