2115ss03

14

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal), EPA ICR Number 2115.03, OMB Control Number 2060-0535

1(b) Short Characterization/Abstract

Respondents are owners or operators of new and existing facilities that manufacture a miscellaneous coating and are either located at, or are part of, major sources of hazardous air pollutant (HAP) emissions. “Major source” means that the process equipment used to manufacture the miscellaneous coatings and any other operations or equipment at the facility emit, or have the potential to emit, 10 tons per year or more of a single HAP or 25 tons per year or more of any combination of HAP. A facility is subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing if it meets the following criteria:

1. Manufactures coatings, including inks, paints, or adhesives described by Standard Industrial Classification (SIC) codes 285, or 289, or North American Industrial Classification System (NAICS) codes 3255, or 3259;

2. Processes, uses, or produces HAP;

3. Not part of an affected source under another subpart of 40 CFR part 63.

An average of approximately 132 existing miscellaneous coating manufacturing respondents will be subject to the standard over the next three years. The number of respondents is expected to grow about two percent over the next three years (0.67 percent per year) which adds approximately one respondent per year to the inventory. An annual average of approximately 133 respondents would be subject to the standard over the three-year period covered by this ICR.

Owners or operators of miscellaneous coating manufacturing facilities subject to the standard must choose one of the compliance options described in the standard, or install and monitor control systems that reduce HAP emissions to the allowable emission rate. Specifically, owners, or operators are required to install, operate, and maintain a continuous monitoring system (CMS) to demonstrate compliance with the emission limitations in Tables 1 through 3 and 5 through 6 in the standard and the operating limits in Table 7; and they also must record the values of equipment operating parameters as specified in Table 7. Owners, or operators are required to conduct equipment inspections and equipment leak monitoring to demonstrate compliance with the work practice standards in Tables 1 through 5.

Also, miscellaneous coating manufacturing facilities are subject to the general provisions at 40 CFR part 63, subpart A which apply to all NESHAP subject facilities. These requirements include those associated with the applicability determinations; notifications that the facilities are subject to the rule; notifications of performance tests; notifications of compliance status, including the results of performance tests and design evaluations; and semiannual compliance reports. In addition to the requirements of subpart A, many respondents are required to submit a precompliance report and leak detection and repair (LDAR) reports; and existing facilities that wish to implement emissions averaging provisions must submit an emissions averaging plan.

All reports are to be submitted to the respondent’s state, or local agency, or to the EPA regional office, whichever has been delegated enforcement authority by EPA. The information is used to determine whether or not all sources subject to the rule are achieving the emission limitations and work practice standards in the rule.

If the owner, or operator identifies any deviation from an emission limitation or work practice standard, a compliance report must be submitted that includes all records that the source is required to maintain that pertain to the periods during which such deviation occurred, as well as data regarding: the magnitude of each deviation; the reason for each deviation; a description of the corrective action taken for each deviation, including action taken to minimize each deviation and actions taken to prevent a recurrence; and a copy of all quality assurance activities performed on any monitoring protocol.

Owners, or operators of a miscellaneous coating manufacturing facility must maintain a copy of all monitored equipment operating parameter values that demonstrate compliance with the operating limits in the rule, as well as records of inspections and results of equipment leak monitoring that demonstrate compliance with the work practice standards in the rule. Also, owners, or operators are required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of a source, or any period during which the monitoring system is inoperative. Those records must be maintained for a minimum of five years. At a minimum, the most recent two years of data must be retained onsite. The remaining three years of data may be retained offsite.

A previous Information Collection Request (ICR) incorrectly identifies “Federal Government” and “State, Local, or Tribal Government” as part of the “Affected Public.” The “Affected Public” is comprised entirely of “Business, or other for profit” entities as described in the previous approved ICR renewal.

The OMB approved the current ICR without any ”Terms of Clearance.”

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal). The burden to the “Federal government” is attributed entirely to work performed by Federal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (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 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, emissions from miscellaneous coating manufacturers cause, or contribute to air pollution that may reasonably be anticipated to endanger public health, or welfare. Therefore, the NESHAP for Miscellaneous Coating Manufacturing was promulgated at 40 CFR part 63, subpart HHHHH.

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

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission requirements. Continuous emission monitors are used to ensure compliance at all times.

The notifications required in the standards are used to inform the Agency, or delegated authority when a source becomes subject to the requirements of the standard. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and the standards are being met. The performance test also may 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 HHHHH.

