**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC)**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63 , Subpart CCCCCCC ) (Renewal), EPA ICR Number 2348.03, OMB Control Number 2060

- 0633. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paints and Allied Products Manufacturing Area Source Category ( 40 CFR part 63, subpart CCCCCCC ) were proposed on June 1, 2009 , and promulgated on December 3, 2009 . These regulations apply to existing or new paints and allied products manufacturing facilities that are an area source of hazardous air pollutants (HAP) emissions and that use or have the potential to emit urban air toxics (i.e., benzene ; methylene chlo ride ; and cadmium, chromium, lead , and nickel compounds)

. These paints and allied products manufacturing sector includes any facility primarily engaged in the production of paints, inks, adhesives, stains, varnishes, shellacs, putties, sealers, caulks, and other coatings which are intended to leave a dried film of solid material on a substrate. The affected sources consist of paint and coating manufacturing, adhesive manufacturing, printing ink manufacturing, and miscellaneous chemical product and preparation manufacturing (writing and stamp inks) facilities

. New facilities include those that commenced construction, modificati on, or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63 , subpart CCCCCCC

. In general, all NESHAP s tandards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any st artup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are ess ential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and re cords. All reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U.S. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 2,190 respondents per ye ar will be subject to the standard s , and no additional respondents per year will become subject to the standard s
. The Office of Management and Budget ( OMB ) approved the currentl y active I CR2

without any “ Terms of Cle arance. ” The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal). The burden to the “Federal Government” burden is attributed entirely to work performed by either other F ederal employees or government contractor s and refer s below to Table 2: Average Annual EPA Burden and Cost

– NESHAP for Paints and Allied Products Manufacturing Area Sour ce Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/** **Authority for the Collection** The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for eac h category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, sectio n 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y r equire. In the Administrator's judgment, urban air toxics emissions from paints and allied products manufacturing facilitie s cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category

at 40 CFR part 63, subpart CCCCCCC

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affect ed facility ’ s initial3

capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. The notifications required in the standard are used to i nform the Agency or delegated authority when a sourc e becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated and the standard are being met. The performance test may also be observed. The required annual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations**  **, and Other Collection Criteria** The requested recordkeeping and reporting are required under 40 CFR part 63 , subpart CCCCCCC

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EP A regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or loc al agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the ren ewal of this I CR was published in the Federal Register ( 77 FR 47631 ) on August 9, 2012. No comments were received on the burden published in the Federal Register

. **3(c) Consultations**  The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem ( OTIS ), which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all c ompliance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply

. In developing this I CR, the4

EPA contacted : 1) the National Paint and Coating Association , at (863)

- 534

- 7160 ; and 2) the Adhesive and Sealant Council , at (202) 256

- 9986. It is our policy

to respond after a thorough review of comments received since the l ast ICR renewal as well as those submitted in response to the first Federal Register notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards was collec ted less frequently , the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for fiveyears allows EPA to establ ish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prev ented from pursuing the violators due to the destruction of nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency polici es set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
The reporting or recordkeeping requirements in the standard do not include sensitive questions.5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are paints and allied products manufacturing facilities . The United States Standard Industrial Classification ( SI C ) code s and associated North American Industry Classification Sy stem (NAICS) codes for the respondents affected b y the standards are listed in the following table.

**Standard ( 40 CFR Part 63, Subpart**  **CCCCCCC )**  **SIC Codes NAICS Codes**  Paint and Coating Manufacturing 2851 , 2899 325510 Adhesive Manufacturing 2891 325520 Printing Ink Manufacturing 2893 325910 Miscellaneous Chemical Product and Preparation Manufacturing

– Writing and Stamp Inks 2819 , 2899 , 3952 , 3999 325998
**4(b) Information Requested**  **(i) Data Items**
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR P art 63, S ubpart CCCCCCC). A source must make the following reports:

**Notification s**  Notification of applicability 63.11603(a)(1) , 63.9(a)(2) Notification of construction/reconstruction 63.9(b)(5) Notification of special compliance requirements 63.9(d) Notification of performance test 63.9(e) Notification of opacity/VE observations 63.9( f) Additional CMS notifications 63.9( g) Notification of compliance status 63. 11603(a)(2) , 63.9(h)6
**Notification s**  Notification of changes in information 63.9( j)

