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	96,000	452	5,520	102,000
	Labor Cost	$11,400,000	$53,600	$654,000	$12,100,000
	Capital and O&M Costs	$25,200	$150	$1,800	$27,100
	Grand Total	$11,400,000	$53,800	$656,000	$12,100,000
					2	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 Notification of Changes Report a	$3	1	166	$499
Subtotal				$549
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 Notification of Changes Report a	$3	1	7,146	$21,439
Subtotal				$24,625
Government Motor Vehicle and Mobile Equipment Refinishing
Annual Notification of Changes Report a	$3	1	50	$150
Subtotal				$150
Paint Stripping
Annual Notification of Changes Report a	$3	1	600	$1,800
Subtotal				$1,800
TOTALb				$27,100
a This ICR assumes that 20% of existing affected sources submit an annual notification of changes report each year. The remaining existing sources would only retain records.
b 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 Respondentsa
	Respondents That Submit Reports b		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents c	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	166	665	25	831	<--Note to EPA: We have adjusted all of these categories to assume 20% will submit an annual notification of changes report in each year.
2	25	166	665	25	831
3	25	166	665	25	831
Commercial Motor Vehicle and Mobile Equipment Refinishing
1	1,593	7,146	28,585	1,593	35,731
2	1,593	7,146	28,585	1,593	35,731
3	1,593	7,146	28,585	1,593	35,731
Government Motor Vehicle and Mobile Equipment Refinishing
1	0	50	200	0	250
2	0	50	200	0	250
3	0	50	200	0	250
Paint Stripping
1	0	600	2,400	0	3,000	<--Note to EPA: The prior ICR had this split as if 35% of stripping sources would submit reports, and 65% would not, but this was based on the assumption (see comment on p. 11 of SS) that stripping sources don't submit any reports unless they use >one ton of MeCl, which is not accurate. So it was treating it as if 35% of MeCl sources use >one ton, and all of those >one ton sources will submit a report every year, which is also inaccurate since they still only have to submit reports when there is a change. With this in mind, we adjusted this number to use the 20% assumption as well.
2	0	600	2,400	0	3,000
3	0	600	2,400	0	3,000
Average	1,618	7,962	31,850	1,618	39,812
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. 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.
b This ICR assumes that 20% of existing affected sources submit an annual notification of changes report each year. The remaining existing sources would only retain records.
c New respondents include sources with constructed, reconstructed and modified affected facilities.

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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 Notification of Changes Report a	166	1	665	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 Notification of Changes Report a	7,146	1	28,585	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 Notification of Changes Report a	50	1	200	250
Subtotal				250
Paint Stripping
Initial notification letter	0	1	0	0
Notification of compliance status	0	1	0	0
Annual Notification of Changes Report a	600	1	2,400	3,000
Subtotal				3,000
Total (after rounding)				43,000
a This ICR assumes that 20% of existing affected sources submit an annual notification of changes report each year. The remaining existing sources would only retain records.

