Aerospace RTR Supporting Statement

Aerospace RTR Supporting Statement.pdf

NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Proposed Rule)

OMB: 2060-0314

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SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
Risk and Technology Review (RTR) for NESHAP for Aerospace Manufacturing and
Rework Facilities (40 CFR Part 63, Subpart GG)
1. Identification of the Information Collection
1(a) Title of the Information Collection
NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG)
RTR, EPA ICR Number 1687.10 OMB Control Number 2060-0314.
1(b) Short Characterization/Abstract
This supporting statement addresses information collection activities that will be imposed
by amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Aerospace Manufacturing and Rework Facilities, 40 CFR part 63, subpart GG. Proposed on June
6, 1994; promulgated on September 1, 1995; and last-amended on April 20, 2006, the NESHAP
applies to existing and new aerospace manufacturing and rework facilities where the total
hazardous air pollutants (HAP) emitted are greater than or equal to 10 tons per year of any single
HAP, or where the total HAP emitted are greater than or equal to 25 tons per year of any
combination of HAP. New facilities include those that commenced construction or
reconstruction after the date of proposal. Operations covered include: cleaning, primer and
topcoat application, depainting, chemical milling maskant application, and handling and storage
of waste.
As part of the residual risk review for the NESHAP and technology reviews for the
NESHAP, the proposed amendments add specialty coating application operations to the rule and
remove the exemptions from the emissions limitations for periods of startup, shutdown and
malfunction (SSM) so that affected units would be subject to the emission standards at all times.
This information collection request documents the additional recordkeeping and reporting
requirements and burden imposed by the proposed amendments to the rule.
In general, all NESHAP standards require initial notifications, performance tests, and
periodic reports by the owners/operators of the affected facilities. These notifications, reports,
and records are essential in determining compliance, and are required of all affected facilities
subject to NESHAP. This ICR includes the burden for activities that will be conducted in the
first three years following promulgation of the proposed amendments to the NESHAP for
Aerospace Manufacturing and Rework Facilities. The proposed rule would add recordkeeping
and reporting provisions for specialty coating operations, but would not change the compliance
costs for operations already being regulated by the existing emission standards.
Any owner/operator subject to the provisions of this part shall maintain a file of these
notifications, reports, and records, and retain the file for at least five years following the date of

such notifications, 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
United States Environmental Protection Agency (EPA) regional office.
Based on our consultations with industry representatives, there is an average of one
affected specialty coating operation (which is the total of all specialty coating applications) at
each plant site and that each plant site has only one respondent (i.e., the owner/operator of the
plant site).
Over the next three years, an average of 144 facilities per year will be subject to the
standard, and no additional respondents per year will become subject to the standard. However,
36 of these facilities are owned and operated by the Federal government, and are not considered
respondents of this ICR. Therefore, the Affected Public only includes the 108 facilities that are
privately-owned, for-profit businesses. Each respondent may have one or more operations (e.g.,
cleaning, coating, depainting, or specialty coating operations) subject to these standards. Of the
144 existing sources currently covered by this standard, 109 facilities have specialty coating
operations. The EPA estimates that the total number of potentially affected facilities with
specialty coating operations is approximately 27 Federal government-operated facilities and 82
privately-operated facilities.
All of the aerospace manufacturing and rework facilities in the United States are owned
and operated by the Aerospace Manufacturing and Rework industry. Thirty-six of the facilities in
the United States are owned by the Federal government and 108 facilities are privately-owned,
for-profit businesses (hereafter, the latter are referred to as the “Affected Public”). The “burden”
to the Affected Public may be found below in Tables A1 to A3 of Attachment A. The cost of this
ICR to privately-operated aerospace manufacturing and rework facilities is $435,176 in labor
costs, averaged over the first 3 years after the amendments are final.
The total average annual Agency cost during the three years of the ICR is estimated to be
$207,135. The “burden” to the Agency may be found below in Tables B1 through C3 of
attachment A. The burden includes the cost to Federal government-operated aerospace
manufacturing and rework facilities to comply with the proposed amendments, and to the Federal
EPA and state agencies to implement the proposed amendments.
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, HAP emissions from aerospace manufacturing and
rework facilities cause or contribute to air pollution that may reasonably be anticipated to
endanger public health or welfare. Therefore, the NESHAP were promulgated for this source
category at 40 CFR part 63, subpart GG.
2(b) Practical Utility/Users of the Data
The recordkeeping and reporting requirements in the standard(s) ensure compliance with
the applicable regulations which where promulgated in accordance with the Clean Air Act. The
collected information is also used for targeting inspections and as evidence in legal proceedings.
Performance tests are required in order to determine an affected facility’s initial
capability to comply with the emission standard(s). Continuous emission monitors are used to
ensure compliance with the standard(s) 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 the standard(s) 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 the standard(s) 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. Nonduplication, Consultations, and Other Collection Criteria
The requested recordkeeping and reporting are required under (40 CFR part 63, subpart
GG).
3(a) Nonduplication

