Burden Calculations

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Overview

Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
3-Year Summary
O&M
Wages

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost (Year 1) – National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$126.95
3. Reporting requirements										Technical	$71.38
A. Familiarization with rule requirements										Clerical	$45.23
New sources	4	1	4	1	4	0.2	0.4	$329.00
Existing sources c	1	1	1	65	65	3.3	6.5	$5,346.23	Note to EPA: We have accounted for time for existing respondents to refamiliarize with the rule requirements, a standard in most CAA ICRs.
B. Gather information	4	1	4	1	4	0.2	0.4	$329.00
C. Write Report
Initial report (including small quantity manufacturers) d	25.3	1	25.3	1	25.3	1.26	2.53	$2,076.80
Supplemental report e	4	1	4	66	264	13.2	26.4	$21,713.91
Variance or compliance extension application f	24	1	24	0.1	2.4	0.12	0.24	$197.40
Respond to the EPA request for data g	60	1	60	10	600	30	60	$49,349.79
Subtotal for Reporting Requirements					1,109			$79,342
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	16	1	16	1	16	1	2	$1,315.99
C. Calculation of reactivity h, i, j	0.5	37	18.5	11	204	10	20	$16,737.80
D. Maintenance of batch information k	0.25	481	120	66	7,937	397	794	$652,774.35
Subtotal for Recordkeeping Requirements					9,379			$670,828
Total Labor Burden and Costs (rounded) k					10,500			$750,000
Total Capital and O&M Cost (rounded) k								$0
GRAND TOTAL (rounded) k								$750,000
Assumptions:
a We have assumed 65 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $126.95 (managerial), $71.38 (technical), and $45.23 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2020 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8090 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that each existing source will re-familiarize with the requirements each year.
d New sources file initial reports in their first year.
e We assume each new and existing respondent will have one incident per year that will require supplemental reporting (also referred to as a “notice of change” report).
f We assume that 10 percent of new respondents will request a variance or extension on their compliance application.
g We assume that 15 percent of new and existing sources per year will be required to respond to enforcement questions or other agency requests for information.
h We assume that the time required (0.5 hours) for the calculation of reactivity for formulations for new coating categories is the same for new sources and existing sources.
i We assume each respondent will maintain records on 37 formulations (average for industry).
j The number of respondents includes one new and 10 existing respondents. We have assumed that 10 existing manufacturers add new coating categories each year.
k We have assumed that it takes the same amount of time (0.25 hours) for new and existing sources to maintain batch information.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Annual Respondent Burden and Cost (Year 2) – National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$126.95
3. Reporting requirements										Technical	$71.38
A. Familiarization with rule requirements										Clerical	$45.23
New sources	4	1	4	1	4	0.2	0.4	$329.00
Existing sources c	1	1	1	66	66	3.3	6.6	$5,428.48	Note to EPA: We have accounted for time for existing respondents to refamiliarize with the rule requirements, a standard in most CAA ICRs.
B. Gather information	4	1	4	1	4	0.2	0.4	$329.00
C. Write Report
Initial report (including small quantity manufacturers) d	25.3	1	25.3	1	25.3	1.26	2.53	$2,076.80
Supplemental report e	4	1	4	67	268	13.4	26.8	$22,042.91
Variance or compliance extension application f	24	1	24	0.1	2.4	0.12	0.24	$197.40
Respond to the EPA request for data g	60	1	60	10	600	30	60	$49,349.79
Subtotal for Reporting Requirements					1,115			$79,753
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	16	1	16	1	16	1	2	$1,315.99
C. Calculation of reactivity h, i, j	0.5	37	18.5	11	204	10	20	$16,737.80
D. Maintenance of batch information k	0.25	481	120	67	8,057	403	806	$662,664.87
Subtotal for Recordkeeping Requirements					9,518			$680,719
Total Labor Burden and Costs (rounded) k					10,600			$760,000
Total Capital and O&M Cost (rounded) k								$0
GRAND TOTAL (rounded) k								$760,000
Assumptions:
a We have assumed 66 existing respondents in year 2 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $126.95 (managerial), $71.38 (technical), and $45.23 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2020 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8090 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that each existing source will re-familiarize with the requirements each year.
d New sources file initial reports in their first year.
e We assume each new and existing respondent will have one incident per year that will require supplemental reporting (also referred to as a “notice of change” report).
f We assume that 10 percent of new respondents will request a variance or extension on their compliance application.
g We assume that 15 percent of new and existing sources per year will be required to respond to enforcement questions or other agency requests for information.
h We assume that the time required (0.5 hours) for the calculation of reactivity for formulations for new coating categories is the same for new sources and existing sources.
i We assume each respondent will maintain records on 37 formulations (average for industry).
j The number of respondents includes one new and 10 existing respondents. We have assumed that 10 existing manufacturers add new coating categories each year.
k We have assumed that it takes the same amount of time (0.25 hours) for new and existing sources to maintain batch information.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 3