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Sheet 5: Respondent Burden

Table 1a: Annual Respondent Burden and Cost – Commercial Miscellaneous Surface Coating Operations at Area Sources
Burden Item	A	B	C	D	E	F	G	H		TECH	$122.66
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b		MGMT	$149.84
1. Applications	Not applicable									CLER	$60.88
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	$1,102,181.60
Existing sources	1	1	1	36,562	36,562	1,828.1	3,656	$4,981,206.88
B. Required activities	Not applicable
C. Create information
1. Initial notification letter	1	1	1	1,618	1,618	80.9	161.8	$220,436.32
2. Notification of compliance status	2	1	2	1,618	3,236	161.8	323.6	$440,872.64
3. Annual Notification of Changes Report	2	1	2	7,312	14,625	731.2	1,462.5	$1,992,482.75
Reporting Subtotal					73,750			$8,737,180
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	$1,763,490.56
E. Time to record information
1. Records of painter certification c	0.25	2.4	0.6	7,312	4,387.4	219.37	438.74	$597,744.83																																																						Thanks, see updated footnotes.
2. Records of filter efficiency d	0.25	1	0.25	366	91.41	4.57	9.14	$12,453.02
3. Records of spray gun performance e	1.5	1	1.5	0	0	0	0	0
4. Records of deviation from rule requirements and corrective actions taken f	1	1	1	1,828	1,828	91.41	182.8	$249,060.34
F. Time to train personnel	Not applicable
G. Time for audits	Not applicable
Recordkeeping Subtotal					22,139			$2,622,749
TOTAL LABOR BURDEN AND COST (rounded) g					96,000			$11,400,000
TOTAL CAPITAL AND O&M COST (rounded) g								$25,200
GRAND TOTAL (rounded) g								$11,400,000
Assumptions:
a This ICR assumes a total of 36,562 commercial surface coating 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 will not change in any given year.
b This ICR uses the following labor rates: $122.66 for technical, $149.84 for managerial, and $60.88 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 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, for new sources, all painters need their records entered into the system.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
d Assumes 1% of affected sources will opt to test the filter effieciency of filters 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.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
e 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.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
f 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 36,652 sources that are required to be in compliance with the rule in any given year are expected to have some type of violation of the proposed work practices.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
g 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	$34,060.00
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 Notification of Changes Report	2	1	2	50	100	5	10	$13,624.00
Reporting Subtotal					403			$47,684
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 c	0.25	2.4	0.6	50	30.00	1.50	3.00	$4,087.20
2. Records of filter efficiency d	0.25	1	0.25	3	0.63	0.03	0.06	$85.15
3. Records of spray gun performance e	1.5	1	1.5	0	0	0	0	0
4. Records of deviation from rule requirements and corrective actions taken f	1	1	1	13	12.50	0.63	1.25	$1,703.00
F. Time to train personnel	Not applicable
G. Time for audits	Not applicable
Recordkeeping Subtotal					50			$5,875
TOTAL LABOR BURDEN AND COST (rounded) g					452			$53,600
TOTAL CAPITAL AND O&M COST (rounded) g								$150
GRAND TOTAL (rounded) g								$53,800
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: $122.66 for technical, $149.84 for managerial, and $60.88 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 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.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
d Assumes 1% of affected sources will opt to test the filter effieciency of filters 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.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
e 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.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
f 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 250 sources that are required to be in compliance with the rule in any given year are expected to have some type of violation of the proposed work practices.										<--Note to EPA: These assumptions are based on similar assumptions from final rule ICR.
g 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	3,000	3,000	150	300	$408,720.00
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 Notification of Changes Report	1	1	1	600	600	30.0	60	$81,744.00
Reporting Subtotal					4,140			$490,464
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	600	1,200	60	120	$163,488.00
D. Time to record information	1	0	0	600	0	0	0	0
Recordkeeping Subtotal					1,380			$163,488
TOTAL LABOR BURDEN AND COST (rounded)c					5,520			$654,000
TOTAL CAPITAL AND O&M COST (rounded)c								$1,800
GRAND TOTAL (rounded)c								$656,000
Assumptions:
a This ICR assumes a total of 3,000 paint stripping facilities exist in any given year. EPA estimates 600 of these facilities will need to submit an annual notification of changes report each year due to changes occurring after the most recent report or notification, such as changes to the MeCl minimization plan or adoption of a minimization plan due to use of more than one ton of MeCl in a calendar year.
b This ICR uses the following labor rates: $122.66 for technical, $149.84 for managerial, and $60.88 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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	$51.23
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) a		MGMT	$69.04
Applications	Not applicable									CLER	$27.73
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	$46,481.10
Notification of compliance status	0.5	1	0.5	1,618	809	40.45	80.9	$46,481.10
Annual Notification of Changes Report	0.5	1	0.5	7,962	3,981	199.06	398.1	$228,739.85
TOTAL ANNUAL BURDEN AND COST (ROUNDED)b					6,440			$322,000
Assumptions:
a. This ICR uses the following labor rates: $51.23 for technical, $69.04 for managerial, and $27.73 for clerical labor. 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.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.