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
A public notice of this collection is provided in the Federal Register notice of proposed
rulemaking published for the Aerospace Manufacturing and Rework Facilities NESHAP RTR.
3(c) Consultations
The public will be provided the opportunity to review and comment on the burden
estimated in this Information Collection Request during the comment period for the proposed
rulemaking. In addition, industry representatives including Aerospace Industries Association,
and several member companies, provided information concerning the NESHAP for Aerospace
Manufacturing and Rework Facilities at meetings with the EPA prior to rule proposal.
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
40 CFR 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 (see 40 CFR 2; 41 FR 36902, September 1,
1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR
17674, March 23, 1979).
3(g) Sensitive Questions
The reporting or recordkeeping requirements in the standard do not include sensitive
questions.
4. The Respondents and the Information Requested
4(a) Respondents/SIC Codes
The respondents to the recordkeeping and reporting requirements are aerospace
manufacturing and rework facilities. The United States Standard Industrial Classification (SIC)
code for the respondents affected by the standards and the corresponding North American
Industry Classification System for aerospace manufacturing and rework facilities are listed
below.
40 CFR Part 63, Subpart GG

SIC Codes

NAICS Codes

Aircraft and Parts

3720

None

Aircraft Manufacturing

3721

336411

Aircraft Engine and Engine Parts Manufacturing

3724

336412

Other Aircraft Part and Auxiliary Equipment
Manufacturing

3728

336413

Guided Missiles and Space Vehicles Manufacturing

3761

336414

Guided Missile and Space Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing

3764

336415

Other Guided Missile and Space Vehicle Parts and
Auxiliary Equipment Manufacturing

3769

336419

Scheduled Passenger Air Transportation

4512

481111

Scheduled Freight Air Transportation

4512

481112

Nonscheduled Chartered Passenger Air Transportation

4522

481211

Nonscheduled Chartered Freight Air Transportation

4522

481212

Other Nonscheduled Air Transportation

4522

481219

4(b) Information Requested
(i) Data Items
In this ICR, all the data that are recorded or reported are required by the proposed
amendments to the NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part
63, Subpart GG).
A source must make the following reports:
Notifications/Reports
Notification of construction and modification

63.743(a)(2-3),
63.753(a), 63.5(d),
63.10(d)(5)

Initial notification for existing sources

63.9(b)(2),
63.753(a)(2)

Notification of performance test and results

63.7(b), 63.7(g)(1),
63.9(e), 63.10(d)(2),
63.753(a)

Notification and report of physical and operational changes

63.5(b)(6),
63.743(a)(2),
63.753(a)

Notification and report of production capacity

63.9(b)(2), 63.753(a)

Notification and report of compliance status

63.9(h), 63.753(a)

Notification and report for waiver applications

63.7(h)(3), 63.753(a)

Semiannual report

63.10(e)(3),
63.753(c)(1),
63.753(d)(1) and (3),
63.753(e)

Annual report

63.753(c)(2),
63.753(d)(2)

A source must keep the following records:

Recordkeeping
Records of daily and monthly inspections

63.10(b)(2),
63.743(a)(3),
63.752(a)

Emission testing

63.10(b)(2),
63.752(a)

Facility operation and maintenance including construction and
modification

63.5(b),
63.743(a)(2) and
(3), 63.752

Primers/topcoats/maskants/specialty coatings: Records using compliant
coatings without averaging

63.752(c)(1-3),
63.752(f)(1)

Primers/topcoats/maskants/specialty coatings: Records using averaging

63.752(c)(1),
63.752(c)(4),
63.752(f)(2)

