Burden Calculation Table

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Overview

Summary Table
Capital and O&M Costs
# Respondents
# Responses Calcs
Respondent Burden
Agency Burden

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Sheet 1: Summary Table

Table 1: Summary of Annual Respondent Burden and Cost – NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)
	Sector	Commercial Misc. Surface Coating	Government Misc. Surface Coating	Paint Stripping	Total
	Burden Hours	163,000	877	4,830	169,000
	Labor Cost	$17,800,000	$96,000	$529,000	$18,400,000
	Capital and O&M Costs	$113,000	$750	$3,150	$117,000
	Grand Total	$17,900,000	$96,800	$532,000	$18,500,000
					4	hrs/response

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Sheet 2: Capital and O&M Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
Burden Item	(A)	(B)	(C)	(D)
	Annual O&M Costs per Occurrence	Number of Occurrences per Respondent per Year	Average Number of Respondents with O&M	Total O&M,
				(A× B×C)
Miscellaneous Surface Coating
Initial Notification Letter	$1	1	25	$25
Notification of Compliance Status	$1	1	25	$25
Annual Compliance Report	$3	1	831	$2,493
Subtotal				$2,543
Commercial Motor Vehicle and Mobile Equipment Refinishing
Initial Notification Letter	$1	1	1,593	$1,593
Notification of Compliance Status	$1	1	1,593	$1,593
Annual Compliance Report	$3	1	35,731	$107,193
Subtotal				$110,379
Government Motor Vehicle and Mobile Equipment Refinishing
Annual Compliance Report	$3	1	250	$750
Subtotal				$750
Paint Stripping
Annual Compliance Report	$3	1	1,050	$3,150
Subtotal				$3,150
TOTALa				$117,000
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: # Respondents

Number of Respondents1
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are No Longer Subject	Number of Respondents
					(E=A+B+C-D)
Miscellaneous Surface Coating
1	25	831	0	25	831
2	25	831	0	25	831
3	25	831	0	25	831
Commercial Motor Vehicle and Mobile Equipment Refinishing
1	1,593	35,731	0	1,593	35,731
2	1,593	35,731	0	1,593	35,731
3	1,593	35,731	0	1,593	35,731
Government Motor Vehicle and Mobile Equipment Refinishing
1	0	250	0	0	250
2	0	250	0	0	250
3	0	250	0	0	250
Paint Stripping
1	0	1,050	1,950	0	3,000
2	0	1,050	1,950	0	3,000
3	0	1,050	1,950	0	3,000
Average	1,618	37,862	1,950	1,618	39,812
1 This ICR assumes a total of 39,812 commercial facilities exist in any given year, and that 1,618 new sources per year will be constructed. This ICR also assumes that existing sources will shut down at a rate equal to that replaced by new sources. Therefore, the total number of affected sources subject to this rule (i.e., 39,312 sources) will not change in any given year.

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Sheet 4: # Responses Calcs

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Miscellaneous Surface Coating
Initial notification letter	25	1	0	25
Notification of compliance status	25	1	0	25
Annual compliance report	831	1	0	831
Subtotal				881
Commercial Motor Vehicle and Mobile Equipment Refinishing
Initial notification letter	1,593	1	0	1,593
Notification of compliance status	1,593	1	0	1,593
Annual compliance report	35,731	1	0	35,731
Subtotal				38,917
Government Motor Vehicle and Mobile Equipment Refinishing
Initial notification letter	0	1	0	0
Notification of compliance status	0	1	0	0
Annual compliance report	250	1	0	250
Subtotal				250
Paint Stripping
Initial notification letter	0	1	0	0
Notification of compliance status	0	1	0
Annual compliance report	1,050	1	1,950	3,000
Subtotal				3,000
Total (after rounding)				43,048