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, no duplication exists.

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 at 74 FR 32580 on July 8, 2009. No comments were received on the burden published in the Federal Register.

3(c) Consultations

An industry consultation was conducted with Carolyn A. Wacker, (651) 737-3627, Specialist, Environmental Engineer, 3M Company. The 3M Company has five facilities that are complying with applicable requirements of this NESHAP. 3M estimated that the burden hours to the five facilities for ongoing compliance activities (Table 1, burden items 3C for semiannual reports excluding emissions averaging, items 4H and 4I) would not exceed the EPA estimates. The cost for LDAR and reporting is 100 to 200 hours per 3M facility; this ICR indicates 250 hours are spent for the same activities. Generally, the 3M estimates confirm the burden hour estimates in this ICR. One 3M facility contracts out the LDAR monitoring. The contractor cost to this facility is $1,300 higher based on the EPA hourly rate for 30 hours.

In addition to an industry-based consultation, the Agency’s industry experts have been consulted during a previous renewal of this ICR. Our internal data sources and the Agency’s projections for industry growth over the next three years were also considered. Our most relevant data source was the Air Facility System (AFS) which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry was based on our consultations with the Agency’s internal industry experts. An annual average of approximately 133 respondents would be subject to the standard over the three year period covered by this ICR.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes.

It is our policy to carefully review any comments received since the last ICR renewal including those submitted in response to the first Federal Register notice and respond appropriately. 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 and 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, monitor any pattern of non-compliance, and 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 and recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are the owners, or operators of miscellaneous coating manufacturing facilities. The United States Standard Industrial Classification (SIC) codes for such facilities are 285 and 289, which correspond to the North American Industry Classification System (NAICS) codes 3255 and 3259.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported are required by the NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH).

A source must make the following reports:

Notifications/Reports	Regulation References
Initial notifications (including construction/reconstruction)	63.5, 63.9(b), and 63.8070(a)-(c)
Notification of performance test, test plan, and emission profile	63.7(b)-(c), 63.9(e), and 63.8070(a),(d)
Notification of CMS performance evaluation	63.8(e)(2) and 63.9(g)
Notification of compliance status (including performance test results)	63.9(h), 63.10(d)(2), and 63.8070(e)
Notification of process change	63.8070(f)
Emissions averaging plan	63.1250-63.1260, 63.8060
Precompliance report	63.8075(c)
Semiannual compliance report Startup, shutdown, and malfunction reports Deviations/no deviations/out-of-control CMS No out-of-control CMS Heat exchange system reports (delay of repair) Maintenance and inspection reports for storage tank control devices Operating scenario reports Equipment leak reports Emissions averaging reports	63.10(e)(3) and 63.8075(b),(d) 63.10(d)(5) and 63.8075(d)(4) 63.8075(d)(5) 63.8(c)(7), 63.8075(d)(6) 63.104(e), (f)(2)(i)-(iv), 63.8075(d)(7) 63.1063(c)(2)(iv)(B) or (e)(2), 63.8075(d)(8) 63.8075(d)(9) 63.1039(b)(1)-(8) and 63.8075(d)(10) 63.1250-63.1260, 63.8060

A source must keep the following records:

Recordkeeping Requirements	Regulation Reference
Record retention	63.10(b)(1) and 63.8085
Documentation supporting initial notifications and notifications of compliance status	63.10(b)(2)(xiv) and 63.8080(a)(1)
Startup, shutdown, and malfunction plan	63.6(e)(3)
Records related to startup, shutdown, and malfunction	63.6(e)(3)(iii)-(iv) and 63.8080(a)(2)
Records of performance tests and CMS performance evaluations	63.10(b)(2)(viii) and 63.8080(a)(3)
Records for equipment leaks	63.1038(b)-(c) and 63.8080(a)(4)
Daily schedule or log of each operating scenario	63.8080(a)(5)
Records for process vessels complying with percent reduction emission limitation	63.8080(a)(6)
Planned routine maintenance records for storage tank control devices	63.8080(a)(7)
Maintenance wastewater plan	63.8080(a)(8)
Records for safety device openings	63.8080(a)(9)
Results of each CMS calibration, validation check, and inspection	63.8035(c)(6)-(8), (d)(4)-(5), (e)(4)-(7), (f)(3)-(4), 63.8080(a)(10)
Records for emissions averaging	63.1250-63.1260, 63.8060
Records for each CMS	3.8(d)(3), 63.8(f)(6)(i), 63.10(b)(2)(vi)-(xi), and 63.8080(b)

Electronic Reporting

Also, regulatory agencies, in cooperation with the respondents, continue to create reporting systems to transmit data electronically. However, electronic reporting systems are still not widely used. At this time, it is estimated that approximately 20 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate opacity and/or parameter monitors

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 Air Facility System (AFS).

