Burden Calculation Tables

---

Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

---

Sheet 1: Summary

ICR Summary Information
Hours Per Response	16
Number of Respondents	43
Total Estimated Burden Hours	1,360
Total Estimated Costs	$809,000
Annualized Capital O&M	$623,000
Form Number	Not Applicable

---

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)
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. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with rule requirement c	1	1	1	43	42.7	2.1	4.3	$6,719.23
B. Required Activities
New Sources											Labor Rates
Initial performance test d	280	1	280	0.33	92.4	4.62	9.24	$14,553.60			Technical	$141.75
Repeat performance test d, e	280	0.2	56	0.33	18.5	0.92	1.85	$2,910.72			Management	$172.41
C. Create Information	See 3B										Clerical	$71.36
D. Gather Existing Information	See 3B
E. Write Report
New Sources
Notification of construction/reconstruction f	2	1	2	0.33	0.7	0.03	0.07	$103.95
Notification of initial performance test e, g	2	1.2	2.4	0.33	0.8	0.04	0.08	$124.75
Report of initial performance test	See 3B
Existing Sources
Semiannual report h	4	2	8	43	341.3	17.06	34.13	$53,753.82
Subtotal for Reporting Requirements					571			$78,166
4. Recordkeeping Requirements
A. Familiarize with rule requirement	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Time to Enter Information
Records of startup, shutdown, and malfunctions i	1.5	2	3	43	128	6.399	12.798	$20,157.68
Records of VOC, temperature, and CMS maintenance j	0.25	52	13	43	554.6	27.73	55.46	$87,349.95
F. Audits	N/A
Subtotal for Recordkeeping Requirements					785			$107,508		Responses	Hr/Response
TOTAL LABOR BURDEN AND COST (rounded) k					1,360			$186,000		86	16
TOTAL CAPITAL AND O&M COSTS (rounded) k								$623,000
GRAND TOTAL (rounded) k								$809,000
Assumptions:
a We estimate that there are an average of 43 existing respondents, and it is estimated that 1 additional source will become subject over the next three years 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 estimate it will take one hour to read and familiarize with the rule. This burden item applies to all sources.
d We estimate each performance test will take 280 hours to complete.
e We estimate 20 percent of respondents will need to repeat the initial performance test.
f We estimate it will take 2 hours to prepare the notification of construction/reconstruction.
g We estimate it will take 2 hours to prepare the notification of initial performance test.
h We estimate it will take 4 hours to compile data for semiannual reports.
i We estimate it will take 1.5 hours to record startups, shutdowns, and malfunctions.
j We estimate it will take 0.25 hours to record VOCs, temperatures, and CMS maintenance.
k 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 Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)
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
Required Activities										Labor Rates
New Sources										Managerial	$76.91
Initial performance tests c	24	1	24	0.33	7.92	0.40	0.79	$507		Technical	$57.07
Repeat performance tests c, d	24	0.2	4.8	0.33	1.58	0.08	0.16	$101		Clerical	$30.88
Report Review
New Sources
Notification of construction/reconstruction e	2	1	2	0.33	0.66	0.03	0.07	$42
Notification of initial startup f	0.5	1	0.5	0.33	0.17	0.01	0.02	$11
Notification of actual startup g	0.5	1	0.5	0.33	0.17	0.01	0.02	$11
Notification of initial test d, h	0.5	1.2	0.6	0.33	0.20	0.01	0.02	$13
Review test results d, i	0.5	1.2	0.6	0.33	0.20	0.01	0.02	$13
Existing Sources
Semiannual reports j	2	2	4	43	170.6	8.5	17.1	$10,922
TOTAL (rounded) k					209			$11,620
Assumptions:
a We estimate that an average of 43 existing respondents, and it is estimated that 1 additional source will become subject over the next three years of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (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 We estimate it will take 24 hours to participate with each performance test.
d We estimate 20 percent of respondents will need to repeat the initial performance test.
e We estimate it will take 2 hours to review construction/reconstruction notifications.
f We estimate it will take 0.5 hours to review initial startup notifications.
g We estimate it will take 0.5 hours to review actual startup notifications.
h We estimate it will take 0.5 hours to review initial test notifications.
i We estimate it will take 0.5 hours to review test results.
j We estimate it will take 2 hours to review each semiannual report twice annually.
k 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	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 or feed rate monitor a	$31,873	0.33	$10,518	$14,343	43	$611,876				CEPCI Index 2007:	499.6
Totals (rounded) b			$10,500			$612,000		$623,000		CEPCI Index 2024:	796.2
a Capital/Startup and O&M costs have been adjusted from 2007 $ to 2024 $ using the CEPCI CE Index.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 5: 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	0.33	42.0	0	0	42.3
2	0.33	42.3	0	0	42.7
3	0.33	42.7	0	0	43.0
Average	0.33	42.3	0	0	42.7
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

---

Sheet 6: 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	0.33	1	0	0.33
Notification of initial performance test	0.33	1.2	0	0.40
Semiannual Reports	43	2	0	85
		Total (rounded)		86