Primers/topcoats/maskants/specialty coatings: Records using control
devices

63.752(c)(1),
63.752(c)(5-6),
63.752(d),
63.752(f)(3),
63.752(f)(4)

5-years retention of records

63.10(b)(1),
63.752(a)

Electronic Reporting
Some of the respondents are using monitoring equipment that automatically records
parameter data. Although personnel at the affected facility must still evaluate the data, internal
automation has significantly reduced the burden associated with monitoring and recordkeeping at
a plant site.
Also, regulatory agencies in cooperation with the respondents continue to create reporting
systems to transmit data electronically. However, electronic reporting systems are still not widely
used. At this time, it is estimated that approximately 10 percent of the respondents use electronic
reporting.

(ii) Respondent Activities

Respondent Activities
Read instructions.
Install, calibrate, maintain, and operate CMS for pressure drop and liquid supply pressure for
control device.
Perform initial performance test, Reference Methods 1, 1A, 2, 2A, 2C, 2D, 3, 4,18, 24, 25A,
40, 301, or 319 tests, 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.
Currently sources are using monitoring and reporting equipment that provide parameter
data in an automated way (e.g., continuous parameter monitoring system). Although personnel at
the source still need to evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.
5. The Information Collected: Agency Activities, Collection Methodology, and Information
Management
5(a) Agency Activities
EPA conducts the following activities in connection with the acquisition, 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 Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management
Facilities are expected to use purchase records and manufacturer’s documentation of
HAP and VOC content, based on coating formulation, to establish compliance with the proposed
HAP and VOC content limit standards in the Aerospace NESHAP for specialty coatings.
Facilities are not expected to measure the HAP or VOC content of the coatings. If a facility is
using add-on controls to comply, 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 used in compliance and enforcement programs. The semiannual reports
submitted by respondents 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 OTIS which is operated and
maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection,
maintenance, and retrieval of compliance data for approximately 125,000 industrial and
government-owned facilities. EPA uses the OTIS 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
There are no small entities (i.e., small businesses) using specialty coatings and affected
by this regulation.
5(d) Collection Schedule
The specific frequency for each information collection activity within this request is
shown in below Tables A1 to B3 of Attachment A.
6. Estimating the Burden and Cost of the Collection
Tables A1 to A3 in Attachment A present an itemized breakdown of the reporting and
recordkeeping requirements in the first 3 years for the private sector respondents subject to the
proposed NESHAP. Tables B1to B3 presents the burden on Federal government-operated
aerospace manufacturing and rework facilities and is included in the Agency burden discussed
below.
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
collection of information unless it displays a currently valid OMB Control Number.
6(a) Estimating Respondent Burden
The average annual burden to respondents in the private sector over the next three years
from these recordkeeping and reporting requirements is estimated to be 4,475 hours (Total Labor
Hours from Tables A1 to A3 of Attachment A). 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
Technical
Clerical

$127.72 ($60.82 + 110%)
$101.60 ($48.38 + 110%)
$38.58 ($18.37 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, May
2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace
Product and Parts Manufacturing (NAICS code 336400). 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 standard(s) are labor costs. There are no capital/startup or operation and
maintenance costs associated with the recordkeeping and reporting requirements. EPA assumed
that the recordkeeping associated with the specialty coating operations will be accomplished with
the existing equipment (e.g., computer systems) used for compliance for existing coating
operations.
(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost
Costs to the Agency include the costs for Federal government-owned aerospace

manufacturing and rework facilities associated with complying with the proposed amendments.
Tables B1 to B3 in Attachment A present an itemized breakdown of the reporting and
recordkeeping requirements in the first 3 years for the Federal government-owned sources
subject to the proposed NESHAP. The average annual burden to these respondents over the next
three years from these recordkeeping and reporting requirements is estimated to be 2,439 hours
and $198,395 (Total Labor Burden and Cost from Tables B1 to B3).
The costs to the Agency also include 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 for these activities during the three years of the ICR is estimated to be $8,740.
Details upon which this estimate is based appear below in Tables C1 to C3 of Attachment A.
The total average annual Agency cost during the three years of the ICR is estimated to be
$207,135.
This ICR uses the following labor rates for the costs for Federal government-owned
sources to comply with the proposed amendments:
Managerial
Technical
Clerical

