Burden Calculations Table

---

Overview

Summary
Table 1a
Table 1b
Table 1c
Table 1d
Table 1e
Table 2a
Table 2b
Table 2c
Table 2d
Table 2e
Table 3
Capital O&M
Responses
Respondents

---

Sheet 1: Summary

ICR Summary Information
Hours per Response	191 hours per response for privately-owned facilities; 193 hours per response for Federal government-owned facilities
Number of Respondents	144
Total Estimated Burden Hours	154,000
Total Estimated Costs	$16,800,000
Annualized Capital O&M	$224,000
Total Annual Responses	805
Form Number	Not Applicable

---

Sheet 2: Table 1a

Table 1a: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Cleaning Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarize with regulatory requirements c	1	1	1	108	108	5.4	10.8	$15,661.03		Clerical	$65.71
B. Required activities	N/A
C. Create information	See 3E & 4C
D. Gather existing information	See 3E & 4C
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical and operational changes d	8	1	8	5	40	2	4	$5,800.38
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of change in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report e	20	1	20	108	2,160	108	216	$313,220.52
Waiver application f	4	1	4	11	44	2.2	4.4	$6,380.42
Preparation of site-specific test plan	N/A
Notification of initial performance test	N/A
Report of initial test	N/A
Semiannual report – including report of periods of noncompliance g	12	2	24	86	2,064	103.2	206.4	$299,299.61
Subtotal for Reporting Requirements					5,078			$640,362
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	4	1	4	108	432	21.6	43.2	$62,644.10
C. Implement activities
Solvent information records	4	2	8	108	864	43.2	86.4	$125,288.21
Approved composition solvent records (demonstrating compliance) h	4	1	4	32	128	6.4	12.8	$18,561.22
Non-approved list solvent usage records i	1	12	12	97	1,164	58.2	116.4	$168,791.06
Solvent usage log for exempt processes j	0.5	12	6	76	456	22.8	45.6	$66,124.33
Log of gun cleaner leaks k	1	6	6	22	132	6.6	13.2	$19,141.25
D. Develop record system l	20	1	20	108	2,160	108	216	$313,220.52
E. Time to enter information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel m	4	50	200	108	21,600	1,080	2,160	$3,132,205.20
G. Time for audits	20	1	20	108	2,160	108	216	$313,220.52
Subtotal for Recordkeeping Requirements					33,460			$4,219,196
TOTAL LABOR BURDEN AND COSTS (rounded) n					38,500			$4,860,000
TOTAL CAPITAL AND O&M COST (rounded) n, o								$168,000
GRAND TOTAL (rounded) n								$5,030,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d We have assumed that 5 percent of the total existing facilities will write the physical and operational changes report (108 x 5% = 5.4, rounded to 5).
e We have assumed that each respondent will write compliance status information report.
f We have assumed that 10 percent of the respondents will request a waiver (108 x 10% = 10.8, rounded to 11).
g We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (108 x 80% = 86.4, rounded to 86).
h We have assumed that 30 percent of facilities will use the approved list of solvents (108 x 30% = 32.4, rounded to 32).
i We have assumed that 90 percent of facilities will use some solvents not on the approved list (108 x 90% = 97.2, rounded to 97).
j We have assumed that 70 percent of facilities will use some solvents for exempt processes (108 x 70% = 75.6, rounded to 76).
k We have assumed that 20 percent of facilities will have a leak in their enclosed gun cleaner (108 x 20% = 21.6, rounded to 22).
l We have assumed that all facilities will need to develop a record keeping system.
m We have assumed that each respondent will take 4 hours 50 times per year to complete task.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
o The total capital and O&M cost in this table are the total for cleaning, coating, depainting and specialty coating operations combined (see Tables 1b-1d for burden associated with these operations).

