Burden Tables

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Overview

Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
3-Year Summary
Capital O&M
Responses
Respondents

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost (Year 1) – National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$130.58
3. Reporting requirements										Technical	$80.22
A. Familiarization with rule requirements										Clerical	$50.30
New sources	4	1	4	1	4	0.2	0.4	$367.12
Existing sources c	1	1	1	46	46	2.3	4.6	$4,221.83
B. Write Report
Initial notification d	25	1	25	1	25	1	3	$2,294.48
Change of Information in Notificatione	4	1	4	15.7	62.7	3.13	6.27	$5,751.48
Temporary Variance/Compliance Extension Applicationf	24	1	24	0.1	2.4	0.12	0.24	$220.27
Respond to the written notification from EPA request for data g	60	1	60	10	600	30	60	$55,067.40
Small Quantity Manufacturer Exemption Claim Notification	2	1	2	2	4	0.2	0.4	$367.12
Exemption Annual Report	8	1	8	2	16	0.8	1.6	$1,468.46
Notice of Certifying Entity to Maintain Records	4	1	4	3	12	0.6	1.2	$1,101.35
Notice Rescinding Certification	1	1	1	1	1	0.05	0.1	$91.78
Triennial Reports	5	1	5	0	$0	$0	$0	$0
C. Establish CEDRI accounth	2	1	2	47	94	5	9	$8,627.23
D. Submit reports in CEDRIh	2	1	2	0	0	$0	$0	$0
Subtotal for Reporting Requirements						997			$79,579
4. Recordkeeping requirements
A. Familiarization with rule requirements
B. Plan activities
C. Maintanence of records of batch information & calculations	120	1	120	47	5,640	282	564	$517,633.56
D. Triennial Report	100	1	100	0	0	0	0	$0
Subtotal for Recordkeeping Requirements						6,486			$517,634
Total Labor Burden and Costs (rounded) i					7,480			$597,000
Total Capital and O&M Cost (rounded) i								$0
GRAND TOTAL (rounded) i								$597,000
Assumptions:
a We have assumed 46 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $130.58 (managerial), $80.22 (technical), and $50.30 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2023 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8091 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that each existing source will re-familiarize with the requirements each year.
d New sources file initial reports in their first year.
e We assume that approximately one-third of respondents will have one incident per year that will require a change of information report).
f We assume that 1.0 percent of new respondents will request a variance or extension on their compliance application.
g We assume that 1.0 percent of new and existing sources per year will be required to respond to enforcement questions or other agency requests for information.
h The includes the burden to establish an account and submit triennial reports in CEDRI for the first time and is a one-time activity for existing respondents following promulgation of the rule, and applies to 1 new respondent each year. The burden to submit reports is otherwise included in the burden under 3B.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Annual Respondent Burden and Cost (Year 2) – National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$130.58
3. Reporting requirements										Technical	$80.22
A. Familiarization with rule requirements										Clerical	$50.30
New sources	4	1	4	1	4	0.2	0.4	$367.12
Existing sources c	1	1	1	47	47	2.4	4.7	$4,313.61
B. Write Report
Initial notification d	25	1	25	1	25	1	3	$2,294.48
Change of Information in Notificatione	4	1	4	15.7	62.7	3.13	6.27	$5,751.48
Temporary Variance/Compliance Extension Applicationf	24	1	24	0.1	2.4	0.12	0.24	$220.27
Respond to the written notification from EPA request for data g	60	1	60	10	600	30	60	$55,067.40
Small Quantity Manufacturer Exemption Claim Notification	2	1	2	2	4	0.2	0.4	$367.12
Exemption Annual Report	8	1	8	2	16	0.8	1.6	$1,468.46
Notice of Certifying Entity to Maintain Records	4	1	4	3	12	0.6	1.2	$1,101.35
Notice Rescinding Certification	1	1	1	1	1	0.05	0.1	$91.78
Triennial Reports	5	1	5	0	0	0.0	0.0	$0
C. Establish CEDRI accounth	2	1	2	1	2	0.1	0.2	$184
D. Submit reports in CEDRIh	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements						892			$71,227
4. Recordkeeping requirements
A. Familiarization with rule requirements
B. Plan activities
C. Maintanence of records of batch information & calculations	120	1	120	48	5,760	288	576	$528,647.04
E. Triennial Report	100	1	100	0	0	0	0	$0
Subtotal for Recordkeeping Requirements						6,624			$528,647
Total Labor Burden and Costs (rounded) i					7,520			$600,000
Total Capital and O&M Cost (rounded) i								$0
GRAND TOTAL (rounded) i								$600,000
Assumptions:
a We have assumed 46 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $130.58 (managerial), $80.22 (technical), and $50.30 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2023 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8091 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that each existing source will re-familiarize with the requirements each year.
d New sources file initial reports in their first year.
e We assume that approximately one-third of respondents will have one incident per year that will require a change of information report).
f We assume that 1.0 percent of new respondents will request a variance or extension on their compliance application.
g We assume that 1.0 percent of new and existing sources per year will be required to respond to enforcement questions or other agency requests for information.
h The includes the burden to establish an account and submit triennial reports in CEDRI for the first time and is a one-time activity following promulgation of the rule. The burden to submit reports is otherwise included in the burden under 3B.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 3