$89.49 ($55.93 + 60%)
$86.16 ($53.85 + 60%)
$29.04 ($18.15 + 60%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, May
2013, “National Occupational Employment and Wage Estimates United States” in the Federal
Executive Branch (NAICS code 999100).
The average hourly labor rate used for the EPA Region and States to review reports and
compliance and enforcement is as follows:
Managerial
Technical
Clerical

$62.90 (GS-13, Step 5, $39.61 + 60%)
$46.67 (GS-12, Step 1, $28.17 + 60%)
$25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,
which excludes locality rates of pay.
Both sets of the above rates have been increased by 60 percent to account for the benefit
packages available to government employees.
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

144 existing facilities will be subject to the standard. Thirty-six of the facilities in the United
States are operated by the Federal government and 108 facilities are privately-owned, for-profit
businesses. Thus, only the 108 privately-owned businesses are considered respondents to this
ICR. Of the 144 existing sources currently covered by this standard, 109 facilities have specialty
coating operations. The EPA estimates that the total number of potentially affected facilities with
specialty coating operations is approximately 27 Federal government-operated facilities and 82
privately-operated facilities. This number of sources is expected to remain constant over the
period of this ICR as no sources are expected to start-up over the next three years. This is based
on a comprehensive ICR that was sent to all known aerospace facilities in February 2011.
While there are no additional reports that are required to be submitted by the respondents
due to the proposed Amendments, additional time is need to complete the annual reports and are
therefore considered as one additional annual response for the 82 privately-operated facilities.
Details regarding these estimates may be found in Attachment Tables A1 to B3.
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 A1 to A3, B1 to B3, and C1 to C3 respectively, and summarized
below.
(i) Respondent Tally
The total annual labor hours for privately-owned facilities are 4,475 hours at a cost of
$435,176. Details regarding these estimates may be found in Tables A1 to A3 of Attachment A.
Attachment A also presents the burden on Federal government-operated facilities and is
discussed below in section (ii).
Furthermore, the annual public reporting and recordkeeping burden for this collection of
information is estimated to average 54.6 hours per response.
There are no total annual capital/startup and O&M costs to the regulated entity. The cost
calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance
(O&M) Costs.
(ii) The Agency Tally
The total average annual Agency cost during the three years of the ICR is estimated to be
$207,135. This includes the average annual Agency burden and cost over next three years for
Federal government-operated facilities (2,439 labor hours at a cost of $198,395) and EPA
Regions and States (148 labor hours at a cost of $8,740). See Tables B1 to B3 and C1 to C3 for
details.
6(f) Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR as it is for the proposed
Aerospace Manufacturing and Rework Facilities NESHAP and is considered new burden.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information
is estimated to average approximately 54.6 hours per response. This burden is estimated by
dividing the average annual burden hours for privately-owned facilities over the three-year
period (4,475) hours by the total number of responses during the three-year period (82). 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-2014-0830. 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 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) 566-1927. 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-2014-0830 and OMB Control Number 2060-0314 in any
correspondence.

Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this
information.

ATTACHMENT A
TABLES A, B, and C

Tables A1 - A3: Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements for Specialty Coating Operations at Privately-Operated Aerospace
Manufacturing and Rework Facilities – Years 1-3
Tables B1 - B3: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements
for Specialty Coating Operations at Federal Government-Operated Aerospace
Manufacturing and Rework Facilities – Years 1-3
Tables C1 - C3: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting
Requirements of Aerospace Specialty Coating Operations – Years 1-3

Table A1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations
at Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 1
Burden item

(A)

(B)

(C)

(D)

Person hours
No. of
Person hours
per occurrence occurrences per per respondent
respondent per
per year
year

Respondents
per year

(A x B)
1. Applications

N/A

2. Surveys and studies

N/A

(E)

(F)

(G)

(H)

Technical personhours per year

Management
person hours per
year

Clerical person
hours per year

Total Cost Per

(C x D)

(E x 0.05)

(E x 0.1)