---

Sheet 3: Table 1b

Table 1b: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Coating Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarize with regulatory requirements c	1	1	1	108	108	5.4	10.8	$15,661.03		Clerical	$65.71
B. Required activities
Initial performance tests d	280	1	280	3	840	42	84	$121,807.98
Repeat performance test e	280	1	280	1	280	14	28	$40,602.66
C. Create information	See 3E & 4C
D. Gather existing information	See 3E & 4C
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical and operational changes f	8	1	8	5	40	2	4	$5,800.38
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of change in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report k	10	1	10	108	1,080	54	108	$156,610.26
Waiver application g	4	1	4	11	44	2.2	4.4	$6,380.42
Preparation of site-specific test plan	See 3B
Notification of initial performance test d	2	1	2	3	6	0.3	0.6	$870.06
Report of initial test	See 3B
Annual and semiannual report – including report of periods of noncompliance h	11	2	22	86	1,892	94.6	189.2	$274,357.97
Subtotal for Reporting Requirements					4,934			$622,091
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	4	1	4	108	432	21.6	43.2	$62,644.10
C. Implement activities
Compliance coating records	1	12	12	108	1,296	64.8	129.6	$187,932.31
Daily records of weighted average mass i	1	250	250	11	2,750	137.5	275	$398,776.13
Control device maintenance or rolling material balance log (organics) d	0.5	250	125	3	375	18.75	37.5	$54,378.56
Control device maintenance log (inorganics)	0.25	250	62.5	108	6,750	337.5	675	$978,814.13
D. Develop record system j	10	1	10	108	1,080	54	108	$156,610.26
E. Time to enter/maintain information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel	8	50	400	108	43,200	2,160	4,320	$6,264,410.40
G. Time for audits	20	1	20	108	2,160	108	216	$313,220.52
Subtotal for Recordkeeping Requirements					66,749			$8,416,786
TOTAL LABOR BURDEN AND COSTS (rounded) l					71,700			$9,040,000
TOTAL CAPITAL AND O&M COST (rounded) l, m								$0
GRAND TOTAL (rounded) l								$9,040,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d We assume that 3 privately-owned facilities will use add-on control equipment for maskant application.
e We have assumed that 20% of privately-owned facility with add-on control equipment will repeat performance test (3 x 20% = 0.6, rounded to 1).
f We have assumed that 5 percent of the total existing facilities will write the physical and operational changes report (108 x 5% = 5.4, rounded to 5).
g We have assumed that 10 percent of the respondents will request a waiver (108 x 10% = 10.8, rounded to 11).
h We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (108 x 80% = 86.4, rounded to 86).
i The final rule required monthly records. Daily averaging was included in the cost analysis because 90 percent of the industry is located in non-attainment areas and will be required to use daily averaging by the permitting agency.
j We have assumed that all facilities will need to develop a record keeping system.
k We have assumed that each respondent will write compliance status information report.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
m The capital and O&M cost for this operation has be included in the table for cleaning operations (see Table 1a).

---

Sheet 4: Table 1c

Table 1c: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Depainting Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarize with regulatory requirements c	1	1	1	4	4	0.2	0.4	$580.04		Clerical	$65.71
B. Required activities	N/A
Initial performance tests	280	1	280	0	0	0	0	$0
Repeat performance test	280	1	280	0	0	0	0	$0
C. Create information	See 3E & 4C
D. Gather existing information	See 3E & 4C
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical and operational changes	8	1	8	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of change in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report g	10	1	10	4	40	2	4	$5,800.38
Waiver application	4	1	4	0	0	0	0	$0
Preparation of site-specific test plan	N/A
Notification of initial performance test	2	1	2	0	0	0	0	$0
Report of initial test	See 3B
Annual and semiannual report – including report of periods of noncompliance d	12	2	24	3	72	3.6	7.2	$10,440.68
Subtotal for Reporting Requirements					133			$16,821
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	4	1	4	4	16	0.8	1.6	$2,320.15
C. Implement activities e
Chemical stripper records (demonstrating compliance)	8	1	8	3	24	1.2	2.4	$3,480.23
Chemical stripper usage log	1	12	12	3	36	1.8	3.6	$5,220.34
Depainting equipment malfunction log	4	3	12	2	24	1.2	2.4	$3,480.23
Exempt stripper usage log and reworked airplane log spot stripping and decal removal	1	12	12	4	48	2.4	4.8	$6,960.46
Record of parts removed for parts depainting	8	2	16	4	64	3.2	6.4	$9,280.61
Control device maintenance log	0.5	250	125	2	250	12.5	25	$36,252.38
D. Develop record system f	10	1	10	4	40	2	4	$5,800.38
E. Time to enter information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel	4	1	4	4	16	0.8	1.6	$2,320.15
G. Time for audits	10	1	10	4	40	2	4	$5,800.38
Subtotal for Recordkeeping Requirements					642			$80,915
TOTAL LABOR BURDEN AND COSTS (rounded) h					775			$97,700
TOTAL CAPITAL AND O&M COST (rounded) h, i								$0
GRAND TOTAL (rounded) h								$97,700
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR. Of the 144 facilites we assume 4 privately-owned facilities and 1 Federally-owned facility will have depainting operations.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (4 x 80% = 3.2, rounded to 3).
e We have assumed that 1 percent of facilities will use HAP containing chemical strippers as the primary stripping techniques, 29 percent will use media blasting equipment, 70 percent will use non-HAP chemical strippers, and 100 percent of facilities will use some HAP stripper for exempt processes.
f We have assumed that all respondents will need to develop a record keeping system.
g We have assumed that each respondent will write compliance status information report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
i The capital and O&M cost for this operation has be included in the table for cleaning operations (see Table 1a).