Table 3: Annual Respondent Burden and Cost (Year 3) – National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$130.58
3. Reporting requirements										Technical	$80.22
A. Familiarization with rule requirements										Clerical	$50.30
New sources	4	1	4	1	4	0.2	0.4	$367.12
Existing sources c	1	1	1	48	48	2.4	4.8	$4,405.39
B. Write Report
Initial notification d	25	1	25	1	25	1	3	$2,294.48
Change of Information in Notificatione	4	1	4	15.7	62.7	3.13	6.27	$5,751.48
Temporary Variance/Compliance Extension Applicationf	24	1	24	0.1	2.4	0.12	0.24	$220.27
Respond to the written notification from EPA request for data g	60	1	60	10	600	30	60	$55,067.40
Small Quantity Manufacturer Exemption Claim Notification	2	1	2	2	4	0.2	0.4	$367.12
Exemption Annual Report	8	1	8	2	16	0.8	1.6	$1,468.46
Notice of Certifying Entity to Maintain Records	4	1	4	3	12	0.6	1.2	$1,101.35
Notice Rescinding Certification	1	1	1	1	1	0.05	0.1	$91.78
Triennial Reports	5	1	5	49	245	12.25	24.5	$22,485.86
C. Establish CEDRI accounth	2	1	2	1	2	0.1	0.2	$184
D. Submit reports in CEDRIh	2	1	2	49	98	4.90	9.80	$8,994.34
Subtotal for Reporting Requirements						1,288			$102,799
4. Recordkeeping requirements
A. Familiarization with rule requirements
B. Plan activities
C. Maintanence of records of batch information & calculations	120	1	120	49	5,880	294	588	$539,660.52
D. Triennial Report	100	1	100	49	4,900	245	490	$449,717.10
Subtotal for Recordkeeping Requirements						12,397			$989,378
Total Labor Burden and Costs (rounded) i					13,700			$1,092,000
Total Capital and O&M Cost (rounded) i								$0
GRAND TOTAL (rounded) i								$1,092,000
Assumptions:
a We have assumed 46 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $130.58 (managerial), $80.22 (technical), and $50.30 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2023 National Occupational Employment and Wage Estimates, for occupational groups 11-1021 (managerial), 51-8091 (technical), and 43-6010 (clerical). The rates represent the mean hourly wage, and have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that each existing source will re-familiarize with the requirements each year.
d New sources file initial reports in their first year.
e We assume that approximately one-third of respondents will have one incident per year that will require a change of information report).
f We assume that 1.0 percent of new respondents will request a variance or extension on their compliance application.
g We assume that 1.0 percent of new and existing sources per year will be required to respond to enforcement questions or other agency requests for information.
h The includes the burden to establish an account and submit triennial reports in CEDRI for the first time and is a one-time activity following promulgation of the rule. The burden to submit reports is otherwise included in the burden under 3B.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 4