Year b

3. Reporting requirements
A. Read instructions c, d
B. Required activities

Initial performance tests

N/A

Repeat performance test

N/A

C. Create information

See 4C

D. Gather existing information

See 4C

4.1

8.2 $

9,171.03

9,171

E. Write report
Notification of construction/reconstruction

N/A e

Notification of physical and operational changes

N/A e

Notification of actual startup

N/A e

Notification of change in production capacity

N/A e

Compliance status information report

N/A e

Waiver application

N/A e

Startup, shutdown, malfunction plan

N/A e

Preparation of site-specific test plan

N/A e

Notification of initial performance test

N/A e

Report of initial test

N/A e

Startup, shutdown, malfunction report

N/A e

Semiannual report – including report of periods of noncompliance

N/A e

Subtotal for Reporting Requirements

94.3

4. Recordkeeping requirements
A. Read instructions

See 3A

B. Plan activities d
C. Implement activities

Compliance coating records

See NOTE 1

328

16.4

32.8 $

36,684.11

2497

124.85

249.7 $

279,268.97

820

82 $

91,710.28

Control device maintenance or rolling material balance log (organics) N/A e
Control device maintenance log (inorganics)

N/A e

d, f

D. Develop record system
E. Time to enter/maintain information
Records of startup, shutdown, and malfunction

N/A e

Records of all measurements and information

See 4C

492

24.6

49.2 $

55,026.17

820

41
5700.55

82 $
$

91,710.28
554,400

5794.85

563,571

required by standard
F. Time to train personneld, g
G. Time for audits h
Subtotal for Recordkeeping Requirements
TOTAL LABOR BURDEN AND COST (rounded)

We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

One-time cost that is only incurred during the first year of compliance.

We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating

We have assumed that all facilities will need to develop a record keeping system.

We have assumed one person per shift will require training on recordkeeping requirements and system.

We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.
NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR
survey responses.

Table A2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations
at Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 2
Burden item

(A)

(B)

(C)

(D)

Person hours
No. of
Person hours per
per occurrence occurrences per respondent per
year
respondent per
year
(A x B)
1. Applications
2. Surveys and studies
3. Reporting requirements

(E)

(F)

(G)

Respondents Technical person- Management
hours per year person hours per
per year a
year
(C x D)

(E x 0.05)

(H)

Clerical Total Cost Per
person
Year b
hours per
year
(E x 0.1)

N/A
N/A

A. Read instructions c, d
B. Required activities
Initial performance tests
Repeat performance test
C. Create information
D. Gather existing information
E. Write report
Notification of construction/reconstruction

N/A

Notification of change in production capacity

N/A e

Compliance status information report

N/A e

Waiver application

N/A e

Startup, shutdown, malfunction plan

N/A e

Preparation of site-specific test plan

N/A e

Notification of initial performance test

N/A e

Report of initial test

N/A e

Startup, shutdown, malfunction report

N/A e

Semiannual report – including report of periods of noncompliance

N/A e
0

Subtotal for Reporting Requirements
4. Recordkeeping requirements
A. Read instructions

See 3A
N/A
B. Plan activities d
C. Implement activities
Compliance coating records
Control device maintenance or rolling material balance log (organics) N/A e

F. Time to train personnel d, g
G. Time for auditsh
Subtotal for Recordkeeping Requirements
TOTAL LABOR BURDEN AND COST (rounded)

N/A e
N/A e

Records of all measurements and information
required by standard

See 4C
See 4C

Notification of actual startup

D. Develop record system
E. Time to enter/maintain information
Records of startup, shutdown, and malfunction

N/A e

d, f

N/A e

Notification of physical and operational changes

Control device maintenance log (inorganics)

See NOTE 1

2497

124.85

249.7 $ 279,268.97

N/A e
N/A

N/A e
See 4C
N/A
10

820

41
3814.55
3814.55

$
82 $
$
$

91,710.28
370,979
370,979

Assumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.
Assumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses mean hourly
wage for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace
Product and Parts Manufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been
increased by 110 percent to account for the benefit packages available to those employed by private industry.
c
We have assumed that there will be no net growth for the industry, only existing sources will read instructions.
d
We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for
coating operations.
e
We have assumed that all facilities will need to develop a record keeping system.
b

We have assumed one person per shift will require training on recordkeeping requirements and system.

We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

One-time cost that is only incurred during the first year of compliance.
NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011
ICR survey responses.

