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

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 2060-0607 can be found here:

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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

(A)

(B)

(C)

(D)

(E)

(F)

(G)

Respondent

Non-Labor

Number of

Hours

Number of

Technical

Management

Clerical

Total

Footnotes

Hours Per

Costs

Occurrences

Per

Respondents

Hours

Labor Costs

Non-Labor

Occurrence

Per

Respondent

Per Year (a)

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)

Applications

Not applicable

#VALUE!

Surveys and Studies

Not applicable

#VALUE!

Reporting Requirements

Read and Understand Rule Requirements

35,731

178,655

8,933

17,866

$8,928,641

B. Required Activities

not applicable

Create Information

1) Initial Notification Letter

35,731

35,731.00

1,786.55

3,573.10

$1,785,728

$35,731

c, d

Notification of Compliance Status

3,236

6,472.00

323.60

647.20

$323,451

$3,236

c, e

3) Annual compliance report

0.00

Recordkeeping Requirements

Read Instructions

Included in 3.A

#VALUE!

Plan Activities

not applicable

#VALUE!

Implement Activities

not applicable

#VALUE!

Develop Record System

35,731

285,848

14,292

28,585

$14,285,825

c, g

Record information

1) Records of painter certification

0.25

2.4

0.6

35,731

Not Applicable

21,439

2) Records of filter efficiency

0.25

8.09

0.40

0.81

$404

3) Records of spray gun

1.5

0.00

4) Records of deviation from the rule requirements and corrective actions taken

162

161.80

8.09

16.18

$8,086

Personnel Training

Not applicable

Time for audits

Not applicable

TOTAL:

#VALUE!

$38,967

Total Hours

Labor

Non-Labor

Total

Summary of Respondent Burden

#VALUE!

$38,967

#VALUE!

Annualized Capital and Startup

O & M Summary

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.

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.

One-time only costs.

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.

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.

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.

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.

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.

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.

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.

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

(A)

(B)

(C)

(D)

(E)

(F)

(G)

Respondent

Non-Labor

Number of

Hours

Number of

Technical

Management

Clerical

Total

Footnotes

Hours Per

Costs

Occurrences

Per

Respondents

Hours

Labor Costs

Non-Labor

Occurrence

Per

Respondent

Per Year (a)

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)

Applications

Not applicable

#VALUE!

Surveys and Studies

Not applicable

#VALUE!

Reporting Requirements

Read and Understand Rule Requirements

1,618

8,090

405

809

$404,314

B. Required Activities

not applicable

Create Information

1) Initial Notification Letter

1,618

1,618.00

80.90

161.80

$80,863

$1,618

c, d

Notification of Compliance Status

1,618

3,236.00

161.80

323.60

$161,726

$1,618

c, e

3) Annual compliance report

3,236

6,472.00

323.60

647.20

$323,451

$9,708

Recordkeeping Requirements

Read Instructions

Included in 3.A

#VALUE!

Plan Activities

not applicable

#VALUE!

Implement Activities

not applicable

#VALUE!

Develop Record System

1,618

12,944

647

1,294

$646,902

c, g

Record information

1) Records of painter certification

0.25

2.4

0.6

7,156

Not Applicable

4,294

2) Records of filter efficiency

0.25

12.14

0.61

1.21

$606

3) Records of spray gun

1.5

0.00

4) Records of deviation from the rule requirements and corrective actions taken

243

242.70

12.14

24.27

$12,129

Personnel Training

Not applicable

Time for audits

Not applicable

TOTAL:

#VALUE!

$12,944

Total Hours

Labor

Non-Labor

Total

Summary of Respondent Burden

#VALUE!

$12,944

#VALUE!

Annualized Capital and Startup

O & M Summary

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.

One-time only costs.

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.

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.

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.

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

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.

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 Type	application/vnd.ms-excel
Author	Eeastern Reseach Group, Inc.
Last Modified By	ckerwin
File Modified	2007-09-14
File Created	1998-09-17