5(b) Collection Methodology and Management

Following the notification of startup, the reviewing authority may inspect the affected facility to 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. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. Immediate startup, shutdown and malfunction notifications and reports alert the Agency to atypical operations conditions which result in violations of the emission limitations. 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 entered into the Air Facility System (AFS), which is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the AFS 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

Based on review of the following sources: Final Rule (71 FR 58499); Proposed Rule (71 FR 28639); Summary of Public Comments and Responses (EPA 450/R-02-XXXX, August 2003); and the Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP (EPA-305-B-06-003, Sept. 2006), an estimate of the number of small entities affected by this rule could not be determined.

Based on the previous ICR renewal, there are few, if any, small entities (i.e., small businesses) affected by this regulation. However, any impact on small entities was taken into consideration during the development of the standard. Generally, only major sources of pollution are regulated under the standard.

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 Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH) (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 respondents. 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.

6(a) Estimating Respondent Burden

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the respondents. 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.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $100.99 ($48.09 + 110%)

Technical $87.97 ($41.89 + 110%)

Clerical $43.81 ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, December, 2005, ”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 types of industry costs associated with the information collection activities in the standard are both labor costs, which are addressed elsewhere in this ICR, and the costs associated with continuous monitoring. The capital/startup costs are one-time costs that occur when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and include other costs, such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring	(B) Capital/Startup Cost	(C) Number of New Respondents	(D) Total Capital/Startup Cost (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Process Vessels	$30,000	1	$30,000	$16,000	132	$2,112,000
Transfer Operations	N/A	N/A	N/A	$3,100	132	$409,200
Wastewater Systems	N/A	N/A	N/A	$2,000	132	$264,000
Totals	$30,000					$2,785,200

The total capital/startup costs for this ICR are $30,000. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this ICR are $2,785,200. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $2,815,000 per year.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. The EPA 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 $41,417.

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

Managerial $57.20 (GS-13, Step 5, $35.75 x 1.6)

Technical $42.45 (GS-12, Step 1, $26.53 x 1.6)

Clerical $22.96 (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) ”2006 General Schedule“ which excludes locality rates of pay. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH) (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 9 of the 132 existing respondents will be subject to the standard. It is estimated that one additional respondent per year will become subject over the three-year period covered by this ICR.

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	1	131	0	0	132
2	1	132	0	0	133
3	1	133	0	0	134
Average	1	133	0	0	133

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 133.

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
Notification of construction/reconstruction	1	1	N/A	1
Notification of anticipated startup	1	1	N/A	1
Notification of actual startup	1	1	N/A	1
Notification of applicability of standard	1	1	N/A	1
Emission averaging plan	1	0	N/A	0
Precompliance report	1	1	N/A	1
Notification of initial performance test	1	0	N/A	0
Notification of initial CMS performance evaluation	1	0	N/A	0
Notification of compliance status	1	1	N/A	1
Notification of process change	13	1	N/A	13
Semiannual report	132	2	N/A	264
Startup, shutdown, malfunction report	7	1	N/A	7
LDAR report	132	2	N/A	264
Emission averaging report	13	1	N/A	13
			Total	567

The number of Total Annual Responses is 567.

6(e) Bottom Line Burden Hours 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 annual labor hours are 167,572 per year over the three years of this ICR. The total annual labor costs are $14,192,714. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 296 hours per response. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH) (Renewal).

The total annual capital/startup and O&M costs to the regulated entity are $2,815,200. 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 1,001 labor hours at a cost of $41,416. See below Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH) (Renewal)

6(f) Reasons for Change in Burden

There is no change in the calculation methodology for labor hours or costs to the respondents in this ICR compared to the previous ICR. This is due to two considerations: (1) the regulations have not changed over the past three years and are not anticipated to change over the next three years; and (2) the growth rate for respondents is very low, negative, or non-existent. Therefore, the labor hours and cost figures in the previous ICR reflect the current burden to the respondents and are reiterated in this ICR.