Table A3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations
at Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 3
Burden item

(A)

(B)

Person hours
per occurrence

1. Applications
2. Surveys and studies
3. Reporting requirements

(C)

(D)

No. of
Person hours per Respondents
occurrences
respondent per
per year a
per respondent
year
per year
(A x B)

(E)

(F)

(G)

Technical
person- hours
per year

Management
person hours per
year

(C x D)

(E x 0.05)

(H)

Clerical Total Cost Per
person
Year b
hours per
year
(E x 0.1)

N/A
N/A

N/A

N/A e

Notification of change in production capacity

N/A e

Compliance status information report

N/A e

Waiver application

N/A e

Startup, shutdown, malfunction plan

N/A e

Preparation of site-specific test plan

N/A e

Notification of initial performance test

N/A e

Report of initial test

N/A e

Startup, shutdown, malfunction report

N/A e

Semiannual report – including report of periods of noncompliance

N/A e

d, f

D. Develop record system
E. Time to enter/maintain information
Records of startup, shutdown, and malfunction
Records of all measurements and information
required by standard
F. Time to train personnel d, g
G. Time for auditsh
Subtotal for Recordkeeping Requirements
TOTAL LABOR BURDEN AND COST (rounded)

N/A e

Notification of actual startup

Control device maintenance log (inorganics)

N/A e
See 4C
See 4C

N/A e

B. Plan activities d
C. Implement activities
Compliance coating records
Control device maintenance or rolling material balance log (organics)

N/A e

Notification of physical and operational changes

Subtotal for Reporting Requirements
4. Recordkeeping requirements
A. Read instructions

0
See 3A
N/A
82

See NOTE 1

2497

124.85

249.7 $

279,268.97

N/A e
N/A e
N/A

N/A e
See 4C
N/A
10

820

41
3814.55
3814.55

$
82 $
$
$

91,710.28
370,979
370,979

Assumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.
Assumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses mean hourly wage for
the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace Product and Parts
Manufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 110 percent to
account for the benefit packages available to those employed by private industry.
c
We have assumed that there will be no net growth for the industry, only existing sources will read instructions.
d
We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating
operations.
e
We have assumed that all facilities will need to develop a record keeping system.
b

We have assumed one person per shift will require training on recordkeeping requirements and system.

We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

Table B1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations
at Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 1
Burden item

(A)

(B)

(C)

(D)

Person hours
No. of
Person hours
per occurrence occurrences per per respondent
respondent per
per year
year
(A x B)
1. Applications

N/A

2. Surveys and studies

N/A

Respondents
per year

(E)

(F)

(G)

(H)

Technical personhours per year

Management
person hours per
year

Clerical person
hours per year

Total Cost Per

(C x D)

(E x 0.05)

(E x 0.1)

Year b

3. Reporting requirements
A. Read instructions c, d
B. Required activities

Initial performance tests

N/A

Repeat performance test

N/A

C. Create information

See 4C

D. Gather existing information

See 4C

1.35

2.7 $

2,525.54

2,526

E. Write report
Notification of construction/reconstruction

N/A e

Notification of physical and operational changes

N/A e

Notification of actual startup

N/A e

Notification of change in production capacity

N/A e

Compliance status information report

N/A e

Waiver application

N/A e

Startup, shutdown, malfunction plan

N/A e

Preparation of site-specific test plan

N/A e

Notification of initial performance test

N/A e

Report of initial test

N/A e

Startup, shutdown, malfunction report

N/A e

Semiannual report – including report of periods of noncompliance

N/A e

Subtotal for Reporting Requirements

31.05

4. Recordkeeping requirements
A. Read instructions

See 3A

B. Plan activities d
C. Implement activities

Compliance coating records

See NOTE 1

108

5.4

10.8 $

10,102.15

1662

83.1

166.2 $

155,460.82

270

13.5

27 $

25,255.37

Control device maintenance or rolling material balance log (organics) N/A e
Control device maintenance log (inorganics)

N/A e

d, f

D. Develop record system
E. Time to enter/maintain information
Records of startup, shutdown, and malfunction

N/A e

Records of all measurements and information

See 4C

162

8.1

16.2 $

15,153.22

270

13.5
2842.8

27 $
$

25,255.37
231,227

2873.85

233,752

required by standard
F. Time to train personnel d, g
G. Time for audits h
Subtotal for Recordkeeping Requirements
TOTAL LABOR BURDEN AND COST (rounded)

We have assumed that there will be no net growth for the industry, only existing sources will read instructions.
We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating
operations.
d

We have assumed that all facilities will need to develop a record keeping system.