---

Sheet 5: Table 1d

Table 1d: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Specialty Coating Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications										Labor Rates
2. Surveys and studies										Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarize with regulatory requirements c	1	1	1	82	82	4.1	8.2	$11,890.78		Clerical	$65.71
B. Required activities
Initial performance tests	N/A
Repeat performance test	N/A
C. Create information	See 4C
D. Gather existing information	See 4C
E. Write report e
Notification of construction/reconstruction	N/A
Notification of physical and operational changes	N/A
Notification of actual startup	N/A
Notification of change in production capacity	N/A
Compliance status information report	N/A
Waiver application	N/A
Preparation of site-specific test plan	N/A
Notification of initial performance test	N/A
Report of initial test	N/A
Annual and semiannual report – including report of periods of noncompliance	N/A
Subtotal for Reporting Requirements					94			$11,891
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities d	4	1	4	0	0	0	0	$0
C. Implement activities
Compliance coating records f	30.5	1	30.5	82	2,501	125.05	250.1	$362,668.76
Control device maintenance or rolling material balance log (organics) e	N/A
Control device maintenance log (inorganics) e	N/A
D. Develop record system d	10	1	10	0	0	0	0	$0
E. Time to enter information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel d, g	2	3	6	0	0	0	0	$0
G. Time for audits h	10	1	10	82	820	41	82	$118,907.79
Subtotal for Recordkeeping Requirements					3,819			$481,577
TOTAL LABOR BURDEN AND COSTS (rounded) i					3,910			$493,000
TOTAL CAPITAL AND O&M COST (rounded) i, j								$0
GRAND TOTAL (rounded) i								$493,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR. Of the 144 facilities we assume 82 privately-owned facilities and 27 Federally-owned facilities will have specialty coating operations.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d One-time cost that is only incurred during the first year of compliance.
e 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.
f These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. The 2015 amendment provides a separate worksheet which breaks down the assumed number of specialty coatings by facility based on 2011 ICR survey responses. This ICR averages the hours over the 82 facilities to get ~30.5 person hours per occurence.
g We have assumed one person per shift will require training on recordkeeping requirements and system.
h 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.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
j The capital and O&M cost for this operation has be included in the table for cleaning operations (see Table 1a).

---

Sheet 6: Table 1e

Table 1e: Summary of Annual Respondent Burden and Cost for Tables 1a, 1b, 1c, & 1d – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal)
Burden	Burden Hours per Year for Reporting	Burden Hours per Year for Recordkeeping	Total Burden Hours per Year (rounded) a	Total Annual Labor Costs ($) (rounded) a	Total Annual Costs ($) (rounded) a, b
1a. Cleaning Operations	5,078	33,460	38,500	$4,860,000	$5,030,000
1b. Coating Operations	4,934	66,749	71,700	$9,040,000	$9,040,000
1c. Depainting Operations	133	642	775	$97,700	$97,700		responses	hr/response
1d. Specialty Coating Operations	94	3,819	3,910	$493,000	$493,000		602	191.029900332226
Total Burden and Costs (rounded)	10,200	105,000	115,000	$14,500,000	$14,700,000
Assumptions:
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
b The total annual costs includes both labor and capital and O&M costs