Table 3: Annual Respondent Burden and Cost (Year 3) – National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$126.95
3. Reporting requirements										Technical	$71.38
A. Familiarization with rule requirements										Clerical	$45.23
New sources	4	1	4	1	4	0.2	0.4	$329.00
Existing sources c	1	1	1	67	67	3.4	6.7	$5,510.73	Note to EPA: We have accounted for time for existing respondents to refamiliarize with the rule requirements, a standard in most CAA ICRs.
B. Gather information	4	1	4	1	4	0.2	0.4	$329.00
C. Write Report
Initial report (including small quantity manufacturers) d	25.3	1	25.3	1	25.3	1.26	2.53	$2,076.80
Supplemental report e	4	1	4	68	272	13.6	27.2	$22,371.90
Variance or compliance extension application f	24	1	24	0.1	2.4	0.12	0.24	$197.40
Respond to the EPA request for data g	60	1	60	10	600	30	60	$49,349.79
D. Write Triennial Report h
Establish account for NEI	2	1	2	68	136	6.8	13.6	$11,185.95
Enter general information into database	0.5	1	0.5	68	34	1.7	3.4	$2,796.49
Enter product formulations into database	0.25	37	9.25	68	629	31.45	62.9	$51,735.03
Enter company-wide volumes of coating constituents into database	2	1	2	68	136	6.8	13.6	$11,185.95
Subtotal for Reporting Requirements					2,196			$157,068
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	16	1	16	1	16	1	2	$1,315.99
C. Calculation of reactivity i, j, k	0.5	37	18.5	11	204	10	20	$16,737.80
D. Maintenance of batch information l	0.25	481	120	68	8,177	409	818	$672,555.39
E. Triennial Report
Calculate company-wide volume usage of coating constituents m	56	1	56	68	3,808	190	381	$313,206.67
QA/QC and review n	40	1	40	68	2,720	136	272	$223,719.05
Read instructions/take training for reporting	4	1	4	68	272	14	27	$22,371.90
Subtotal for Recordkeeping Requirements					17,476			$1,249,907
Total Labor Burden and Costs (rounded) o					19,700			$1,410,000
Total Capital and O&M Cost (rounded) o								$0
GRAND TOTAL (rounded) o								$1,410,000
Assumptions:
a We have assumed 67 existing respondents in year 3 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $126.95 (managerial), $71.38 (technical), and $45.23 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2020 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8090 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that each existing source will re-familiarize with the requirements each year.
d New sources file initial reports in their first year.
e We assume each new and existing respondent will have one incident per year that will require supplemental reporting (also referred to as a “notice of change” report).
f We assume that 10 percent of new respondents will request a variance or extension on their compliance application.
g We assume that 15 percent of new and existing sources per year will be required to respond to enforcement questions or other agency requests for information.
h We assume each respondent will submit a triennial report of formulations and VOC usage.
i We assume that the time required (0.5 hours) for the calculation of reactivity for formulations for new coating categories is the same for new sources and existing sources.
j We assume each respondent will maintain records on 37 formulations (average for industry).
k The number of respondents includes one new and 10 existing respondents. We have assumed that 10 existing manufacturers add new coating categories each year.
l We have assumed that it takes the same amount of time (0.25 hours) for new and existing sources to maintain batch information.
m We have assumed that it takes 16 hours to gather information and an additional 40 hours to perform calculations. We have assumed that an average of 20 different constituents are used by each facility and that it takes 2 hours to sum the information for each constituent. (16 + (20 x 2) = 56)
n We have assumed that the Triennial report undergoes QA/QC and review prior to submittal to EPA.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 4

Table 4: Annual EPA Burden and Cost (Year 1) - National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (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 per year (C=AxB)	Number of occurrences per respondent per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial report c	8	1	8	1	8	0.4	0.8	$459.64		Labor Rates
2. Supplemental report d	4	1	4	66	264	13.2	26.4	$15,168.12		Management	$69.04
3. Variance application e	16	1	16	0.1	1.6	0.08	0.16	$91.93		Technical	$51.23
4. Supplemental data request f	40	1	40	10	400	20	40	$22,982.00		Clerical	$27.73
TOTAL (rounded) g					775			$38,700
Assumptions:
a We have assumed 65 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $69.04 (managerial), $51.23 (technical), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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 eight hours for the Agency to review the initial report filed by new sources.
d We have assumed that it will take four hours for the Agency to review to review the supplemental reports.
e We have assumed that it will take sixteen hours for the Agency to review requests for variances or extensions filed by new sources on their compliance application.
f We assume that EPA will request additional data from 15 percent of new and existing sources regarding enforcement questions or other agency requests for information, and that it will take 40 hours to review this data.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 5

Table 5: Annual EPA Burden and Cost (Year 2) - National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (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 per year (C=AxB)	Number of occurrences per respondent per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial report c	8	1	8	1	8	0.4	0.8	$459.64		Labor Rates
2. Supplemental report d	4	1	4	67	268	13.4	26.8	$15,397.94		Management	$69.04
3. Variance application e	16	1	16	0.1	1.6	0.08	0.16	$91.93		Technical	$51.23
4. Supplemental data request f	40	1	40	10	400	20	40	$22,982.00		Clerical	$27.73
TOTAL (rounded) g					779			$38,900
Assumptions:
a We have assumed 66 existing respondents in year 2 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $69.04 (managerial), $51.23 (technical), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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 eight hours for the Agency to review the initial report filed by new sources.
d We have assumed that it will take four hours for the Agency to review to review the supplemental reports.
e We have assumed that it will take sixteen hours for the Agency to review requests for variances or extensions filed by new sources on their compliance application.
f We assume that EPA will request additional data from 15 percent of new and existing sources regarding enforcement questions or other agency requests for information, and that it will take 40 hours to review this data.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: Table 6

