2268t01

2268t01.xls

NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR 63, subpart HHHHHH) (Proposed Rule)

2268t01

OMB: 2060-0607

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Overview

A1
A2
A3
A4
B1
B2
B3
B4
C1
C2
C3
C4
D1
D2
D3
D4
Table 4
Table 5


Sheet 1: A1

Table A1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Commercial Miscellaneous Surface Coating Operations at Area Sources - Year 1










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable

#VALUE!








2. Surveys and Studies

Not applicable

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!



3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 35,731 178,655 8,933 17,866 $8,928,641 $0 c


B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 35,731 35,731.00 1,786.55 3,573.10 $1,785,728 $35,731 c, d



2) Notification of Compliance Status 2 $1 1 2 3,236 6,472.00 323.60 647.20 $323,451 $3,236 c, e



3) Annual compliance report
2 $3 1 2 0 0.00 0.00 0.00 $0 $0 f

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!




B. Plan Activities
not applicable

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!




C. Implement Activities
not applicable

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!




D. Develop Record System
8 $0 1 8 35,731 285,848 14,292 28,585 $14,285,825 $0 c, g


E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 35,731 Not Applicable Not Applicable 21,439

h



2) Records of filter efficiency
0.25 $0 1 0.25 32 8.09 0.40 0.81 $404 $0 i



3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0 j



4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 162 161.80 8.09 16.18 $8,086 $0 k


F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







#VALUE! #VALUE! #VALUE! #VALUE! $38,967



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

#VALUE! #VALUE! $38,967 #VALUE!









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 35,731 miscellaneous surface coating or commercially-owned motor vehicle and mobile equipment refinishing facilities will exist in any given year of this ICR. It is estimated that 1,618 new affected sources per year will be constructed. Existing sources will shutdown after a period of time and be replaced with new sources, but the total number of affected automotive refinishing shops expected to become subject to this rule will not change over this ICR period.





















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.



























c One-time only costs.































d Assumes that 1,618 new affected sources were constructed or reconstructed between proposal and promulgation, and another 1,618 new sources were constructed within 1 year after the promulgation of this rule. These sources are both considered new sources, and are required to submit an initial notification within 120 days of start-up. The existing affected sources must also submit their initial notification within one year from promulgation, which makes for a total of 35,781 miscellaneous surface coating or motor vehicle or mobile equipment refinishing sources submitting an initial notification within one year of promulgation of this rule.
























e All new sources (3,236) are required to submit a notification of compliance status within 120 days of start-up or from the promulgation of this rule, whichever is later. Existing sources have three years and 60 days to submit this notification and are thus excluded from the initial 3-year ICR period.





















f The new affected sources will have to submit their first annual compliance report by March 1 in the calendar year following their initial year of compliance. Therefore no reports will be submitted in the first year of this ICR. Existing sources will not have to submit their first annual compliance report until March 1 of the 4th year after promulgation of this rule and are thus excluded from the initial 3-year ICR period.





















g A facility will develop a simple system to track the date of each employee's initial certification and most recent refresher training. Painter certification records must be completed by both new and existing sources within the first year.































h Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years and it is assumed that each year, 20 percent of the painters will need to have their records updated. However, in the first year, all painters need their records entered into the system.





















i Assumes 1% of affected sources will opt to test the filter effieciency of filter that are not polyester fiber or fiberglass. If a source opts to test the efficiency of a filter it is assumed that the filter manufacturer would perform the test and the burden on the source would only be the time to record and file the efficiency of this filter based on the results of the manufacturer's test.





















j Only sources without an HVLP gun are required to maintain records on the testing of non-HVLP type spray guns. It is assumed that no source will opt for a testing of their spray gun, and all sources with non-HVLP type spray guns will purchase new guns in response to the rule before the effective date and there are no recordkeeping costs associated with this requirement.





















k The number of sources expected to record a deviation for the rule requirements is based on the assumption of a 95 percent compliance rate. Approximately 5 percent of the estimated 3,236 new sources that are required to be in compliance with the rule in year 1 are expected to have some type of violation of the proposed work practices in any given year.


Sheet 2: A2

Table A2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Commercial Miscellaneous Surface Coating Operations at Area Sources - Year 2










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable

#VALUE!








2. Surveys and Studies

Not applicable

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!