Table 4: Annual EPA Burden and Cost (Year 1) - National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Number of occurrences per respondent per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial notification c	8	1	8	1	8	0.4	0.8	$512.04		Labor Rates
2. Change of Information in Notificatione d	4	1	4	15.7	62.7	3.13	6.27	$4,011.02		Management	$76.91
3. Temporary Variance/Compliance Extension Application e	16	1	16	0.1	1.6	0.08	0.16	$102.41		Technical	$57.07
4. Written notification of data request f	40	1	40	10	400	20	40	$25,602.24		Clerical	$30.88
5. Small Quantity Manufacturer Exemption Claim Notification	4	1	4	2	8	0.4	0.8	$512.04
6. Exemption Annual Report	8	1	8	2	16	0.8	1.6	$1,024.09
7. Notice of Certifying Entity to Maintain Records	2	1	2	3	6	0.3	0.6	$384.03
8. Notice Rescinding Certification	2	1	2	1	2	0.1	0.2	$128.01
9. Triennial Reportsg
A. Develop Database and Report Forms	300	1	300	1	300	15	30	$19,201.68
B. Populate Database	12	1	12	0	0	0	0	$0
C. QA/Review Data	600	1	600	1	600	30	60	$38,403.36
TOTAL (rounded) h					1,610			$89,900
Assumptions:
a We have assumed 46 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $76.91 (managerial), $57.07 (technical), and $30.88 (clerical). These rates are from the Office of Personnel Management (OPM), 2024 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 We have assumed that it will take eight hours for the Agency to review the initial report filed by new sources.
d We have assumed that it will take four hours for the Agency to review to review the change of information reports.
e We have assumed that it will take sixteen hours for the Agency to review requests for variances or extensions filed by new sources on their compliance application.
f We assume that EPA will request additional data from 10 new and existing sources regarding enforcement questions or other agency requests for information, and that it will take 40 hours to review this data.
g Each respondent is required to submit a report of formulations and VOC usage once every three years. We assume EPA will develop/update the database and reporting forms, collect the data submissions from all respondents, populate the database, and then perform a QA and review of the data.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 5

Table 5: Annual EPA Burden and Cost (Year 2) - National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Number of occurrences per respondent per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial notification c	8	1	8	1	8	0.4	0.8	$512.04		Labor Rates
2. Change of Information in Notification d	4	1	4	15.7	62.7	3.1	6.3	$4,011.02		Management	$76.91
3. Temporary Variance/Compliance Extension Application e	16	1	16	0.1	1.6	0.08	0.16	$102.41		Technical	$57.07
4. Written notification of data request f	40	1	40	10	400	20	40	$25,602.24		Clerical	$30.88
5. Small Quantity Manufacturer Exemption Claim Notification	4	1	4	2	8	0.4	0.8	$512.04
6. Exemption Annual Report	8	1	8	2	16	0.8	1.6	$1,024.09
7. Notice of Certifying Entity to Maintain Records	2	1	2	3	6	0.3	0.6	$384.03
8. Notice Rescinding Certification	2	1	2	1	2	0.1	0.2	$128.01
9. Triennial Reportsg
A. Develop Database and Report Forms	300	1	300	1	300	15	30	$19,201.68
B. Populate Database	12	1	12	0	0	0	0	$0
C. QA/Review Data	600	1	600	1	600	30	60	$38,403.36
TOTAL (rounded) h					1,610			$89,900
Assumptions:
a We have assumed 46 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $76.91 (managerial), $57.07 (technical), and $30.88 (clerical). These rates are from the Office of Personnel Management (OPM), 2024 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 We have assumed that it will take eight hours for the Agency to review the initial report filed by new sources.
d We have assumed that it will take four hours for the Agency to review to review the change of information reports.
e We have assumed that it will take sixteen hours for the Agency to review requests for variances or extensions filed by new sources on their compliance application.
f We assume that EPA will request additional data from 10 new and existing sources regarding enforcement questions or other agency requests for information, and that it will take 40 hours to review this data.
g Each respondent is required to submit a report of formulations and VOC usage once every three years. We assume EPA will develop/update the database and reporting forms, collect the data submissions from all respondents, populate the database, and then perform a QA and review of the data.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: Table 6