**Reports** Reports of exceed ances 63. 11603 (b )( 3 ) Initial/repeat performance tests 63.7(e)(1) , 63.6(h)(7) Quality assurance test plan 6 3.7(c) CMS performance evaluation/report 63.8(e)(5) SSM reports 63.6(e)(3) Excess emissions reports 63.10(e)(3) Annual compliance certifications 63. 11603 (b) Performance test plan 63.7(c)(2) CMS quality

control plan 63.8(d) CMS performance evaluation test plan 63.8(e)(3) A source must keep the following records: **Recordkeeping** Records of notifications 63. 11603 (c)(1), 63.10 Records that demonstrate continuous compliance 63. 11603 (c)(2), 63.10 Monitoring/inspection information 63. 11603 (c)(3), 63.10 Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies , in cooperation with the respondents, continue to create reporting s ys tems to transmit dat a electronicall y. However, electronic reporting s ys tems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.7 **(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate particulate matter control device. Perform initial performance test and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information.8 **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y install ed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The annual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained i n the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agenci es, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility**  All existing respondents subject to this standard are small entities (i.e., small businesses)

. However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to techn ical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. Our anal ys is indicates that the standard would not impose a significant adverse impact on any entities, large or small, since the average burden costs are less than 0.3 p ercent of revenue. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is9

shown in Table 1 below : Annual Respondent Burden and Cost

– NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the con cept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required t o respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 4,53 3 hours ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approved IC R, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the sub

ject standard are labor costs. There are no capital/startup or operation and maintenance costs.10 **(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**  The only type of industry costs associated with the information collection activity in the regulations is labor costs. There are no capital/startup or operation a nd maintenance costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 45,398

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 2012 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appe ar below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Paints and Allied Produ cts Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 2,190 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below , is 2,190 per year. The number of respondents is c alculated using the following table that addresses the three ye ars covered b y this ICR.11 **Number of Respondents**

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents 1 (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 219 1,971 0 2,190
2 0 219 1,971 0 2,190
3 0 219 1,971 0 2,190 Average 2,190 1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard , existing respondent s do not submit annual compliance certification and exceedance reports unless a deviation from the requirements of this s ubpart has occurred. We estimate that 10 percent of facilities will experience deviations. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 2,190

. The total number of annual responses per ye ar is calculated using the following table:
**Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses 1 (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Annual Compliance Certification Report 2 19 1 1,971 2,190
Report of Exceedances 219 1 1,971 2,190 Total 4,380 1 In this standard , existing respondents do not submit annual compliance certification and exceedance reports unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of facilities will experience deviations. The number of Total Annual Re sponses is 4,380. Th e total annual labor costs are $ 1,172,604

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Ren ewal)

.12

**6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y , and summarized below. **(i) Respondent Tally** The total annual labor hours are 4,53 3 hours at the cost of $1,172,604

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR P art 63, Subpart CCCCCCC) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour per response

. There are no capital/startup or O&M costs to the regulated entities

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

**(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 1,007 labor hours at a cost of $45,398 . See Table 2 below : Average Annual EPA Burden and Cost

– NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal). **6(f) Reasons for Change in Burden** There is an adjustment increase in the total estimated burden costs for the respondents as currently

identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. The increase reflects an adjustment in labor rates. This I CR uses updated labo r rates from the Bureau of Labor Statistics to calculate all labor costs. However, there is an adjustment decrease in the total burden hours and Agency costs from the previous ICR. The change in the burden and cost estimates occurred because the standard has been in effect for more than three ye ars and the requirements are different during initial compliance (new facilities) as compared to on

- going compliance (existing facilities). The previous ICR reflected those burdens and costs associated with the initial activities for subject facilities. This includes conducting performance tests , notifying initial compliance status, and establishing recordkeeping s ys tems. This I CR, by in large, reflects only

the on

- going burden and costs for existing facilitie s. Activities for existing sources include continuously monitoring of pollutants and the submission of annual reports. Specifically , this ICR includes the burdens associated with annual compliance certification and exceedance reports

. R espondents must submit these reports to the Agency onl y if a deviation from the requirements of this subpart has occurred

