1966.10 Burden Calculation Table

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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	55
Number of Respondents	108
Total Estimated Burden Hours	11,800
Total Estimated Costs	$1,620,000
Annualized Capital O&M	$0
Form Number	5900-717

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing (40 CFR Part 63, Subpart VVVV)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Applications	N/A
2. Surveys and studies	N/A
3. Familiarize with regulatory requirements c	25	1	25	108	2700	135	270	$425,267.55
4. Required activities for sources with add-on control devices
a. Initial performance test and report h	410	1	410	0	0	0	0	$0
b. Establish operating parameters h	See 4A										Labor Rates
c. Re-evaluating startup, shutdown, and amlfucntion requirements d	4	1	4	0	0	0	0	$0			Technical	$141.75
5. Required activities for sources using pollution prevention measures											Management	$172.41
a. Develop recordkeeping system h	See 10a										Clerical	$71.36
1) Fiberglass manufacturing operations	22	1	22	0	0	0	0	$0
2) Adhesive operations	1	1	1	0	0	0	0	$0
3) Aluminum coating operations	6	1	6	0	0	0	0	$0
b. Enter information into recordkeeping system	See 10c
c. Work practice requirements e	4	12	48	108	5184	259.2	518.4	$816,513.70
6. Create information	See 5c
7. Gather information	See 5c
8. Notification requirements
a. Initial notification that existing sources are subject to the standard h	24	1	24	0	0	0	0	$0
b. Notification for new major sources h
1) Intent to construct and application for approval of construction	80	1	80	0	0	0	0	$0
2) Start of construction	2	1	2	0	0	0	0	$0
3) Anticipated startup date	2	1	2	0	0	0	0	$0
4) Actual startup date	2	1	2	0	0	0	0	$0
c. Request for compliance extension h	N/A
d. Notification of special compliance requirements h	N/A
e. Notification of performance tests e	2	1	2	0	0	0	0	$0
f. Notification of compliance status f	4	1	4	0	0	0	0	$0
9. Reporting requirements
a. Semiannual compliance reports for all sources g	8	2	16	108	1728	86.4	172.8	$272,171.23
b. Additional reports for sources with add-on control devices e	N/A
1) Quarterly compliance report for sources with exceedances	16	4	64	0	0	0	0	$0
2) Request to return to semiannual compliance reporting	8	1	8	0	0	0	0	$0
3) Control device performance test report	See 4A
4) Operating range for monitored parameters	See 4B
5) Startup, shutdown, malfunction	8	1	8	0	0	0	0	$0
Subtotal for Reporting Requirements					11,054			$1,513,952
10. Recordkeeping requirements
a. Familiarize with CEDRI and CDX registration	0	1	0	108	0	0	0	$0
b. Plan and develop record system	See 10a
c. Record information	6	1	6	108	648	32.4	64.8	$102,064.21
d. Records for area sources not subject to the standard	N/A
11. Time to train personnel	See 10a
12. Time for audits	N/A
Subtotal for Recordkeeping Requirements					745			$102,064		Responses	Hr/Response
TOTAL LABOR BURDEN AND COST (rounded) h					11,800			$1,620,000		216	55
TOTAL CAPITAL AND O&M COSTS (rounded) h								$0
GRAND TOTAL (rounded) h								$1,620,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 108 existing sources. There will be no additional sources over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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 that it will take the same length of time (25 hours) for both fiberglass and aluminum boat manufacturers to refamiliarize with the regulatory requirements each year.
d We have assumed that facilities have already evalualuated the effect of the rule removing the SSM exemption, and adjusted recordkeeping and reporting to accommodate these changes.
e We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures.
f We have assumed that no new facilities will become operational in the next three years.
g We have assumed that each respondent will take 8 hours two times per year to complete 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 3: Table 2

Table 2: Average Annual EPA Burden and Cost – National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing (40 CFR Part 63, Subpart VVVV)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant-year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Familiarize with regulatory requirement	25	1	25	0	0	0	0	$0		Labor Rates
2. Enter and update information into agency recordkeeping system	4	1	4	108	432	21.6	43.2	$27,650		Managerial	$76.92
3. Notification review										Technical	$57.07
a. Review initial notification for existing sources	2	1	2	0	0	0	0	$0		Clerical	$30.88
b. Notifications for new major sources
1. Review intent to construct and application to construct	12	1	12	0	0	0	0	$0
2. Start of construction	2	1	2	0	0	0	0	$0
3. Anticipated startup date	2	1	2	0	0	0	0	$0
4. Actual startup date	2	1	2	0	0	0	0	$0
c. Review request for compliance extension	N/A
d. Review special compliance requirements	N/A
e. Review initial performance test and test plan	20	1	20	0	0	0	0	$0
f. Review compliance status	2	1	2	0	0	0	0	$0
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	4	2	8	108	864	43.2	86.4	$55,299
b. Reports for sources with add-on control devices
1. Quarterly compliance report for source with exceedances	4	4	16	0	0	0	0	$0
2. Request to return to semiannual compliance reporting	4	2	8	0	0	0	0	$0
3. Review control device performance test report and operating range	20	1	20	0	0	0	0	$0
4. Review startup, shutdown, malfunction reports	4	1	4	0	0	0	0	$0
Total (rounded) m					1,490			$82,900
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 108 existing sources. There will be no additional sources over the three-year period of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $76.92 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 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), 2024 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 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs

The only costs to the regulated industry resulting from information collection activities required by the subject standards are labor costs. There are no capital/startup or operation and maintenance costs.

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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
Initial notification that existing sources are subject to the standard	0	1	0	0
Notification of intent to construct and application for approval of construction	0	1	0	0
Notification of start of construction	0	1	0	0
Notification of anticipated startup date	0	1	0	0
Notification of actual startup date	0	1	0	0
Notification of compliance status	0	1	0	0
Semiannual compliance reports of all sources	108	2	0	216
Quarterly compliance report	0	4	0	0
		Total (rounded)		216

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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 1	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	108	0	0	108
2	0	108	0	0	108
3	0	108	0	0	108
Average	0	108	0	0	108
1 New respondents include sources with constructed, reconstructed and modified affected facilities.