Burden Calculation Tables

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Overview

TBL1-YR1
TBL2-YR2
TBL3-YR3
TBL4-Summary
TBL5-YR1
TBL6-YR2
TBL7-YR3
TBL8-Summary
Capital O&M

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Sheet 1: TBL1-YR1

Table 1: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year 1
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person- hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Manager	$147.40
3. Reporting Requirements										Technical	$117.92
A. Familiarization with the regulatory requirements	4	1	4	43	172	8.6	17.2	$22,531		Clerical	$57.02
B. Required Activities
Add-on control performance test c	30	1	30	0	0	0	0	$0
Repeat add-on control performance test c	30	1	30	0	0	0	0	$0
Initial CMS performance evaluation d	10	1	10	0	0	0	0	$0
Create Information	See 4
Gather Existing Information	See 4
C. Write Reports
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of applicability of standard
i. Existing sources	2	0	0	0	0	0	0	$0
ii. New sources	2	1	2	0	0	0	0	$0
Emissions averaging plan e	40	1	40	0	0	0	0	$0
Pre-compliance report f	40	1	40	0	0	0	0	$0
Notification of performance test/re-test g	2	1	2	0	0	0	0	$0
Performance test/re-test report g	10	1	10	0	0	0	0	$0
Notification of initial CMS performance evaluation d	2	1	1	0	0	0	0	$0
Notification of compliance status g
i. With performance test	80	1	80	0	0	0	0	$0
ii. Without performance test	120	1	120	0	0	0	0	$0
Notification of process change h	8	1	8	0	0	0	0	$0
Semi-annual compliance report - no deviations i	4	2	8	0	0	0	0	$0
Semi-annual compliance report - with deviations i	12	2	24	0	0	0	0	$0
Startup, shutdown, and malfunction report j	8	1	8	0	0	0	0	$0
LDAR report k	125	2	250	0	0	0	0	$0
Emissions averaging report l	20	1	20	0	0	0	0	$0
Subtotal for Reporting Requirements					198			$22,531
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system m	40	1	40	0	0	0	0	$0
E. Develop startup, shutdown, malfunction plan n	100	1	100	0	0	0	0	$0
F. Develop QA/QC Plan for CMS o	40	1	40	0	0	0	0	$0
G. Time to enter information
i. Records of startup, shutdown, and malfunction	1.5	1	1.5	0	0	0	0	$0
ii. Records of CMS data
a. Record continuously monitored parameters	1	365	365	0	0	0	0	$0
b. Compile data	24	2	48	0	0	0	0	$0
c. Information for semi-annual reports	16	2	32	0	0	0	0	$0
d. LDAR recordkeeping	See 3C
iii. Records of operating hours and add-on control bypass hours per semiannual compliance period	0.5	2	1	23	23	1.15	2.3	$3,013
H. Calibration of CMS	376	1	376	0	0	0	0.0	$0
I. Time to train personnel p	40	1	40	0	0	0	0	$0
J. Refresher course q	16	1	16	0	0	0	0	$0
K. Time for audits	N/A				0	0	0	$0
L. Revise record systems due to SSM revisions r	8	1	8	43	344	17.2	34.4	$45,061.25
M. Become familiar with CEDRI for electronic filing of notifications and reports s	8	1	8	43	344	17.2	34.4	$45,061.25
Subtotal for Recordkeeping Requirements					818			$93,135
Total Labor Burden and Costs (rounded) t					1,000			$116,000
Total Capital and O&M Cost (rounded) t								$0
Grand Total (rounded) t								$116,000
Assumptions:
a. There are 43 existing major source facilities subject to the NESHAP. We assume no new sources will become subject during the three-year period of this ICR.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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. 23 facilities have add-on controls for compliance. The performance test will affect 12 facilities in the third year. These facilities do not already have a testing requirement in their permits.
d. Assumes 10 hours to conduct a CMS performance evaluation and 2 hours to prepare a notification.
e. Assumes that all existing facilities have complied with the emissions averaging requirements; new facilities are not allowed to use emissions averaging.
f. Assumes 50 percent of the new facilities will submit a pre-compliance report.
g. Assumes that the 12 facilities without periodic testing requirements in their permits will do performance testing in year 3. Assume a 5% failure and re-test rate (12 x 0.05 = 0.6). Assumes all other facilities will comply by submitting engineering calculations and design calculations.
h. Assumes 10 percent of the facilities will implement process changes.
i. Assumes 10 percent will have deviations.
j. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan.
k. Assumes all facilities will be subject to the equipment leak standards with an average of 125 hours per report.
l. Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply.
m. Assumes 40 hours to develop a record system for recording parameter monitoring information.
n. Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours.
o. Assumes 40 hours to develop/review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule.
p. Assumes no facilities will use the alternative standard, which requires CEMS and QA/QC plans.
q. Assumes 40 hours to train personnel and 16 hours for an annual refresher course.
r We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form.
s Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
t. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: TBL2-YR2