3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 1,618 8,090 405 809 $404,314 $0 c


B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 1,618 1,618.00 80.90 161.80 $80,863 $1,618 c, d



2) Notification of Compliance Status 2 $1 1 2 1,618 3,236.00 161.80 323.60 $161,726 $1,618 c, e



3) Annual compliance report
2 $3 1 2 3,236 6,472.00 323.60 647.20 $323,451 $9,708 f

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!




B. Plan Activities
not applicable

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!




C. Implement Activities
not applicable

#VALUE!
#VALUE! #VALUE! #VALUE! #VALUE!




D. Develop Record System
8 $0 1 8 1,618 12,944 647 1,294 $646,902 $0 c, g


E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 7,156 Not Applicable Not Applicable 4,294

h



2) Records of filter efficiency
0.25 $0 1 0.25 49 12.14 0.61 1.21 $606 $0 i



3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0 j



4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 243 242.70 12.14 24.27 $12,129 $0 k


F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







#VALUE! #VALUE! #VALUE! #VALUE! $12,944



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

#VALUE! #VALUE! $12,944 #VALUE!









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 35,731 facilities will exist in any given year of this ICR. It is estimated that 1,678 new affected sources per year will be constructed. Existing sources will shutdown after a period of time and be replaced with new sources, but the total number of affected automotive refinishing shops expected to become subject to this rule will not change over this ICR period.





















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.
























c One-time only costs.































d Year 2 represents the third calendar year after the promulgation of this rule. It is assumed that 1,618 new affected sources were constructed or reconstructed during this year and are subject to the initial notification requirement during this year.





e All new sources in year 2 (1,618) are required to submit a notification of compliance status within 120 days of start-up or from the promulgation of this rule, whichever is later.


















f The new affected sources will have to submit their first annual compliance report by March 1 in the calendar year following their initial year of compliance. Therefore the 3,236 new sources constructed or reconstructed by year 1 will submit their first report in year 2.





















g A new facility will develop a simple system to track the date of each employee's initial certification and most recent refresher training.































h Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years. It is assumed that 20 percent of the certifications from 35,781 existing and new facilities will have to be updated in the record system each year.





















i Assumes 1% of affected sources will opt to test the filter effieciency of filter that are not polyester fiber or fiberglass. If a source opts to test the efficiency of a filter it is assumed that the filter manufacturer would perform the test and the burden on the source would only be the time to record and file the efficiency of this filter based on the results of the manufacturer's test.





















j Only sources without an HVLP gun are required to maintain records on the testing of non-HVLP type spray guns. It is assumed that no source will opt for a testing of their spray gun, and all sources with non-HVLP type spray guns will purchase new guns in response to the rule before the effective date and there are no recordkeeping costs associated with this requirement.





















k The number of sources expected to record a deviation for the rule requirements is based on the assumption of a 95 percent compliance rate. Approximately 5 percent of the estimated 4,854 new sources that are required to be in compliance with the rule in year 1 are expected to have some type of violation of the proposed work practices in any given year.


Sheet 3: A3

Table A3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Commercial Miscellaneous Surface Coating Operations at Area Sources - Year 3










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 1,618 8,090 405 809 $404,314 $0 c


B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 1,618 1,618.00 80.90 161.80 $80,863 $1,618 c, d



2) Notification of Compliance Status 2 $1 1 2 1,618 3,236.00 161.80 323.60 $161,726 $1,618 c, e



3) Annual compliance report
2 $3 1 2 4,854 9,708.00 485.40 970.80 $485,177 $14,562 f

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
not applicable












C. Implement Activities
not applicable












D. Develop Record System
8 $0 1 8 1,618 12,944 647 1,294 $646,902 $0 c, g


E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 7,156 Not Applicable Not Applicable 4,294

h



2) Records of filter efficiency
0.25 $0 1 0.25 65 16.18 0.81 1.62 $809 $0 i



3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0 j



4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 324 323.60 16.18 32.36 $16,173 $0 k


F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







35,936 1,797 7,887 $1,795,962 $17,798



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

45,620 $1,795,962 $17,798 $1,813,760









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 35,731 facilities will exist in any given year of this ICR. It is estimated that 1,618 new affected sources per year will be constructed. Existing sources will shutdown after a period of time and be replaced with new sources, but the total number of affected automotive refinishing shops expected to become subject to this rule will not change over this ICR period.





















