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 2348.04, 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 were proposed on June 1, 2009, 

promulgated on December 3, 2009, and most recently-amended on June 3, 2010. The regulation 

was amended by revising the definition of Material containing HAP. 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 either use or have the potential to emit urban 

air toxics (i.e., benzene; methylene chloride; 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 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 standards require initial notification reports, 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 startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential 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 containing 

these documents, and retain the file for at least five years following the generation date of such 

maintenance reports, and records. 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 directly to the U.S.

Environmental Protection Agency (EPA) regional office.

The “Affected Public” are all private-sector, for-profit businesses. 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, 
2

Subpart CCCCCCC) (Renewal). The Federal Government’s “burden” is attributed entirely to 

work performed by either Federal employees or government contractors and may be found below 

in Table 2: Average Annual EPA Burden and Cost – NESHAP for Paints and Allied Products 

Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal). 

Over the next three years, approximately 2,190 respondents per year will be subject to 

these standards, and no additional respondents per year will become subject to these same

standards. This is based on the Agency’s estimates from a previous renewal. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance”. 

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 each 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. In addition, section 

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 Administrator may

reasonably require.

In the Administrator's judgment, urban air toxics emissions from paints and allied 

products manufacturing facilities either cause or contribute to air pollution that may reasonably

be anticipated to endanger public health and/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 were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
3

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standards. Continuous emission monitors are used to 

ensure compliance with these same standards at all times. During the performance test a record 

of the operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and that the standards are being 

met. The performance test may also be observed.

The required semiannual 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 directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly 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 copy of the report submitted to the state or local 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 renewal of this ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. 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 standards, is the Online Tracking Information System (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 compliance data. The growth rate for the industry is 
4

based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with these standard as they were being developed. In 

developing this ICR, we contacted both the National Paint and Coating Association, at (202) 

462-6272; and the Adhesive and Sealant Council, at (301) 986-9700.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal, as well as those comments submitted in response to the first Federal Register

notice. In this case, no comments were received.

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. If the information required by these standards was 

collected 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 by 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-year records retention requirement is consistent with the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish 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 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

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 policies 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 these standards do not include sensitive 
5

questions.

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 (SIC)

codes for the respondents affected by the standards and the corresponding North American 

Industry Classification System (NAICS) codes are listed in the table below:

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 by the NESHAP for Paints 

and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart 

CCCCCCC).

A source must make the following reports:

Notifications

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

Notifications

Notification of changes in information 63.9(j)

Reports

Reports of exceedances 63. 11603 (b)(3)

Initial/repeat performance tests 63.7(e)(1), 

63.6(h)(7)

Quality assurance test plan 63.7(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.

(ii) Respondent Activities

Respondent Activities
7

Respondent Activities

Familiarization with the regulatory requirements.

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 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems 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.

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, analysis, 

storage, and distribution of the required information:

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 
8

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard, and note the operating conditions under which compliance was achieved.

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five

years.

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 technical 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. 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 is 

shown 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).

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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept 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 to respond to, a 
9

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 requirements is estimated to be 5,040 hours (Total Labor Hours from Table 1

below). 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 previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. There are no capital/startup or operation and 

maintenance costs.

(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 are labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis 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 

$45,800.
10

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 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. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Paints 

and Allied Products Manufacturing Area Source Category (40 CFR Part 63, Subpart CCCCCCC) 

(Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

2,190 existing respondents will be subject to these standards. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 2,190 per year. Of all respondents, only 10 percent are expected to submit a 

report. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR:

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(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 respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 2,190. 
11

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Annual Compliance Certification 

Report

219 1 1,971 2,190

Report of Exceedances 219 1 1,971 2,190

Total 4,380

The number of Total Annual Responses is 4,380.

The total annual labor costs are $1,240,000 (rounded). 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) 

(Renewal).