Table 2: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year 2
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person- hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Manager	$147.40
3. Reporting Requirements										Technical	$117.92
A. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0		Clerical	$57.02
B. Required Activities
Add-on control performance test c	30	1	30	0	0	0	0	$0
Repeat add-on control performance test c	30	1	30	0	0	0	0	$0
Initial CMS performance evaluation d	10	1	10	0	0	0	0	$0
Create Information	See 4
Gather Existing Information	See 4
C. Write Reports
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of applicability of standard
i. Existing sources	2	0	0	0	0	0	0	$0
ii. New sources	2	1	2	0	0	0	0	$0
Emissions averaging plan e	40	1	40	0	0	0	0	$0
Pre-compliance report f	40	1	40	0	0	0	0	$0
Notification of performance test/re-test g	2	1	2	0	0	0	0	$0
Performance test/re-test report g	10	1	10	0	0	0	0	$0
Notification of initial CMS performance evaluation d	2	1	1	0	0	0	0	$0
Notification of compliance status g
i. With performance test	80	1	80	0	0	0	0	$0
ii. Without performance test	120	1	120	0	0	0	0	$0
Notification of process change h	8	1	8	0	0	0	0	$0
Semi-annual compliance report - no deviations i	4	2	8	0	0	0	0	$0
Semi-annual compliance report - with deviations i	12	2	24	0	0	0	0	$0
Startup, shutdown, and malfunction report j	8	1	8	0	0	0	0	$0
LDAR report k	125	2	250	0	0	0	0	$0
Emissions averaging report l	20	1	20	0	0	0	0	$0
Subtotal for Reporting Requirements					0			$0
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system m	40	1	40	0	0	0	0	$0
E. Develop startup, shutdown, malfunction plan n	100	1	100	0	0	0	0	$0
F. Develop QA/QC Plan for CMS o	40	1	40	0	0	0	0	$0
G. Time to enter information
i. Records of startup, shutdown, and malfunction	1.5	1	1.5	0	0	0	0	$0
ii. Records of CMS data
a. Record continuously monitored parameters	1	365	365	0	0	0	0	$0
b. Compile data	24	2	48	0	0	0	0	$0
c. Information for semi-annual reports	16	2	32	0	0	0	0	$0
d. LDAR recordkeeping	See 3C
iii. Records of operating hours and bypass hours per semiannual compliance period	0.5	2	1	23	23	1.15	2.3	$3,013
H. Calibration of CMS	376	1	376	0	0	0	0.0	$0
I. Time to train personnel p	40	1	40	0	0	0	0	$0
J. Refresher course q	16	1	16	0	0	0	0	$0
K. Time for audits	N/A				0	0	0	$0
L. Revise record systems due to SSM revisions r	8	1	8	0	0	0	0	$0
M. Become familiar with CEDRI for electronic filing of notifications and reports s	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					26			$3,013
Total Labor Burden and Costs (rounded) t					0			$3,000
Total Capital and O&M Cost (rounded) t								$0
Grand Total (rounded) t								$3,000
Assumptions:
a. There are 43 existing major source facilities subject to the NESHAP. We assume no new sources will become subject during the three-year period of this ICR.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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. 23 facilities have add-on controls for compliance. The performance test will affect 12 facilities in the third year. These facilities do not already have a testing requirement in their permits.
d. Assumes 10 hours to conduct a CMS performance evaluation and 2 hours to prepare a notification.
e. Assumes that all existing facilities have complied with the emissions averaging requirements; new facilities are not allowed to use emissions averaging.
f. Assumes 50 percent of the new facilities will submit a pre-compliance report.
g. Assumes that the 12 facilities without periodic testing requirements in their permits will do performance testing in year 3. Assume a 5% failure and re-test rate (12 x 0.05 = 0.6). Assumes all other facilities will comply by submitting engineering calculations and design calculations.
h. Assumes 10 percent of the facilities will implement process changes.
i. Assumes 10 percent will have deviations.
j. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan.
k. Assumes all facilities will be subject to the equipment leak standards with an average of 125 hours per report.
l. Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply.
m. Assumes 40 hours to develop a record system for recording parameter monitoring information.
n. Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours.
o. Assumes 40 hours to develop/review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule.
p. Assumes no facilities will use the alternative standard, which requires CEMS and QA/QC plans.
q. Assumes 40 hours to train personnel and 16 hours for an annual refresher course.
r We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form.
s Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
t. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: TBL3-YR3