In the previous ICR renewal, the total respondent burden approved in the “Notice of Office of Management and Budget Action” was 167,832 hours. This burden does not match the total burden as calculated below in Table 1 of the Supporting Statement. This ICR uses the same calculation methodology as the past ICR renewal. This renewal requests approval of 167,572 hours—260 less hours than previously approved.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 296 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-2009-0405. 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, 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), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, D.C. 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, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2009-0405 and OMB Control Number 2060-0535 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal)
			A	B	C	D	E	F	G	H	I
			Burden hours per occurrence	Number of occurrences per year	Technical hours per respondent per year	Respondents per yeara	Technical hours per respondent	Management hours per year	Clerical hours per year	Respondent hours per year	Labor Cost, $
		Burden item
					(C = A * B)		(E = C * D)	(F = E * 0.05)	(G = E * 0.1)	(H = E + F + G)
1	Applications		N/A
2	Surveys and Studies		N/A
3	Reporting Requirements
	A.	Read Instructionsc	1.0	1.0	1.0	1	1.0	0.1	0.1	1.2	97
	B.	Required Activities
		Initial CMS performance evaluationd	10.0	1.0	10.0	0	0.0	0.0	0.0	0.0	0
		Create Information	Included in item 4
		Gather Existing Information	Included in item 4
	C.	Write Reports
		Notification of construction/reconstruction	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195
		Notification of anticipated startup	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195
		Notification of actual startup	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195
		Notification of applicability of standard
		1. Existing sources	2.0	0.0	0.0	0	0.0	0.0	0.0	0.0	0
		2. New sources	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195
		Emissions averaging plane	40.0	1.0	40.0	0	0.0	0.0	0.0	0.0	0
		Precompliance reportf	40.0	1.0	40.0	1	40.0	2.0	4.0	46.0	3,896
		Notification of initial performance testg	2.0	1.0	2.0	0	0.0	0.0	0.0	0.0	0
		Notification of initial CMS performance evaluationd	2.0	1.0	2.0	0	0.0	0.0	0.0	0.0	0
		Notification of compliance status
		1. With performance testg	80.0	1.0	80.0	0	0.0	0.0	0.0	0.0	0
		2. Without performance testg	120.0	1.0	120.0	1	120.0	6.0	12.0	138.0	11,688
		Notification of process changeh	8.0	1.0	8.0	13	104.0	5.2	10.4	119.6	10,130
		Semiannual compliance report
		1. No Deviationsi	8.0	1.0	8.0	119	952.0	47.6	95.2	1,094.8	92,725
		2. Deviationsi	24.0	1.0	24.0	13	312.0	15.6	31.2	358.8	30,389
		Startup, shutdown and malfunction reportj	8.0	1.0	8.0	7	56.0	2.8	5.6	64.4	5,454
		LDAR reportk	125.0	2.0	250.0	132	33,000.0	1,650.0	3,300.0	37,950.0	3,214,217
		Emission averaging reportl	20.0	1.0	20.0	13	260.0	13.0	26.0	299.0	25,324
	Subtotal Reporting						40,081			40,081	$3,394,700
4	Recordkeeping Requirements
	A.	Read Instructions	Included in 3A
	B.	Plan Activities	N/A
	C.	Implement Activities	N/A
	D.	Develop Record Systemm	40.0	1.0	40.0	1	40.0	2.0	4.0	46.0	3,896
	E.	Develop Startup, Shutdown, Malfunction Plann	100.0	1.0	100.0	1	100.0	5.0	10.0	115.0	9,740
	F.	Develop QA/QC Plan for CMSo	40.0	1.0	40.0	0	0.0	0.0	0.0	0.0	0
	G.	Time for Audits	N/A
	H.	Time to Enter Information
		1. Records of startup, shutdown and malfunction	1.5	1.0	1.5	132	198.0	9.9	19.8	227.7	19,285
		2. Records of CMS data
		a. Record Continuously monitored parameters	1.0	365.0	365.0	132	48,180.0	2,409.0	4,818.0	55,407.0	4,692,756
		b. Compile data	24.0	2.0	48.0	132	6,336.0	316.8	633.6	7,286.4	617,130
		c. Information for semiannual reports	16.0	2.0	32.0	132	4,224.0	211.2	422.4	4,857.6	411,420
		d. LDAR recordkeeping	Included in 3C
	I.	Calibration of CMS	376.0	1.0	376.0	132	49,632.0	2,481.6	4,963.2	57,076.8	4,834,182
	J.	Personnel Trainingp	40.0	1.0	40.0	1	40.0	2.0	4.0	46.0	3,896
	K.	Refresher Coursep	16.0	1.0	16.0	132	2,112.0	105.6	211.2	2,428.8	205,710
	L	Time for Audits	N/A				0.0	0.0	0.0	0.0	0
Subtotal Recordkeeping							127,491			127,491	$10,798,014
Totals							167,572			167,572	$14,192,714
Assumptions:
a	132 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.
b	Labor cost assumes a rate of $87.97/hour for technical labor, $100.99/hour for management labor, and $43.81/hour for clerical labor.
c	This will occur only in the first year after a facility becomes subject to the rule.
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 precompliance report [50% x 1= 1 (rounded)].
g	Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests.
h	Assumes 10 percent of the facilities will implement process changes [(10% x 132= 13 (rounded)].
i	Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations [90% x 132=119 (rounded), 10% x 132 = 13 (rounded)].
j	Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan [5% x 132 = 7 (rounded)}.
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 [10% x 132 = 13 (rounded)].
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.
	Assumes no facilities will use the alternative standard, which requires CEMS and QA/QC plans.
p	Assumes 40 hours to train personnel and 16 hours for an annual refresher course.

Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal)
Activity			A	B	C	D	E	F	G
			Agency hours per occurrence	Occurrences per yeara	Technical hours per year	Management hours per year	Clerical hours per year	Total hours per year	Labor Costb, $
					(C = A * B)	(D = C * 0.05)	(E = C * 0.1)	(F = C + D + E)
	Notifications/Reports
A.		Performance Testc	8	0	0	0	0	0	0
B.	Repeat Performance Testd		8	0	0	0	0	0	0
C.	CMS Performance Evaluatione		4	0	0	0	0	0	0
D.		Review Notification of Construction/Reconstruction	2	1	2	0.1	0.2	2.3	95
E.		Review Notification of Anticipated Startup	2	1	2	0.1	0.2	2.3	95
F.		Review Notification of Actual Startup	2	1	2	0.1	0.2	2.3	95
G.		Review Notification of Applicability of Standard	2	1	2	0.1	0.2	2.3	95
H.		Review Emissions Averaging Planf	12	13	156	7.8	15.6	179.4	7,427
I.		Review Precompliance Reportg	4	1	4	0.2	0.4	4.6	190
J.		Review Notification of Initial Performance Test	2	0	0	0	0	0	0
K.		Review Notification of Initial CMS Performance Evaluatione	2	0	0	0	0	0	0
L.		Review Notification of Compliance Status
		1. With performance testh	4	0	0	0	0	0	0
		2. Without performance testi	4	1	4	0.2	0.4	4.6	190
M.		Review Notification of Process Changej	6	13	78	3.9	7.8	89.7	3,713
N.		Review Semiannual Compliance Report
O.		No deviationsk	2	119	238	11.9	23.8	273.7	11,330
P.		Deviationsk	4	13	52	2.6	5.2	59.8	2,476
Q.		Startup, shutdown, and malfunction reportl	2	7	14	0.7	1.4	16.1	666
R.		LDAR reportm	2	132	264	13.2	26.4	303.6	12,568
S.		Emissions averaging reportf	4	13	52	2.6	5.2	59.8	2,476
Totals					870	44	87	1,001	$41,416
Assumptions:
a	132 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.
b	Labor cost assumes a rate of $42.45/hour for technical labor, $57.20/hour for management labor, and $22.96/hour for clerical labor.
c	Assumes no initial performance tests because all facilities will comply by submitting engineering calculations.
d	Assumes no repeat performance tests.
e	Assumes no performance evaluations are required for the parameter monitoring systems included in the rule.
f	Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply [10% x 132 = 13 (rounded)].
g	Assumes 50 percent of the new facilities will submit a precompliance report [50% x 1= 1 (rounded)].
h	Assumes one new facility will conduct initial performance tests.
i	Assumes all existing facilities have complied by submitting engineering calculations.
j	Assumes 10 percent of the facilities will implement process changes [(10% x 132= 13 (rounded)].
k	Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations [90% x 132=119 (rounded), 10% x 132 = 13 (rounded)].
l	Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan [5% x 132 = 7 (rounded)}.
m	Assumes all facilities will report the specified information for processes subject to the equipment leak standards.