Table 6: Annual EPA Burden and Cost (Year 3) - National Volatile Organic Compound Emission Standards for Aerosol Coatings (40 CFR Part 59, Subpart E) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Number of occurrences per respondent per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
1. Initial notification c	8	1	8	1	8	0.4	0.8	$512.04		Labor Rates
2. Change of Information in Notificatione d	4	1	4	15.7	62.7	3.1	6.3	$4,011.02		Management	$76.91
3. Temporary Variance/Compliance Extension Application e	16	1	16	0.1	1.6	0.08	0.16	$102.41		Technical	$57.07
4. Written notification of data request f	40	1	40	10	400	20	40	$25,602.24		Clerical	$30.88
5. Small Quantity Manufacturer Exemption Claim Notification	4	1	4	2	8	0.4	0.8	$512.04
6. Exemption Annual Report	8	1	8	2	16	0.8	1.6	$1,024.09
7. Notice of Certifying Entity to Maintain Records	2	1	2	3	6	0.3	0.6	$384.03
8. Notice Rescinding Certification	2	1	2	1	2	0.1	0.2	$128.01
5. Triennial Report g
A. Develop Database and Report Forms	300	1	300	1	300	15	30	$19,201.68
B. Populate Database	12	1	12	49	588	29	59	$37,635.29
C. QA/Review Data	600	1	600	1	600	30	60	$38,403.36
TOTAL (rounded) h					2,290			$128,000
Assumptions:
a We have assumed 46 existing respondents in year 1 and one additional new aerosol coating manufacturer each year.
b This ICR uses the following labor rates: $76.91 (managerial), $57.07 (technical), and $30.88 (clerical). These rates are from the Office of Personnel Management (OPM), 2024 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 We have assumed that it will take eight hours for the Agency to review the initial report filed by new sources.
d We have assumed that it will take four hours for the Agency to review to review the change of information reports.
e We have assumed that it will take sixteen hours for the Agency to review requests for variances or extensions filed by new sources on their compliance application.
f We assume that EPA will request additional data from 10 new and existing sources regarding enforcement questions or other agency requests for information, and that it will take 40 hours to review this data.
g Each respondent is required to submit a report of formulations and VOC usage once every three years. We assume EPA will develop/update the database and reporting forms, collect the data submissions from all respondents, populate the database, and then perform a QA and review of the data.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: 3-Year Summary

Three Year Summary
Respondent Burden and Costs
Year	Reporting Hours	Recordkeeping Hours	Total Hours	Reporting Costs	Recordkeeping Costs	Total Costs
Year 1	997	6,486	7,483	$79,579	$517,634	$597,212
Year 2	892	6,624	7,516	$71,227	$528,647	$599,874
Year 3	1,288	12,397	13,685	$102,799	$989,378	$1,092,176
Total	3,178	25,507	28,685	$253,604	$2,035,658	$2,289,262
3-Year Average	1,059	8,502	9,562	$84,535	$678,553	$763,087
Agency Burden and Costs
Year	Labor Hours	Labor Costs
Year 1	1,610	$89,900
Year 2	1,610	$89,900
Year 3	2,290	$128,000
Total	5,510	$307,800
3-Year Average	1,840	$103,000
Average Hours per Response		115

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Sheet 8: Capital O&M

There are no Capital/Startup and O&M costs associated with this ICR.

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Sheet 9: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial notification	1	1	N/A	1
Change of Information in Notification	15.7	1	N/A	15.7
Temporary Variance/Compliance Extension Application	0.1	1	N/A	0.1
Respond to the written notification of data request	10	1	N/A	10
Small Quantity Manufacturer Exemption Claim Notification	2	1	N/A	2
Exemption Annual Report	2	1	N/A	2
Notice of Certifying Entity to Maintain Records	3	1	N/A	3
Notice Rescinding Certification	1	1	N/A	1
Triennial Reports	48	1	N/A	48
		Total (rounded)		83

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Sheet 10: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	1	46	0	0	47
2	1	47	0	0	48
3	1	48	0	0	49
Average	1	47	0	0	48
1 New respondents include sources with constructed, reconstructed and modified affected facilities.