Table 3: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year 3
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person- hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Manager	$147.40
3. Reporting Requirements										Technical	$117.92
A. Familiarization with the regulatory requirements	4	1	4	0	0	0	0	$0		Clerical	$57.02
B. Required Activities
Add-on control performance test c	30	1	30	12	360	18	36	$47,157
Repeat add-on control performance test c	30	1	30	1	30	1.5	3	$3,930
Initial CMS performance evaluation d	10	1	10	0	0	0	0	$0
Create Information	See 4
Gather Existing Information	See 4
C. Write Reports
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of applicability of standard
i. Existing sources	2	0	0	0	0	0	0	$0
ii. New sources	2	1	2	0	0	0	0	$0
Emissions averaging plan e	40	1	40	0	0	0	0	$0
Pre-compliance report f	40	1	40	0	0	0	0	$0
Notification of performance test/re-test g	2	1	2	13	26	1.3	2.6	$3,406
Performance test/re-test report g	10	1	10	13	130	6.5	13	$17,029
Notification of initial CMS performance evaluation d	2	1	1	0	0	0	0	$0
Notification of compliance status g
i. With performance test	80	1	80	0	0	0	0	$0
ii. Without performance test	120	1	120	0	0	0	0	$0
Notification of process change h	8	1	8	0	0	0	0	$0
Semi-annual compliance report - no deviations i	4	2	8	0	0	0	0	$0
Semi-annual compliance report - with deviations i	12	2	24	0	0	0	0	$0
Startup, shutdown, and malfunction report j	8	1	8	0	0	0	0	$0
LDAR report k	125	2	250	0	0	0	0	$0
Emissions averaging report l	20	1	20	0	0	0	0	$0
Subtotal for Reporting Requirements					628			$71,522
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system m	40	1	40	0	0	0	0	$0
E. Develop startup, shutdown, malfunction plan n	100	1	100	0	0	0	0	$0
F. Develop QA/QC Plan for CMS o	40	1	40	0	0	0	0	$0
G. Time to enter information
i. Records of startup, shutdown, and malfunction	1.5	1	1.5	0	0	0	0	$0
ii. Records of CMS data
a. Record continuously monitored parameters	1	365	365	0	0	0	0	$0
b. Compile data	24	2	48	0	0	0	0	$0
c. Information for semi-annual reports	16	2	32	0	0	0	0	$0
d. LDAR recordkeeping	See 3C
iii. Records of operating hours and bypass hours per semiannual compliance period	0.5	2	1	23	23	1.15	2.3	$3,013
H. Calibration of CMS	376	1	376	0	0	0	0.0	$0
I. Time to train personnel p	40	1	40	0	0	0	0	$0
J. Refresher course q	16	1	16	0	0	0	0	$0
K. Time for audits	N/A				0	0	0	$0
L. Revise record systems due to SSM revisions r	8	1	8	0	0	0	0	$0
M. Become familiar with CEDRI for electronic filing of notifications and reports s	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					26			$3,013
Total Labor Burden and Costs (rounded) t					654			$75,000
Total Capital and O&M Cost (rounded) t								$247,000
Grand Total (rounded) t								$322,000
Assumptions:
a. There are 43 existing major source facilities subject to the NESHAP. We assume no new sources will become subject during the three-year period of this ICR.
b. This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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. 23 facilities have add-on controls for compliance. The performance test will affect 12 facilities in the third year. These facilities do not already have a testing requirement in their permits.
d. Assumes 10 hours to conduct a CMS performance evaluation and 2 hours to prepare a notification.
e. Assumes that all existing facilities have complied with the emissions averaging requirements; new facilities are not allowed to use emissions averaging.
f. Assumes 50 percent of the new facilities will submit a pre-compliance report.
g. Assumes that the 12 facilities without periodic testing requirements in their permits will do performance testing in year 3. Assume a 5% failure and re-test rate (12 x 0.05 = 0.6). Assumes all other facilities will comply by submitting engineering calculations and design calculations.
h. Assumes 10 percent of the facilities will implement process changes.
i. Assumes 10 percent will have deviations.
j. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan.
k. Assumes all facilities will be subject to the equipment leak standards with an average of 125 hours per report.
l. Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply.
m. Assumes 40 hours to develop a record system for recording parameter monitoring information.
n. Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours.
o. Assumes 40 hours to develop/review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule.
p. Assumes no facilities will use the alternative standard, which requires CEMS and QA/QC plans.
q. Assumes 40 hours to train personnel and 16 hours for an annual refresher course.
r We assume that costs associated with elimination of the SSM exemption include time for re-evaluating previously developed SSM record systems in year one. Costs are also associated with the use of electronic reporting and include time to become familiar with CEDRI and the semi-annual reporting form.
s Responses in year one associated with the use of electronic reporting include becoming familiar with CEDRI and the semi-annual reporting form.
t. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: TBL4-Summary