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.
























c One-time only costs.































d Year 3 represents the third calendar year after the promulgation of this rule. It is assumed that 1,618 new affected sources were constructed or reconstructed during this year and are subject to the initial notification requirement during this year.


















e All new sources in year 3 (1,618) are required to submit a notification of compliance status within 120 days of start-up or from the promulgation of this rule, whatever is later.



















f The new affected sources will have to submit their first annual compliance report by March 1 in the calendar year following their initial year of compliance. Therefore the 3,236 new sources constructed or reconstructed by year 1 will and the 1,618 sources constructed in year 2 will submit their reports in year 3.





















g A new facility will develop a simple system to track the date of each employee's initial certification and most recent refresher training.































h Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years and it is assumed that the burden will be on a five year recurring basis for each facility.





















i Assumes 1% of affected sources will opt to test the filter effieciency of filter that are not polyester fiber or fiberglass. If a source opts to test the efficiency of a filter it is assumed that the filter manufacturer would perform the test and the burden on the source would only be the time to record and file the efficiency of this filter based on the results of the manufacturer's test.





















j Only sources without an HVLP gun are required to maintain records on the testing of non-HVLP type spray guns. It is assumed that no source will opt for a testing of their spray gun, and all sources with non-HVLP type spray guns will purchase new guns in response to the rule before the effective date and there are no recordkeeping costs associated with this requirement.





















k The number of sources expected to record a deviation for the rule requirements is based on the assumption of a 95 percent compliance rate. Approximately 5 percent of the estimated 6,472 new sources that are required to be in compliance with the rule in year 3 are expected to have some type of violation of the proposed work practices in any given year.


Sheet 4: A4

Table A4. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Commercial Miscellaneous Surface Coating Operations at Area Sources - Year 4 (all existing sources comply)










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 1,618 8,090 405 809 $404,314 $0 c


B. Required Activities

not applicable












C. Create Information





0 0 0






1) Initial Notification Letter
1 $1 1 1 1,618 1,618 81 162 $80,863 $1,618 c, d



2) Notification of Compliance Status 2 $1 1 2 29,259 58,518 2,926 5,852 $2,924,554 $29,259 c, e



3) Annual compliance report
2 $3 1 2 35,731 71,462 3,573 7,146 $3,571,456 $107,193 f

4. Recordkeeping Requirements






0 0 0





A. Read Instructions
Included in 3.A



0 0 0





B. Plan Activities
not applicable



0 0 0





C. Implement Activities
not applicable



0 0 0





D. Develop Record System
8 $0 1 8 1,618 12,944 647 1,294 $646,902 $0 c, g


E. Record information





0 0 0






1) Records of painter certification
0.25 $0 2.4 0.6 7,156 Not Applicable Not Applicable 4,294

h



2) Records of filter efficiency
0.25 $0 1 0.25 357 89 4 9 $4,464 $0 i



3) Records of spray gun
1.5 $0 1 1.5 0 0 0 0 $0 $0 j



4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 1,787 1,787 89 179 $89,286 $0 k


F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







152,721 7,636 19,566 $7,632,554 $138,070



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

179,923 $7,632,554 $138,070 $7,770,624









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 35,731 facilities will exist in any given year of this ICR. It is estimated that 1,618 new affected sources per year will be constructed. Existing sources will shutdown after a period of time and be replaced with new sources, but the total number of affected automotive refinishing shops expected to become subject to this rule will not change over this ICR period.





















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.
























c One-time only costs.































d Year 4 represents the fourth calendar year after the promulgation of this rule. It is assumed that 1,618 new affected sources were constructed or reconstructed during this year and are subject to the initial notification requirement during this year.


















e All new sources from year 4 (1,618), as well as all the sources that are considered existing sources under this rule, are required to submit a notification of compliance status starting in year 4. The recordkeeping and reporting schedule for existing sources becomes applicable during year 4.





















f The new and existing affected sources will have to submit their first annual compliance report by March 1 in the calendar year following their initial year of compliance. It is assumed that starting with year 4 the entire population (35,781) of commercial automotive refinishing facilities and miscellaneous surface coating facilities will submit an annual compliance report.





















g A new facility will develop a simple system to track the date of each employee's initial certification and most recent refresher training.



















h Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years and it is assumed that the burden will be on a five year recurring basis for each facility.





















