Burden Calulation Tables

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Overview

Summary
Industry
Agency
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours per Response	1
Number of Respondents	219
Total Estimated Burden Hours	504
Total Estimated Costs	$134,000
Annualized Capital O&M	$0
Total Annual Responses	438
Form Number	Not Applicable

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Sheet 2: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and studies	N/A
3. Acquisition, installation, and utilization of technical systems	N/A
4. Reporting requirements
A. Familiarization with the regulatory requirement	2	1	2	22	44	2.2	4.4	$6,075.19
B. Required activities
Initial notificationc	1	1	1	0	0	0	0	$0
Notification of compliance statusc	1	1	1	0	0	0	0	$0
Annual compliance certificationd	1	1	1	22	22	1.10	2.2	$3,037.60
Report of exceedencesd	2	1	2	22	44	2.2	4.4	$6,075.19
C. Create information	See 4B
D. Gather existing information	See 4B									TECH	$123.94
E. Write report	See 4B									MNG	$157.61
Reporting subtotal					127			$15,187.98		CLER	$62.52
5. Recordkeeping requirements
A. Familiarization with the regulatory requirement	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information
Records of all information required by standards	0.25	1	0.25	219	54.8	2.74	5.48	$7,559.47
F. Time and cost to perform VE observatione	1	1	1	219	219	11.0	22	$103,602.88
G. Time to adjust existing ways to comply with previous applicable regulations	N/A
H. Time to transmit or disclose information	0.25	1	0.25	219	54.8	2.74	5.48	$7,559.47
I. Time for audits	N/A
Recordkeeping subtotal					378			$118,721.82
TOTAL ANNUAL BURDEN AND COSTS (rounded): f					504			$134,000			504
Capital and O&M Cost (see Section 6(b)(iii)):								$0
TOTAL COST: f								$134,000		1	hrs/response
Assumptions:
a We have assumed that there are 219 existing facilities that are subject to the rule, and that no new major sources per year will become subject over the 3 year-period of this ICR. We assume that 10 percent of facilities will be required to respond and will refamiliarize with the rule requirements each year.
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This burden item applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
d This report does not need to be submitted unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of facilities will experience deviations.
e Cost includes $335 per facility to certify technical person in VE (EPA Method 9) testing.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal)
										TECH	52.37
										MNG	70.56
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b		CLER	28.34
Report review
Initial notificationc	1	1	1	0	0	0	0	$0
Notification of compliance statusc	2	1	2	0	0	0	0	$0
Annual compliance certificationd	2	1	2	22	44	2.2	4.4	$2,584.21
Report of exceedanced	2	1	2	22	44	2.2	4.4	$2,584.21
TOTAL ANNUAL BURDEN e					101			$5,170
Assumptions:
a We have assumed that there are 219 existing facilities that are subject to the rule, and that no new major sources per year will become subject over the 3 year-period of this ICR. We assume that 10 percent of facilities will be required to respond.
b This ICR uses the following labor rates: $70.56 per hour for Managerial labor; $52.37 per hour for Technical labor, and $28.34 per hour for Clerical labor. These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees.
c This burden item applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
d This report does not need to be submitted unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of facilities will experience deviations.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents2	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	22	197	0	219
2	0	22	197	0	219
3	0	22	197	0	219
Average	0	22	197	0	219
1 New respondents include sources with constructed, reconstructed and modified affected facilities.
2 Existing respondents include sources required to submit a report of deviation; this applies to only 10% of sources.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Annual Compliance Certification Report	22	1	197	219
Report of Exceedances	22	1	197	219
			Total	438