Table 4 - Summary of Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	883	44	88	1,015	$116,000	$0	$116,000
2	23	1	2	26	$3,000	$0	$3,000
3	569	28	57	654	$75,000	$247,000	$322,000
Total	1,475	74	148	1,696	$194,000	$247,000	$441,000
Average	492	25	49.2	565	$65,000	$82,000	$147,000
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	43	175	198	818	1,015	6.0	24
2	43	46	0	26	26	-	1
3	43	85	628	26	654	8	15
Total	-	306	826	871	1,696	-	39
Average	43	102	275	290	565	5.5	13.1
Average annual additional costs per respondent:				$3,420
Average annual additional hours per respondent:				13.1
Average annual additional hours per response:				5.5

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Sheet 5: TBL5-YR1

Table 5: Average Annual EPA Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year 1
Activity	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Year	(C) EPA Hours per Year (AxB)	(D) Plants per Year a	(E) Technical Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.10)	(H) Total cost per year, $ b
Notifications/Reports
A. Review Notification of Construction/Reconstruction	2	1	2	0	0	0	0	$0
B. Review Notification of Anticipated Startup	2	1	2	0	0	0	0	$0
C. Review Notification of Actual Startup	2	1	2	0	0	0	0	$0
D. Review Notification of Applicability of Standard	2	1	2	0	0	0	0	$0		Labor Rates
E. Review Notification of Performance Test	2	1	2	0	0	0	0	$0		Manager	$65.71
F. Review Performance Test Report c	8	1	8	0	0	0	0	$0		Technical	$48.75
G. Review Repeat Performance Test Report d	8	1	8	0	0	0	0	$0		Clerical	$26.38
H. Review Notification of Initial CMS Performance Evaluation e	2	1	2	0	0	0	0	$0
I. CMS Performance Evaluation e	4	1	4	0	0	0	0	$0
J. Review Emissions Averaging Plan f	12	1	12	0	0	0	0	$0
K. Review Pre-compliance Report g	2	1	2	0	0	0	0	$0
L. Review Notification of Compliance Status h
i. With performance test	4	1	4	0	0	0	0	$0
ii. Without performance test	4	1	4	0	0	0	0	$0
M. Review Notification of Process Change i	6	1	6	0	0	0	0	$0
N. Review Semiannual Compliance Report j
i. No deviations	2	1	2	0	0	0	0	$0
ii. Deviations	4	1	4	0	0	0	0	$0
O. Startup, shutdown, and malfunction report l	2	1	2	0	0	0	0	$0
R. LDAR report m	2	1	2	0	0	0	0	$0
S. Emissions averaging report f	4	1	4	0	0	0	0	$0
T. Review record systems due to SSM revisions n	2	2	4	43	172	8.6	17.2	$9,404
TOTAL (rounded) n					198			$9,400
Assumptions:
a. There are 43 existing major source facilities subject to the NESHAP. No new sources are expected to become subject over the three-year period of this ICR.
b. This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical and $26.38 for Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c. Assumes that the 12 facilities without periodic testing requirements in their permits will do performance testing in year 3. All facilities will comply by submitting engineering calculations based on: materials usage, materials HAP content, and control efficiency from testing (if applicable).
d. Assume a 5% failure and re-test rate (12 x 0.05 = 0.6, rounded up to 1).
e. Assumes no performance evaluations are required for the parameter monitoring systems included in the rule.
f. Assumes that all existing facilities have already submitted emissions averaging plans.
g. Assumes 50 percent of the new facilities will submit a pre-compliance report.
h. Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests.
i. Assumes 10 percent of the facilities will implement process changes.
j. Assumes 10 percent will have deviations.
l. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan.
m. Assumes all facilities will be subject to the equipment leak standards.
n. These are costs associated with evaluating new SSM record systems in year one.
n. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: TBL6-YR2