i Assumes 1% of affected sources will opt to test the filter effieciency of filter that are not polyester fiber or fiberglass. If a source opts to test the efficiency of a filter it is assumed that the filter manufacturer would perform the test and the burden on the source would only be the time to record and file the efficiency of this filter based on the results of the manufacturer's test.





















j Only sources without an HVLP gun are required to maintain records on the testing of non-HVLP type spray guns. It is assumed that no source will opt for a testing of their spray gun, and all sources with non-HVLP type spray guns will purchase new guns in response to the rule before the effective date and there are no recordkeeping costs associated with this requirement.





















k The number of sources expected to record a deviation for the rule requirements is based on the assumption of a 95 percent compliance rate. Approximately 5 percent of the estimated 32,801 sources that are required to be in compliance with the rule in year 4 are expected to have some type of violation of the proposed work practices in any given year.


Sheet 5: B1

Table B1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Government-Owned Miscellaneous Surface Coating Operations at Area Sources - Year 1










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 250 1,250 63 125 $62,471 $0 c


B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 250 250.00 12.50 25.00 $12,494 $250 c, d



2) Notification of Compliance Status 2 $1 1 2 0 0.00 0.00 0.00 $0 $0 c, d



3) Annual compliance report
2 $3 1 2 0 0.00 0.00 0.00 $0 $0 d

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
not applicable












C. Implement Activities
not applicable












D. Develop Record System
8 $0 1 8 250 2,000 100 200 $99,954 $0



E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 250 Not Applicable Not Applicable 150






2) Records of filter efficiency
0.25 $0 1 0.25 0 0.00 0.00 0.00 $0 $0




3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0




4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 0 0.00 0.00 0.00 $0 $0



F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







3,500 175 500 $174,920 $250



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

4,175 $174,920 $250 $175,170









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 250 government owned paint shops exist. This assumption estimates one government-owned paint shop per county, for counties with a population greater than 240,000. It is estimated that no new government owned paint shops will open and that this rule will only impact existing government owned paint shops. The only impacts in the first year for existing sources are to read the rule and submit the initial notification and to develop a record system and enter data on painter certifications.
























b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.
























c One-time only costs.































d It is assumed that no new government-owned sources will open. Existing sources will not have to submit their first annual compliance report or notification of compliance status until March 1 of the 4th year after promulgation of this rule and are thus excluded from the initial 3-year ICR period.


Sheet 6: B2

Table B2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Government-Owned Miscellaneous Surface Coating Operations at Area Sources - Year 2










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 0 0 0 0 $0 $0



B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 0 0.00 0.00 0.00 $0 $0




2) Notification of Compliance Status 2 $1 1 2 0 0.00 0.00 0.00 $0 $0




3) Annual compliance report
2 $3 1 2 0 0.00 0.00 0.00 $0 $0


4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
not applicable












C. Implement Activities
not applicable












D. Develop Record System
8 $0 1 8 0 0 0 0 $0 $0



E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 0 Not Applicable Not Applicable 0 $0
c



2) Records of filter efficiency
0.25 $0 1 0.25 0 0.00 0.00 0.00 $0 $0




3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0




4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 0 0.00 0.00 0.00 $0 $0



F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







0 0 0 $0 $0



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

0 $0 $0 $0









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 250 government owned paint shops exist. This assumption estimates one government-owned paint shop per county, for counties with a population greater than 240,000. It is estimated that no new government owned paint shops will open and that this rule will only impact existing government owned paint shops. The only impacts in the second year for existing sources are enter data on renewed painter certifications.





















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.
























c Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years. It is assumed that 20 percent of the certifications from 250 existing facilities will have to be updated in the record system each year.


Sheet 7: B3

Table B3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Government-Owned Miscellaneous Surface Coating Operations at Area Sources - Year 3










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 0 0 0 0 $0 $0



B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 0 0.00 0.00 0.00 $0 $0




2) Notification of Compliance Status 2 $1 1 2 0 0.00 0.00 0.00 $0 $0




3) Annual compliance report
2 $3 1 2 0 0.00 0.00 0.00 $0 $0


4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
not applicable












C. Implement Activities
not applicable












D. Develop Record System
8 $0 1 8 0 0 0 0 $0 $0



E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 0 Not Applicable Not Applicable 0 $0
c



2) Records of filter efficiency
0.25 $0 1 0.25 0 0.00 0.00 0.00 $0 $0




3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0




4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 0 0.00 0.00 0.00 $0 $0



F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







0 0 0 $0 $0



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

0 $0 $0 $0









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 250 government owned paint shops exist. This assumption estimates one government-owned paint shop per county, for counties with a population greater than 240,000. It is estimated that no new government owned paint shops will open and that this rule will only impact existing government owned paint shops. The only impacts in the third year for existing sources are enter data on renewed painter certifications.





