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Sheet 5: Respondent Burden

Table 1a: Annual Respondent Burden and Cost – Commercial Motor Vehicle and Mobile Equipment Refinishing and Miscellaneous Surface Coating Operations at Area Sources
Burden Item	A	B	C	D	E	F	G	H		TECH	$112.98
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b		MGMT	$149.35
1. Applications	Not applicable									CLER	$54.81
2. Surveys and studies	Not applicable
3. Reporting requirements
A. Familiarization with Regulatory Requirements
New sources	5	1	5	1,618	8,090	404.5	809	$1,018,761.57
Existing sources	1	1	1	36,562	36,562	1,828.1	3,656	$4,604,197.82			Note: assumes 1 hr for existing source to familiarize with regulations.
B. Required activities	Not applicable
C. Create information
1. Initial notification letter	1	1	1	1,618	1,618	80.9	161.8	$203,752.31
2. Notification of compliance status	2	1	2	1,618	3,236	161.8	323.6	$407,504.63
3. Annual compliance report	2	1	2	36,562	73,124	3,656.2	7,312.4	$9,208,395.63
Reporting Subtotal					141,025			$15,442,612
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	Included in 3A
B. Plan activities	Not applicable
C. Implement activities	Not applicable
D. Develop record system	8	1	8	1,618	12,944	647.2	1,294.4	$1,630,018.50
E. Time to record information
1. Records of painter certification	0.25	2.4	0.6	7,156	4,293.6	214.68	429.36	$540,686.61
2. Records of filter efficiency	0.25	1	0.25	357	89.25	4.46	8.93	$11,239.12
3. Records of spray gun	1.5	1	1.5	0	0	0	0	0
4. Records of deviation from rule requirements and corrective actions taken	1	1	1	1,787	1,787	89.35	178.7	$225,034.23
F. Time to train personnel	Not applicable
G. Time for audits	Not applicable
Recordkeeping Subtotal					21,981			$2,406,978
TOTAL ANNUAL BURDEN AND COST (ROUNDED)c					163,000			$17,800,000
TOTAL CAPITAL AND O&M COST (ROUNDED)c								$113,000
GRAND TOTAL (ROUNDED)c								$17,900,000	--was 120,315 hrs, $10,885,792
Assumptions:
a. This ICR assumes a total of 39,812 commercial facilities exist in any given year, and that 1,618 new sources per year will be constructed. These commercial facilities comprise both the miscellaneous surface coating and commercial motor vehicle and mobile equipment refinishing categories. This ICR also assumes that existing sources will shut down at a rate equal to that replaced by new sources. Therefore, the total number of affected sources subject to this rule (i.e., 41,430 sources) will not change in any given year.
b. This ICR uses the following labor rates: $112.98 for technical, $149.35 for managerial, and $54.81 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Table 1b: Annual Respondent Burden and Cost – Government-owned Miscellaneous Surface Coating Operations at Area Sources
Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b
1. Applications	Not applicable
2. Surveys and studies	Not applicable
3. Reporting requirements
A. Familiarization with Regulatory Requirements	1	1	1	250	250	13	25	$31,482.13
B. Required activities	Not applicable
C. Create information
1. Initial notification letter	1	1	1	0	0	0	0	0
2. Notification of compliance status	2	1	2	0	0	0	0	0
3. Annual compliance report	2	1	2	250	500	25	50	$62,964.25
Reporting Subtotal					863			$94,446
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	Included in 3A
B. Plan activities	Not applicable
C. Implement activities	Not applicable
D. Develop record system	8	1	8	0	0	0	0	0
E. Time to record information
1. Records of painter certification	0.25	2.4	0.6	0	0	0	0	0
2. Records of filter efficiency	0.25	1	0.25	0	0	0	0	0
3. Records of spray gun	1.5	1	1.5	0	0	0	0	0
4. Records of deviation from rule requirements and corrective actions taken	1	1	1	12.5	12.5	0.63	1.25	$1,574.11
F. Time to train personnel	Not applicable
G. Time for audits	Not applicable
Recordkeeping Subtotal					14			$1,574
TOTAL ANNUAL BURDEN AND COST (ROUNDED)c					877			$96,000
TOTAL CAPITAL AND O&M COST (ROUNDED)c								$750
GRAND TOTAL (ROUNDED)c								$96,800
Assumptions:
a. EPA estimates a total of 250 existing, government-owned paint shops by assuming one shop per county for counties with a population greater than 240,000. This ICR assumes no new, government-owned paint shops will open over the three-year ICR period.
b. This ICR uses the following labor rates: $112.98 for technical, $149.35 for managerial, and $54.81 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Table 1c: Annual Respondent Burden and Cost – Paint Stripping Operations at Area Sources
Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b
1. Applications	Not applicable
2. Surveys and studies	Not applicable
3. Reporting requirements
A. Familiarization with Regulatory Requirements	1	1	1	1,050	1,050	53	105	$132,224.93
B. Process/Review information	2	0	0	0	0	0	0	0
C. Create information
1. Initial notification letter	1	0	0	0	0	0	0	0
2. Notification of compliance status	1	0	0	0	0	0	0	0
3. Annual compliance report	1	1	1	1,050	1,050	52.5	105	$132,224.93
Reporting Subtotal					2,415			$264,450
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	Included in 3A
B. Plan activities	8	0	0	0	0	0	0	0
C. Implement activities
1. Train personnel	8	0	0	0	0	0	0	0
2. Update plan	2	1	2	1,050	2,100	105	210	$264,449.85
D. Time to record information	1	0	0	1,050	0	0	0	0
Recordkeeping Subtotal					2,415			$264,450
TOTAL ANNUAL BURDEN AND COST (ROUNDED)c					4,830			$529,000
TOTAL CAPITAL AND O&M COST (ROUNDED)c								$3,150
GRAND TOTAL (ROUNDED)c								$532,000
Assumptions:
a. This ICR assumes a total of 3,000 paint stripping facilities exist in any given year. EPA estimates 1,050 of these facilities will use more than 150 gallons per year of paint strippers containing methylene chloride. These facilities are required to develop a written plan and to submit notification of compliance status and annual compliance reports.
b. This ICR uses the following labor rates: $112.98 for technical, $149.35 for managerial, and $54.81 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)
Burden Item	A	B	C	D	E	F	G	H		TECH	$48.08
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) a		MGMT	$64.80
Applications	Not applicable									CLER	$26.02
Required activities	Not applicable
Create information	Not applicable
Gather information	Not applicable
Report reviews	Not applicable
Initial notification letter	0.5	1	0.5	1,618	809	40.45	80.9	$43,622.90
Notification of compliance status	0.5	1	0.5	1,618	809	40.45	80.9	$43,622.90
Annual compliance report	0.5	1	0.5	37,862	18,931	946.55	1,893.1	$1,020,797.38
TOTAL ANNUAL BURDEN AND COST (ROUNDED)b					23,600			$1,110,000
Assumptions:
a. This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2013 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.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.