Table 6: Average Annual EPA Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year 2
Activity	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Year	(C) EPA Hours per Year (AxB)	(D) Plants per Year a	(E) Technical Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.10)	(H) Total cost per year, $ b
Notifications/Reports
A. Review Notification of Construction/Reconstruction	2	1	2	0	0	0	0	$0
B. Review Notification of Anticipated Startup	2	1	2	0	0	0	0	$0
C. Review Notification of Actual Startup	2	1	2	0	0	0	0	$0
D. Review Notification of Applicability of Standard	2	1	2	0	0	0	0	$0		Labor Rates
E. Review Notification of Performance Test	2	1	2	0	0	0	0	$0		Manager	$65.71	<- 12 in year 3
F. Review Performance Test Report c	8	1	8	0	0	0	0	$0		Technical	$48.75	<- 12 in year 3
G. Review Repeat Performance Test Report d	8	1	8	0	0	0	0	$0		Clerical	$26.38	<- 1 in year 3
H. Review Notification of Initial CMS Performance Evaluation e	2	1	2	0	0	0	0	$0
I. CMS Performance Evaluation e	4	1	4	0	0	0	0	$0
J. Review Emissions Averaging Plan f	12	1	12	0	0	0	0	$0
K. Review Pre-compliance Report g	2	1	2	0	0	0	0	$0
L. Review Notification of Compliance Status h
i. With performance test	4	1	4	0	0	0	0	$0
ii. Without performance test	4	1	4	0	0	0	0	$0
M. Review Notification of Process Change i	6	1	6	0	0	0	0	$0
N. Review Semiannual Compliance Report j
i. No deviations	2	1	2	0	0	0	0	$0
ii. Deviations	4	1	4	0	0	0	0	$0
O. Startup, shutdown, and malfunction report l	2	1	2	0	0	0	0	$0
R. LDAR report m	2	1	2	0	0	0	0	$0
S. Emissions averaging report f	4	1	4	0	0	0	0	$0
T. Review record systems due to SSM revisions n	2	2	4	0	0	0	0	$0
TOTAL (rounded) n					0			$0
Assumptions:
a. There are 43 existing major source facilities subject to the NESHAP. No new sources are expected to become subject over the three-year period of this ICR.
b. This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical and $26.38 for Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c. Assumes that the 12 facilities without periodic testing requirements in their permits will do performance testing in year 3. All facilities will comply by submitting engineering calculations based on: materials usage, materials HAP content, and control efficiency from testing (if applicable).
d. Assume a 5% failure and re-test rate (12 x 0.05 = 0.6, rounded up to 1).
e. Assumes no performance evaluations are required for the parameter monitoring systems included in the rule.
f. Assumes that all existing facilities have already submitted emissions averaging plans.
g. Assumes 50 percent of the new facilities will submit a pre-compliance report.
h. Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests.
i. Assumes 10 percent of the facilities will implement process changes.
j. Assumes 10 percent will have deviations.
l. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan.
m. Assumes all facilities will be subject to the equipment leak standards.
n. These are costs associated with evaluating new SSM record systems in year one.
n. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: TBL7-YR3