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.
























c Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years. It is assumed that 20 percent of the certifications from 250 existing facilities will have to be updated in the record system each year.


Sheet 8: B4

Table B4. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Government-Owned Miscellaneous Surface Coating Operations at Area Sources - Year 4 (all existing sources comply)










45.15 58.48 19.03








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
5 $0 1 5 0 0 0 0 $0 $0



B. Required Activities

not applicable












C. Create Information















1) Initial Notification Letter
1 $1 1 1 0 0.00 0.00 0.00 $0 $0




2) Notification of Compliance Status 2 $1 1 2 250 500.00 25.00 50.00 $24,989 $250 c, d



3) Annual compliance report
2 $3 1 2 250 500.00 25.00 50.00 $24,989 $750 d

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
not applicable












C. Implement Activities
not applicable












D. Develop Record System
8 $0 1 8 0 0 0 0 $0 $0



E. Record information















1) Records of painter certification
0.25 $0 2.4 0.6 0 Not Applicable Not Applicable 0

e



2) Records of filter efficiency
0.25 $0 1 0.25 0 0.00 0.00 0.00 $0 $0




3) Records of spray gun
1.5 $0 1 1.5 0 0.00 0.00 0.00 $0 $0




4) Records of deviation from the rule requirements and corrective actions taken 1 $0 1 1 13 12.50 0.63 1.25 $625 $0



F. Personnel Training
Not applicable












G. Time for audits
Not applicable











TOTAL:







1,013 51 101 $50,602 $1,000



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

1,164 $50,602 $1,000 $51,602









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 250 government owned paint shops exist. This assumption estimates one government-owned paint shop per county, for counties with a population greater than 240,000. It is estimated that no new government owned paint shops will open and that this rule will only impact existing government owned paint shops. Existing sources are required to be in compliance with the rule by year four, and as such they must submit a notification of compliance status, an annual compliance report, and enter data on renewed painter certifications.
























b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at 58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.



























c One-time only costs.































d Existing sources have to submit their first annual compliance report or notification of compliance status until March 1 of the 4th year after promulgation of this rule.





















e Assumes that each facility has 2.4 painters, on average. A record of the certification must be kept for each painter at the facility, and entering the record for each painter is expected to take 15 minutes. Certifications are good for 5-years. It is assumed that 20 percent of the certifications from 250 existing facilities will have to be updated in the record system each year.


Sheet 9: C1

Table C1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Paint Stripping Operations at Area Sources - Year 1










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
2 $0 1 2 3,000 6,000.00 300.00 600.00 $299,862 $0 c


B. Required Activities Process/Review Information
2 $0 1 2 3,000 6,000.00 300.00 600.00 $299,862 $0



C. Create Information















1) Initial Notification Letter
1 $1 1 1 3,000 3,000.00 150.00 300.00 $149,931 $3,000 c, d



2) Notification of Compliance Status 1 $1 0 0 0 0.00 0.00 0.00 $0 $0




3) Annual compliance report
1 $3 0 0 0 0.00 0.00 0.00 $0 $0


4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
8 $0 0 0 0 0 0 0 $0 $0



C. Implement Activities
















1) Train personnel 8 $0 0 0 0 0 0 0 $0 $0





2) Update Plan 2 $0 0 0 0 0 0 0 $0 $0



D. Record information
1 $0 0 0 0 0 0 0 $0 $0



















TOTAL:







15,000 750 1,500 $749,655 $3,000



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

17,250 $749,655 $3,000 $752,655









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 3,000 existing area source paint stripping facilities will exist in any given year of this ICR.


















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at $58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.



























c One-time only costs.































d The existing affected sources must submit their initial notification within one year from promulgation, which makes for a total of 3,000 sources submitting an initial notification within one year of promulgation of this rule.