We have assumed one person per shift will require training on recordkeeping requirements and system.

We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

Table B2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations
at Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 2
Burden item

(A)

(B)

Person hours
per occurrence

1. Applications
2. Surveys and studies
3. Reporting requirements
A. Read instructions c, d
B. Required activities
Initial performance tests
Repeat performance test
C. Create information
D. Gather existing information
E. Write report
Notification of construction/reconstruction

Technical
person- hours
per year

Management
person hours per
year

(C x D)

(E x 0.05)

(H)

Clerical Total Cost Per
person
Year b
hours per
year
(E x 0.1)

N/A e
N/A e
N/A e

Compliance status information report

N/A e

Waiver application

N/A e

Startup, shutdown, malfunction plan

N/A e

Preparation of site-specific test plan

N/A e

Notification of initial performance test

N/A e

Report of initial test

N/A e

Startup, shutdown, malfunction report

N/A e

Semiannual report – including report of periods of noncompliance

N/A e
0
See 3A
N/A
27

See NOTE 1

1662

83.1

166.2 $

155,460.82

N/A e

Control device maintenance log (inorganics)

N/A e

D. Develop record system d, f
E. Time to enter/maintain information
Records of startup, shutdown, and malfunction

N/A

TOTAL LABOR BURDEN AND COST (rounded)

(G)

N/A e
See 4C
See 4C

Notification of change in production capacity

F. Time to train personnel d, g
G. Time for auditsh
Subtotal for Recordkeeping Requirements

(F)

N/A e

Records of all measurements and information
required by standard

No. of
Person hours per Respondents
occurrences
respondent per
per year a
per respondent
year
per year
(A x B)

(E)

N/A

Notification of actual startup

B. Plan activities d
C. Implement activities
Compliance coating records
Control device maintenance or rolling material balance log (organics)

(D)

N/A
N/A

Notification of physical and operational changes

Subtotal for Reporting Requirements
4. Recordkeeping requirements
A. Read instructions

(C)

N/A e
See 4C
N/A
10

270

13.5
2221.8
2221.8

$
27 $
$
$

25,255.37
180,716
180,716

Assumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.
Assumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04 per hour for Clerical labor. This ICR uses mean hourly wage for the
following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch
(NAICS code 999100): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 60 percent to account for the benefit
packages available to government employees.
c
We have assumed that there will be no net growth for the industry, only existing sources will read instructions.
d
We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating
operations.
e
We have assumed that all facilities will need to develop a record keeping system.
b

We have assumed one person per shift will require training on recordkeeping requirements and system.

We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

Table B3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations
at Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 3
Burden item

(A)

(B)

Person hours
per occurrence

Technical
person- hours
per year

Management
person hours per
year

(C x D)

(E x 0.05)

(H)

Clerical Total Cost Per
person
Year b
hours per
year
(E x 0.1)

N/A e

Notification of change in production capacity

N/A e

Compliance status information report

N/A e

Waiver application

N/A e

Startup, shutdown, malfunction plan

N/A e

Preparation of site-specific test plan

N/A e

Notification of initial performance test

N/A e

Report of initial test

N/A e

Startup, shutdown, malfunction report

N/A e

Semiannual report – including report of periods of noncompliance

N/A e
0
See 3A
N/A
27

See NOTE 1

1662

83.1

166.2 $

155,460.82

N/A e

Control device maintenance log (inorganics)

N/A e

D. Develop record system d, f
E. Time to enter/maintain information
Records of startup, shutdown, and malfunction

N/A

TOTAL LABOR BURDEN AND COST (rounded)

(G)

N/A e
See 4C
See 4C

N/A e

F. Time to train personnel d, g
G. Time for auditsh
Subtotal for Recordkeeping Requirements

(F)

N/A e

Records of all measurements and information
required by standard

Person hours per Respondents
No. of
respondent per
occurrences
per year a
per respondent
year
per year
(A x B)

(E)

N/A

Notification of actual startup

B. Plan activities d
C. Implement activities
Compliance coating records
Control device maintenance or rolling material balance log (organics)

(D)

N/A
N/A

Notification of physical and operational changes

Subtotal for Reporting Requirements
4. Recordkeeping requirements
A. Read instructions

(C)

N/A e
See 4C
N/A
10

270

13.5
2221.8
2221.8

$
27 $
$
$

25,255.37
180,716
180,716

We have assumed one person per shift will require training on recordkeeping requirements and system.