Table 7: Average Annual EPA Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year 3
Activity	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Year	(C) EPA Hours per Year (AxB)	(D) Plants per Year a	(E) Technical Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.10)	(H) Total cost per year, $ b
Notifications/Reports
A. Review Notification of Construction/Reconstruction	2	1	2	0	0	0	0	$0
B. Review Notification of Anticipated Startup	2	1	2	0	0	0	0	$0
C. Review Notification of Actual Startup	2	1	2	0	0	0	0	$0
D. Review Notification of Applicability of Standard	2	1	2	0	0	0	0	$0		Labor Rates
E. Review Notification of Performance Test	2	1	2	13	26	1.3	2.6	$1,422		Manager	$65.71
F. Review Performance Test Report c	8	1	8	12	96	4.8	9.6	$5,249		Technical	$48.75
G. Review Repeat Performance Test Report d	8	1	8	1	8	0.4	0.8	$437		Clerical	$26.38
H. Review Notification of Initial CMS Performance Evaluation e	2	1	2	0	0	0	0	$0
I. CMS Performance Evaluation e	4	1	4	0	0	0	0	$0
J. Review Emissions Averaging Plan f	12	1	12	0	0	0	0	$0
K. Review Pre-compliance Report g	2	1	2	0	0	0	0	$0
L. Review Notification of Compliance Status h
i. With performance test	4	1	4	0	0	0	0	$0
ii. Without performance test	4	1	4	0	0	0	0	$0
M. Review Notification of Process Change i	6	1	6	0	0	0	0	$0
N. Review Semiannual Compliance Report j
i. No deviations	2	1	2	0	0	0	0	$0
ii. Deviations	4	1	4	0	0	0	0	$0
O. Startup, shutdown, and malfunction report l	2	1	2	0	0	0	0	$0
R. LDAR report m	2	1	2	0	0	0	0	$0
S. Emissions averaging report f	4	1	4	0	0	0	0	$0
T. Review record systems due to SSM revisions n	2	2	4	0	0	0	0	$0
TOTAL (rounded) n					150			$7,100
Assumptions:
a. There are 43 existing major source facilities subject to the NESHAP. No new sources are expected to become subject over the three-year period of this ICR.
b. This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical and $26.38 for Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c. Assumes that the 12 facilities without periodic testing requirements in their permits will do performance testing in year 3. All facilities will comply by submitting engineering calculations based on: materials usage, materials HAP content, and control efficiency from testing (if applicable).
d. Assume a 5% failure and re-test rate (12 x 0.05 = 0.6, rounded up to 1).
e. Assumes no performance evaluations are required for the parameter monitoring systems included in the rule.
f. Assumes that all existing facilities have already submitted emissions averaging plans.
g. Assumes 50 percent of the new facilities will submit a pre-compliance report.
h. Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests.
i. Assumes 10 percent of the facilities will implement process changes.
j. Assumes 10 percent will have deviations.
l. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan.
m. Assumes all facilities will be subject to the equipment leak standards.
n. These are costs associated with evaluating new SSM record systems in year one.
n. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: TBL8-Summary

Table 8 - Summary of Annual Agency Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Amendments)
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	172	9	17	198	$9,400	$0	$9,400
2	0	0	0	0	$0	$0	$0
3	130	7	13	150	$7,100	$0	$7,100
Total	302	15.1	30.2	347	$16,500	$0	$16,500
Average	100.7	5.0	10.1	116	$5,500	$0	$5,500
Year	Number of Responses	Total Hours
1	86	198
2	0	0
3	26	150
Total	112	347
Average	37.3	116
Average annual hours per response:			3.1

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Sheet 9: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Performance Testing	Capital Startup Cost for One Performance Test	Number of Respondents Doing Testing	Total Capital/ Startup Cost (B x C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E x F)
Performance Testing	$19,000	12 + 1	$247,000	$0	0	$0
Totals (rounded)			$247,000			$0	Total	$247,000
Note: In year 3, twelve sources test one control device each at a cost of $19,000. One re-test is done at a cost of $19,000 each. Totals have been rounded to three significant figures.