. This I CR assumes ten percent of respondents will submit these reports annuall y for Agency review. These changes result in a net decrease in the respondent13

and Agency

burden hours, as well as a decrease in Agency labor costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour per response. Burden means the t otal time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize techno logy and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this informatio n, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has e stablished a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 052 7. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, an d to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a. m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1752

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2012

- 0527 and OMB Control Number 2060

- 0633 in any correspondence.
**Part B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.14

**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**  **B C**  **D E**  **F G**  **H**

**Hours per**  **occurrence No. of** 

**occurrences per**  **respondent per year**  **Hours**

**per respondent**  **per year Respondents** 

**per year a**  **Technical**

**hours per year**  **Management**

**hours per year**  **Clerical**

**hours per year**  **Total costs**

**per year ($)**  **b (C = A x B)**  **(E = C x D) (F = E x**  **0.05) (G = E x** 

**0.10)** 1. Applications N/A 2. Survey and studies N/A 3. Acquisition, installation, and utilization of technical systems N/A 4. Reporting requirements A. Read instructions c 2 1 2 0 0 0 0 $ 0 B. Required activities Initial notification 1 1 1 0 0 0 0 $ 0 Notification of compliance status c 1 1 1 0 0 0 0 $ 0 Annual compliance certification d 1 1 1 219 219 10.95 21.9 $ 24,386.31 Report of exceedances d 2 1 2 219 438 21.9 43.8 $ 48,772.61 C. Create information See 4B D. Gather existing information See 4B E. Write report See 4B **Subtotal for Reporting**  **Requirements 75**  **5.55** 5. Recordkeeping requirements A. Read instructions See 4A B. Plan activities See 5E C. Implement activities See 5E15

**Burden Item A**  **B C**  **D E**  **F G**  **H**

**Hours per**  **occurrence No. of** 

**occurrences per**  **respondent per year**  **Hours**

**per respondent**  **per year Respondents** 

**per year a**  **Technical**

**hours per year**  **Management**

**hours per year**  **Clerical**

**hours per year**  **Total costs**

**per year ($)**  **b (C = A x B)**  **(E = C x D) (F = E x**  **0.05) (G = E x** 

**0.10)** D. Develop record system See 5E E. Time to enter information Records of all information required by standards 0.25 1 0.25 2,190 547.5 27.38 54.75 $ 60,965.77 F. Time to perform VE observation 1 1 1 2,190 2,190 109.5 219 $ 977,513.07 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 2,190 547.5 27.38 54.75 $ 60,965.77 I. Time for audits N/A **Subtotal for Recordkeeping**  **Requirements 3,77**  **7.76 TOTAL ANNUAL BURDEN (rounded)**  **4,53 3**  **$1,172,604**
**Assu mptions:** 
a. We have assumed that there are 2,190 existing facilities that are subject to the rule, and that no ne w major sources per year will become subject over the 3 year

period of this ICR. b. This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $121.44 ($57.83+ 110%); and Clerical $ 50.51 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Tabl e 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. This ICR ass umes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c. This burden item applies to new facilities only. No ne w 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.16

**Table 2: Average Annual EPA Burden and Cos**  **t**

**– NESHAP for Paints and Allied Products**  **Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC)**  **(Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H**

**EPA Hours per**  **occurrence No. of** 

**occurrences per plant**  **per year EPA hours** 

**per plant per year**  **Plants**

**per year a**  **EPA**

**technical hours**  **per year EPA** 

**managerial hours**  **per year EPA** 

**clerical hours per year**  **Total cost**

**per year b**  **($) (C = A x B)**  **(E = C x D) (F = E x 0.05)**  **(G = E x 0.10)**  Report review Initial notification c 1 1 1 0 0 0 0 $ 0 Notification of compliance status c 2 1 2 0 0 0 0 $ 0 Annual compliance certification d 2 1 2 219 438 21.9 43.8 $ 22,699.13 Report of exceedance d 2 1 2 219 438 21.9 43.8 $ 22,699.13 **TOTAL ANNUAL BURDEN (rounded)**  **1,007 $45,398** 

a. We have assumed that there are 2,190 existing facilities that are subject to the rule, and that no ne w major sources per year will become subject over the 3 year

period of this ICR. b. This cost is based on the average hourly labor rate as follow s: Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%); Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Te chnical hours. These rates are from the OPM, 2012 General Schedule, which excludes locality , rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c. This burden item applies to new facilities only. No ne w 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.