Sheet 10: C2

Table C2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Paint Stripping Operations at Area Sources - Year 2










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
2 $0 0 0 0 0.00 0.00 0.00 $0 $0



B. Required Activities Process/Review Information
2 $0 0 0 0 0.00 0.00 0.00 $0 $0



C. Create Information















1) Initial Notification Letter
1 $1 0 0 0 0.00 0.00 0.00 $0 $0




2) Notification of Compliance Status 1 $1 0 0 0 0.00 0.00 0.00 $0 $0




3) Annual compliance report
1 $3 0 0 0 0.00 0.00 0.00 $0 $0


4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
8 $0 1 8 1050 8,400 420 840 $419,807 $0 c, d


C. Implement Activities
















1) Train personnel 8 $0 0 0 0 0 0 0 $0 $0





2) Update Plan 2 $0 0 0 0 0 0 0 $0 $0



D. Record information
1 $0 0 0 0 0 0 0 $0 $0



















TOTAL:







8,400 420 840 $419,807 $0



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

9,660 $419,807 $0 $419,807









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 3,000 existing area source paint stripping facilities will exist in any given year of this ICR.


















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at $58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.



























c One-time only costs.































d Facilities that annually use more than 150 gallons of paint strippers that contain methylene chloride (estimated to be 1,050 facilities out of the 3,000 facilities) are required to develop a written plan. They are also required to submit a notification of compliance status report and annual compliance reports.


Sheet 11: C3

Table C3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Paint Stripping Operations at Area Sources - Year 3










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
2 $0 0 0 0 0.00 0.00 0.00 $0 $0 c


B. Required Activities Process/Review Information
2 $0 0 0 0 0.00 0.00 0.00 $0 $0



C. Create Information















1) Initial Notification Letter
1 $1 0 0 0 0.00 0.00 0.00 $0 $0 c



2) Notification of Compliance Status 1 $1 1 1 1,050 1,050.00 52.50 105.00 $52,476 $1,050 c, d



3) Annual compliance report
1 $3 0 0 0 0.00 0.00 0.00 $0 $0 e

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
8 $0 0 0 0 0 0 0 $0 $0



C. Implement Activities
















1) Train personnel 15 $0 1 15 1050 15,750 100 200 $309,219 $0 f




2) Update Plan 2 $0 0 0 0 0 0 0 $0 $0



D. Record information
1 $0 0 0 0 0 0 0 $0 $0



















TOTAL:







16,800 153 305 $361,695 $1,050



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

17,258 $361,695 $1,050 $362,745









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 3,000 existing area source paint stripping facilities will exist in any given year of this ICR.


















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at $58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.



























c One-time only costs.































d Assumes sources that annually use more than 150 gallons of paint strippers that contain methylene chloride (estimated to be 1,050 facilities out of the 3,000 facilities) complete and submit their notification of compliance status at the end of this year.


















e The 15 hrs training includes 2 technical hrs (at $45/hr) and 13 laborer hrs (at $15/hr) for an average labor rate of $19/hr. The management and clerical hours are based on the technicl hours only.


















f Existing sources will not have to submit their first annual compliance report until March 1 of the 4th year after promulgation of this rule and are thus excluded from the initial 3-year ICR period.


Sheet 12: C4

Table C4. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

of Paint Stripping Operations at Area Sources - Year 4










45 58 19








(A)
(B) (C) (D) (E) (F) (G)








Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Footnotes





Hours Per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor






Occurrence Per Per Respondent Per Year (a) Per Year Per Year Per Year Per Year Costs






(Technical Occurrence Respondent Per Year
@$45.15 @$58.48 @$19.03 (b) Per Year


Burden Item hours)
Per Year (C=A x B)
(CXD) (E x 0.05) (E x 0.1)




1. Applications

Not applicable











2. Surveys and Studies

Not applicable











3. Reporting Requirements















A. Read and Understand Rule Requirements
2 $0 0 0 0 0.00 0.00 0.00 $0 $0



B. Required Activities Process/Review Information
2 $0 0 0 0 0.00 0.00 0.00 $0 $0



C. Create Information















1) Initial Notification Letter
1 $1 0 0 0 0.00 0.00 0.00 $0 $0




2) Notification of Compliance Status 1 $1 0 0 0 0.00 0.00 0.00 $0 $0




3) Annual compliance report
1 $3 1 1 1,050 1,050.00 52.50 105.00 $52,476 $3,150 c