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, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 5,040 hours. 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) 

(Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 1 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. The cost 
12

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 

1,010 labor hours at a cost of $45,800. See below in Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Paints and Allied Products Manufacturing Area Source Category (40 CFR 

Part 63, Subpart CCCCCCC) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is a small adjustment increase in the estimated respondent labor hours in this ICR 

from the most recently-approved ICR. This is due to a change in our estimation assumption, and 

not associated with any program changes. In this ICR, we assume existing sources will have to 

re-familiarize themselves with the regulatory requirements each year, which results in an 

increase in burden. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 1 hours per response. “Burden” means the total time, effort, or financial 

resources expended by 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 technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply 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 information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2012-0527. 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 
13

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, 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), WJC 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information 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) 

Hours 

per 

occurrence

(B) 

No. of 

occurrences

per 

respondent

per year

(C) 

Hours

per 

respondent

per year 

(A x B)

(D) 

Respondent

per year a

(E) 

Technical 

hours per 

year 

(C x D)

(F) 

Management 

hours per 

year 

(E x 0.05)

(G) 

Clerical 

hours per 

year 

(E x 0.1)

(H) 

Total costs 

per year ($)b

1. Applications N/A

2. Survey and studies N/A

3. Acquisition, installation, and utilization 

of technical systems N/A

4. Reporting requirements

A. Familiarize with the regulatory 

requirement 2 1 2 219 438 21.9 43.8 $50,652.73

B. Required activities

Initial notification c1 1 1 0 0 0 0 $0

Notification of compliance status c1 1 1 0 0 0 0 $0

Annual compliance certification d1 1 1 219 219 10.95 21.9 $25,326.36

Report of exceedences d2 1 2 219 438 21.9 43.8 $50,652.73

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

Reporting subtotal 1,259 $126,631.82

5. Recordkeeping requirements

A. Familiarize with the regulatory 

requirement See 4A

B. Plan activities See 5E
15

Burden Item

(A) 

Hours 

per 

occurrence

(B) 

No. of 

occurrences

per 

respondent

per year

(C) 

Hours

per 

respondent

per year 

(A x B)

(D) 

Respondent

per year a

(E) 

Technical 

hours per 

year 

(C x D)

(F) 

Management 

hours per 

year 

(E x 0.05)

(G) 

Clerical 

hours per 

year 

(E x 0.1)

(H) 

Total costs 

per year ($)b

C. Implement activities See 5E

D. Develop record system See 5E

E. Time to enter information

Records of all information 

required by standards 0.25 1 0.25 2,190 547.5 27.38 54.75 $63,315.91

F. Time and cost to perform VE 

observation 1 1 1 2,190 2,190 109.5 219 $986,913.65

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 $63,315.91

I. Time for audits N/A

Recordkeeping subtotal 3,778 $1,113,545.47

TOTAL ANNUAL BURDEN AND 

COSTS (rounded): f5,040 $1,240,000

Capital and O&M Cost (see Section 

6(b)(iii)): $0 

TOTAL COST: f

$1,240,000 

Assumptions:

a We have assumed that there are 2,190 existing facilities that are subject to the rule, and that no new major sources per year will become subject over the 3 year-
16

period of this ICR.

b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). These 

rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “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. This ICR assumes 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 new facilities are expected over the three-year period of this ICR.

d This report does not need to be submitted unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of the foundries will 

experience deviations.

e Cost includes $335 per facility to certify technical person in VE (EPA Method 9) testing.

f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Paints and Allied Products Manufacturing Area Source 

Category (40 CFR Part 63, Subpart CCCCCCC) (Renewal)

Burden Item

(A) 

EPA Hours 

per 

Occurrence

(B) 

No. of 

occurrences

per plant

per year

(C) 

EPA hours

per plant

per year 

(A x B)

(D) 

Plants

per 

year a

(E) 

EPA

technical 

hours

per year 

(C x D)

(F) 

EPA

managerial 

hours

per year (E x 

0.05)

(G) 

EPA

clerical 

hours

per year 

(E x 0.1)

(H) 

Total cost

per year b

($)

Report review

Initial notification c1 1 1 0 0 0 0 $0

Notification of compliance status c2 1 2 0 0 0 0 $0

Annual compliance certification d2 1 2 219 438 21.9 43.8 $22,924.92

Report of exceedance d2 1 2 219 438 21.9 43.8 $22,924.92

TOTAL ANNUAL BURDEN e1,010 $45,800

Assumptions:

a We have assumed that there are 2,190 existing facilities that are subject to the rule, and that no new major sources per year will become subject over the 3 yearperiod of this ICR.

b This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 

60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 

percent of Technical hours. These rates are from the OPM, 2015 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 new facilities are expected over the three-year period of this ICR.

d This report does not need to be submitted unless a deviation from the requirements of this subpart has occurred. We estimate that 10 percent of the foundries will 

experience deviations.

e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.