We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

Table C1. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Aerospace Specialty Coating Operations - Year 1
(A)
Number of
Occurrences
Per Year
Burden Item
1. Applications
2. Read and Understand Rule Requirements c, d

N/A
60

46.67

62.90

25.25

(B)
EPA
Hours
Per
Occurrence
(Tech Hours)

(D)
Management
Hours
Per Year
@$62.90
(D=Cx0.05)

(E)
Clerical
Hours
Per Year
@$25.25
(E=Cx0.1)

0
$4,065

(F)
EPA
Cost
Per Year (a, b)

3. Required Activities
A. Observe initial performance tests

N/A

B. Observe annual performance tests

N/A

Excess emissions -- Enforcement Activities

N/A

Create Information

N/A

Gather Information

N/A

Report Reviews
1)

Initial Notification d

0.5

Notification of Compliance Status d

0.5

109

$7,385
$11,450

3) Review annual and semiannual compliance report
4. Travel expenses:
TOTAL:

N/A
169

Total Hours

Labor

Non-Labor

Total

194

$11,450

We have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.
Assumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office of
Personnel Management (OPM), 2014 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. These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.
c
Assume that each State and EPA region reviews the rule and develops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10
Regions = 60 occurrences.
d
One-time only costs.
b

Table C2. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Aerospace Specialty Coating Operations - Year 2
(B)
EPA
Hours
Per
Occurrence
(Tech Hours)

47
(C)
Tech
Hours
Per Year
@$46.67
(C=AxB)

63
(D)
Management
Hours
Per Year
@$62.90
(D=Cx0.05)

25
(E)
Clerical
Hours
Per Year
@$25.25
(E=Cx0.1)

0.5

109

$7,385
$7,385

(A)
Number of
Occurrences
Per Year
Burden Item
1. Applications
2. Read and Understand Rule Requirements c, d

(F)
EPA
Cost
Per Year (a, b)

N/A
0

3. Required Activities
A. Observe initial performance tests

N/A

B. Observe annual performance tests

N/A

Excess emissions -- Enforcement Activities

N/A

Create Information

N/A

Gather Information

N/A

Report Reviews
1)

Initial Notification d

Notification of Compliance Status d
3) Review annual and semiannual compliance report
2)

4. Travel expenses:
TOTAL:

N/A
109

Total Hours

Labor

Non-Labor

Total

125

$7,385

We have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.

Assumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office of
Personnel Management (OPM), 2014 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. These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.
c

Assume that each State and EPA region reviews the rule and develops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10
Regions = 60 occurrences.
d
One-time only costs.

Table C3. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements
of Aerospace Specialty Coating Operations - Year 3
(B)
EPA
Hours
Per
Occurrence
(Tech Hours)

47
(C)
Tech
Hours
Per Year
@$46.67
(C=AxB)

63
(D)
Management
Hours
Per Year
@$62.90
(D=Cx0.05)

25
(E)
Clerical
Hours
Per Year
@$25.25
(E=Cx0.1)

0.5

109

$7,385
$7,385

(A)
Number of
Occurrences
Per Year
Burden Item
1. Applications
2. Read and Understand Rule Requirements c, d

N/A
0

(F)
EPA
Cost
Per Year (a, b)

3. Required Activities
A. Observe initial performance tests

N/A

B. Observe annual performance tests

N/A

Excess emissions -- Enforcement Activities

N/A

Create Information

N/A

Gather Information

N/A

Report Reviews
1)

Initial Notification d

Notification of Compliance Status d
3) Review annual and semiannual compliance report
2)

4. Travel expenses:
TOTAL:

N/A
109

Total Hours

Labor

Non-Labor

Total

125

$7,385

File Type	application/pdf
File Title	Microsoft Word - Aerospace RTR Supporting Statement_Final_01222015.docx
Author	JShweky
File Modified	2015-01-22
File Created	2015-01-22