4. Recordkeeping Requirements















A. Read Instructions
Included in 3.A












B. Plan Activities
8 $0 0 0 0 0 0 0 $0 $0



C. Implement Activities
















1) Train personnel 8 $0 0 0 0 0 0 0 $0 $0





2) Update Plan 2 $0 1 2 1050 2,100 105 210 $104,952 $0 e


D. Record information
1 $0 0 0 0 0 0 0 $0 $0



















TOTAL:







3,150 158 315 $157,428 $3,150



























Total Hours Labor Non-Labor Total









Summary of Respondent Burden

3,623 $157,428 $3,150 $160,578









Annualized Capital and Startup

0 $0 $0 $0









O & M Summary

0 0 0 0





















a Assumes that a total of 3,000 existing area source paint stripping facilities will exist in any given year of this ICR.


















b Labor references an average of the Bureau of Labor Statistics rates in the Automotive Body, Paint, Interior, and Glass Repair Industry (NAICS code 811120), Fabricated Metal Product Manufacturing (NAICS code 332000) and Plastics Product Manufacturing (NAICS code 236100), for the following occupations: automotive body and related repairers, first-line supervisors/managers of mechanics, installers, and repairers, and file clerks, engineering managers, environmental engineers, and clerical positions. These rates are fully loaded (adjusted by an overhead and profit rate). Hourly rates are as follows: technical at $45.15, management at $58.48, and clerical at $19.03. One hour of technical work requires 6 minutes of clerical and 3 minutes of managerial support.



























c One-time only costs.































d Assumes existing sources that annually use more than 150 gallons of paint strippers that contain methylene chloride (estimated to be 1,050 facilities out of the 3,000 facilities) will submit their first annual compliance report by March 1 of the 4th year after promulgation of this rule.


















e Facilities will update the work practice plan and placards displaying this plan.


Sheet 13: D1

Table D1. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources - Year 1







33 72 25




(A) (B) (C) (D) (E) (F)




Number of EPA Tech Management Clerical EPA




Occurrences Hours Hours Hours Hours Cost




Per Year Per Per Year Per Year Per Year Per Year (a)






Occurrence @$33 @$72 @$25
Burden Item

(Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)
1. Applications

not applicable



0
2. Read and Understand Rule Requirements

60 b, c 40 2400 120 240 $182,760
3. Required Activities

not applicable






A. Observe initial performance tests
not applicable





B. Observe annual performance tests
not applicable






C. Excess emissions -- Enforcement Activities
not applicable






D. Create Information
not applicable






E. Gather Information
not applicable






F. Report Reviews









1) Initial Notification 38,981 c 0.5 19,491 975 1,949 $1,484,202


2) Notification of Compliance Status 3,236 c 0.5 1,618 81 162 $123,211


3) Review annual compliance report
0
0.5 0 0 0 $0
4. Travel expenses:

not applicable





TOTAL:





23,509 1,175 2,351 $1,790,172







Total Hours Labor Non-Labor Total
a Figures may not add exactly due to rounding.




27,035 $1,790,172 $0 $1,790,172
b Assume that each State and EPA Region reviews the MSCAS rule to develop a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10 Regions = 60 occurrences.
c One-time only costs.









Sheet 14: D2

Table D2. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources - Year 2







33 72 25




(A) (B) (C) (D) (E) (F)




Number of EPA Tech Management Clerical EPA




Occurrences Hours Hours Hours Hours Cost




Per Year Per Per Year Per Year Per Year Per Year (a)






Occurrence @$33 @$72 @$25
Burden Item

(Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)
1. Applications

not applicable



0
2. Read and Understand Rule Requirements

0 b, c 40 0 0 0 $0
3. Required Activities

not applicable






A. Observe initial performance tests
not applicable





B. Observe annual performance tests
not applicable






C. Excess emissions -- Enforcement Activities
not applicable






D. Create Information
not applicable






E. Gather Information
not applicable






F. Report Reviews









1) Initial Notification 1,618 c 0.5 809 40 81 $31,632


2) Notification of Compliance Status 1,618 c 0.5 809 40 81 $31,632


3) Review annual compliance report
3,236
0.5 1,618 81 162 $63,264
4. Travel expenses:

not applicable





TOTAL:





3,236 162 324 $126,528







Total Hours Labor Non-Labor Total
a Figures may not add exactly due to rounding.




3,721 $126,528 $0 $126,528
b Review of the rule by EPA Regions and States only occurs in year 1 of this ICR








c One-time only costs.