Table 6: Annual EPA Burden and Cost (Year 3) - National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (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 per year (C=AxB)	Number of occurrences per respondent per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial report c	8	1	8	1	8	0.4	0.8	$459.64		Labor Rates
2. Supplemental report d	4	1	4	68	272	13.6	27.2	$15,627.76		Management	$69.04
3. Variance application e	16	1	16	0.1	1.6	0.08	0.16	$91.93		Technical	$51.23
4. Supplemental data request f	40	1	40	10	400	20	40	$22,982.00		Clerical	$27.73
5. Triennial Report g
A. Develop Database and Report Forms	300	1	300	1	300	15	30	$17,236.50
B. Populate Database	12	1	12	68	816	41	82	$46,883.28
C. QA/Review Data	600	1	600	1	600	30	60	$34,473.00
TOTAL (rounded) h					2,760			$138,000
Assumptions:
a We have assumed 67 existing respondents in year 3 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $69.04 (managerial), $51.23 (technical), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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 eight hours for the Agency to review the initial report filed by new sources.
d We have assumed that it will take four hours for the Agency to review to review the supplemental reports.
e We have assumed that it will take sixteen hours for the Agency to review requests for variances or extensions filed by new sources on their compliance application.
f We assume that EPA will request additional data from 15 percent of new and existing sources regarding enforcement questions or other agency requests for information, and that it will take 40 hours to review this data.
g Each respondent is required to submit a report of formulations and VOC usage once every three years. We assume EPA will develop/update the database and reporting forms, collect the data submissions from all respondents, populate the database, and then perform a QA and review of the data in year 3.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: 3-Year Summary

Three Year Summary
Respondent Burden and Costs
Year	Reporting Hours	Recordkeeping Hours	Total Hours	Reporting Costs	Recordkeeping Costs	Total Costs
Year 1	1,109	9,379	10,489	$79,342	$670,828	$750,170
Year 2	1,115	9,518	10,633	$79,753	$680,719	$760,472
Year 3	2,196	17,476	19,672	$157,068	$1,249,907	$1,406,975
Total	4,421	36,373	40,794	$316,164	$2,601,454	$2,917,617
3-Year Average	1,474	12,124	13,598	$105,388	$867,151	$972,539
Agency Burden and Costs
Year	Labor Hours	Labor Costs
Year 1	775	$38,700
Year 2	779	$38,900
Year 3	2,760	$138,000
Total	4,314	$215,600
3-Year Average	1,438	$71,867
Average Hours per Response		80.6

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Sheet 8: 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 a	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M	Total O&M, (ExF)
Total			$0			$0
No capital/startup and operation and maintenance costs are associated with this rulemaking.
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	1	65	0	0	66
2	1	66	0	0	67
3	1	67	0	0	68
Average	1	66	0	0	67
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
Year 1
Initial report	1	1	0	1
Supplemental report	66	1	0	66
Variance or compliance extension application	0.1	1	0	0.1
Respond to the EPA request for data	10	1	0	10
Year 2
Initial report	1	1	0	1
Supplemental report	67	1	0	67
Variance or compliance extension application	0.1	1	0	0.1
Respond to the EPA request for data	10	1	0	10
Year 3
Initial report	1	1	0	1
Supplemental report	68	1	0	68
Variance or compliance extension application	0.1	1	0	0.1
Respond to the EPA request for data	10	1	0	10
Establish account for NEI	68	1	0	68
Enter general information into database	68	1	0	68
Enter product formulations into database	68	1	0	68
Enter company wide volumes of coating constituents into database	68	1	0	68
			Total	506
			Average	169

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Sheet 9: Wages

Wages
Industry
U.S Bureau of Labor Statistics
May 2020 National Occupational Employment and Wage Estimates
https://www.bls.gov/oes/current/oes_nat.htm#00-0000
Labor Category	Occupational Code	Mean Wage Estimate ($2020)	Loaded Wage (+110%)($2020)
Managerial	11-1021	$60.45	$126.95
Technical	51-8090	$33.99	$71.38
Clerical	43-6010	$21.54	$45.23
This ICR uses the following labor rates: $126.95 (managerial), $71.38 (technical), and $45.23 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2020 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8090 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
Government
Labor Rates
Management	$69.04	(GS-13, Step 5, $43.15 + 60%)
Technical	$51.23	(GS-12, Step 1, $32.02 + 60%)
Clerical	$27.73	(GS-6, Step 3, $17.33 + 60%)
This ICR uses the following labor rates: $69.04 (managerial), $51.23 (technical), and $27.73 (clerical). These rates are from the Office of Personnel Management (OPM), 2021 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.