Sheet 15: D3

Table D3. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources - Year 3







33 72 25




(A) (B) (C) (D) (E) (F)




Number of EPA Tech Management Clerical EPA




Occurrences Hours Hours Hours Hours Cost




Per Year Per Per Year Per Year Per Year Per Year (a)






Occurrence @$33 @$72 @$25
Burden Item

(Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)
1. Applications

not applicable



0
2. Read and Understand Rule Requirements

0 b, c 40 0 0 0 $0
3. Required Activities

not applicable






A. Observe initial performance tests
not applicable





B. Observe annual performance tests
not applicable






C. Excess emissions -- Enforcement Activities
not applicable






D. Create Information
not applicable






E. Gather Information
not applicable






F. Report Reviews









1) Initial Notification 1,618 c 0.5 809 40 81 $31,632


2) Notification of Compliance Status 2,668 c 0.5 1,334 67 133 $52,159


3) Review annual compliance report
4,854
0.5 2,427 121 243 $94,896
4. Travel expenses:

not applicable





TOTAL:





4,570 229 457 $178,687







Total Hours Labor Non-Labor Total
a Figures may not add exactly due to rounding.




5,256 $178,687 $0 $178,687
b Review of the rule by EPA Regions and States only occurs in year 1 of this ICR








c One-time only costs.









Sheet 16: D4

Table D4. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources - Year 4







33 72 25




(A) (B) (C) (D) (E) (F)




Number of EPA Tech Management Clerical EPA




Occurrences Hours Hours Hours Hours Cost




Per Year Per Per Year Per Year Per Year Per Year (a)






Occurrence @$33 @$72 @$25
Burden Item

(Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)
1. Applications

not applicable



0
2. Read and Understand Rule Requirements

0 b, c 40 0 0 0 $0
3. Required Activities

not applicable






A. Observe initial performance tests
not applicable





B. Observe annual performance tests
not applicable






C. Excess emissions -- Enforcement Activities
not applicable






D. Create Information
not applicable






E. Gather Information
not applicable






F. Report Reviews









1) Initial Notification 1,618 c 0.5 809 40 81 $31,632


2) Notification of Compliance Status 29,509 c 0.5 14,755 738 1,475 $576,901


3) Review annual compliance report
37,031
0.5 18,516 926 1,852 $723,956
4. Travel expenses:

not applicable





TOTAL:





34,079 1,704 3,408 $1,332,489







Total Hours Labor Non-Labor Total
a Figures may not add exactly due to rounding.




39,191 $1,332,489 $0 $1,332,489
b Review of the rule by EPA Regions and States only occurs in year 1 of this ICR








c One-time only costs.









Sheet 17: Table 4

Table 4 Summary of Burden and Costs for the Affected Source Categories





Sector Commercial Misc. Surface Coating Government Misc. Surface Coating Paint Stripping Total
Year 1 Burden Hours #VALUE! 4,175 17,250 #VALUE!
Labor Cost #VALUE! $174,920 $749,655 #VALUE!
O&M cost $38,967 $250 $3,000 $42,217

Year 2 Burden Hours #VALUE! - 9,660 #VALUE!
Labor Cost #VALUE! $- $419,807 #VALUE!
O&M cost $12,944 $- $- $12,944

Year 3 Burden Hours 45,620 - 17,258 $62,877
Labor Cost $1,795,962 $- $361,695 $2,157,657
O&M cost $17,798 $- $1,050 $18,848

Annual Average Burden Hours #VALUE! 1,392 14,723 #VALUE!
Labor Cost #VALUE! $58,307 $510,386 #VALUE!
O&M cost $23,236 $83 $1,350 $24,670







Sheet 18: Table 5

Table 5 Summary of Agency Burden for Years 1-3 of this ICR.






Agency


Year 1 Burden Hours 27,035


Labor Cost $1,790,172


O&M cost $-






Year 2 Burden Hours 3,721


Labor Cost $126,528


O&M cost $-






Year 3 Burden Hours 5,256

12,004
Labor Cost $178,687

$698,462
O&M cost $-






3-year Average Burden Hours 12,004


Labor Cost $698,462


O&M cost $-


File Typeapplication/vnd.ms-excel
AuthorEeastern Reseach Group, Inc.
Last Modified Byckerwin
File Modified2007-09-14
File Created1998-09-17

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