---

Sheet 7: Table 2a

Table 2a: Annual Burden and Cost for Federal Government-Owned Facilities – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Cleaning Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$73.46
3. Reporting requirements										Technical	$54.51
A. Familiarize with regulatory requirements c	1	1	1	36	36	1.8	3.6	$2,200.79		Clerical	$29.50
B. Required activities	N/A
C. Create information	See 3E & 4C
D. Gather existing information	See 3E & 4C
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical and operational changes d	8	1	8	2	16	0.8	1.6	$978.13
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of change in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report e	20	1	20	36	720	36	72	$44,015.76
Waiver application f	4	1	4	4	16	0.8	1.6	$978.13
Preparation of site-specific test plan	N/A
Notification of initial performance test	N/A
Report of initial test	N/A
Semiannual report – including report of periods of noncompliance g	12	2	24	29	696	34.8	69.6	$42,548.57
Subtotal for Reporting Requirements					1,707			$90,721
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	4	1	4	36	144	7.2	14.4	$8,803.15
C. Implement activities
Solvent information records	4	2	8	36	288	14.4	28.8	$17,606.30
Approved composition solvent records (demonstrating compliance) h	4	1	4	11	44	2.2	4.4	$2,689.85
Non-approved list solvent usage records i	1	12	12	32	384	19.2	38.4	$23,475.07
Solvent usage log for exempt processes j	0.5	12	6	25	150	7.5	15	$9,169.95
Log of gun cleaner leaks k	1	6	6	7	42	2.1	4.2	$2,567.59
D. Develop record system l	20	1	20	36	720	36	72	$44,015.76
E. Time to enter information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel m	4	50	200	36	7,200	360	720	$440,157.60
G. Time for audits	20	1	20	36	720	36	72	$44,015.76
Subtotal for Recordkeeping Requirements					11,146			$592,501
TOTAL LABOR BURDEN AND COSTS (rounded) n					12,900			$683,000
TOTAL CAPITAL AND O&M COST (rounded) n, o								$55,900
GRAND TOTAL (rounded) n								$739,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d We have assumed that 5 percent of the total existing facilities will write the physical and operational changes report (36 x 5% = 1.8, rounded to 2).
e We have assumed that each respondent will write compliance status information report.
f We have assumed that 10 percent of the respondents will request a waiver (36 x 10% = 3.6, rounded to 4).
g We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (36 x 80% = 28.8, rounded to 29).
h We have assumed that 30 percent of facilities will use the approved list of solvents (36 x 30% = 10.8, rounded to 11).
i We have assumed that 90 percent of facilities will use some solvents not on the approved list (36 x 90% = 32.4, rounded to 32).
j We have assumed that 70 percent of facilities will use some solvents for exempt processes (36 x 70% = 25.2, rounded to 25).
k We have assumed that 20 percent of facilities will have a leak in their enclosed gun cleaner (36 x 20% = 7.2, rounded to 7).
l We have assumed that all facilities will need to develop a record keeping system.
m We have assumed that each respondent will take 4 hours 50 times per year to complete task.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
o The total capital and O&M cost in this table are the total for cleaning, coating, depainting and specialty coating operations combined (see Tables 1b-1d for burden associated with these operations).

---

Sheet 8: Table 2b

Table 2b: Annual Burden and Cost for Federal Government-Owned Facilities – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Coating Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$73.46
3. Reporting requirements										Technical	$54.51
A. Familiarize with regulatory requirements c	1	1	1	36	36	1.8	3.6	$2,200.79		Clerical	$29.50
B. Required activities
Initial performance tests d	280	1	280	1	280	14	28	$17,117.24
Repeat performance test e	280	1	280	0	0	0	0	$0
C. Create information	See 3E & 4C
D. Gather existing information	See 3E & 4C
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical and operational changes f	8	1	8	2	16	0.8	1.6	$978.13
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of change in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report k	10	1	10	36	360	18	36	$22,007.88
Waiver application g	4	1	4	4	16	0.8	1.6	$978.13
Preparation of site-specific test plan	See 3B
Notification of initial performance test d	2	1	2	1	2	0.1	0.2	$122.27
Report of initial test	See 3B
Annual and semiannual report – including report of periods of noncompliance h	11	2	22	29	638	31.9	63.8	$39,002.85
Subtotal for Reporting Requirements					1,550			$82,407
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	4	1	4	36	144	7.2	14.4	$8,803.15
C. Implement activities
Compliance coating records	1	12	12	36	432	21.6	43.2	$26,409.46
Daily records of weighted average mass i	1	250	250	4	1,000	50	100	$61,133.00
Control device maintenance or rolling material balance log (organics) d	0.5	250	125	1	125	6.25	12.5	$7,641.63
Control device maintenance log (inorganics)	0.25	250	62.5	36	2,250	112.5	225	$137,549.25
D. Develop record system j	10	1	10	36	360	18	36	$22,007.88
E. Time to enter/maintain information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel	8	50	400	36	14,400	720	1,440	$880,315.20
G. Time for audits	20	1	20	36	720	36	72	$44,015.76
Subtotal for Recordkeeping Requirements					22,346			$1,187,875
TOTAL LABOR BURDEN AND COSTS (rounded) l					23,900			$1,270,000
TOTAL CAPITAL AND O&M COST (rounded) l, m								$0
GRAND TOTAL (rounded) l								$1,270,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d We assume that 1 Federally-owned facility will use add-on control equipment for maskant application.
e We have assumed that 20% of Federally-owned facility with add-on control equipment will repeat performance test (1 x 20% = 0.2, rounded to 0).
f We have assumed that 5 percent of the total existing facilities will write the physical and operational changes report (36 x 5% = 1.8, rounded to 2).
g We have assumed that 10 percent of the respondents will request a waiver (36 x 10% = 3.6, rounded to 4).
h We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (36 x 80% = 28.8, rounded to 29).
i The final rule required monthly records. Daily averaging was included in the cost analysis because 90 percent of the industry is located in non-attainment areas and will be required to use daily averaging by the permitting agency.
j We have assumed that all facilities will need to develop a record keeping system.
k We have assumed that each respondent will write compliance status information report.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
m The capital and O&M cost for this operation has be included in the table for cleaning operations (see Table 1a).

---

Sheet 9: Table 2c

Table 2c: Annual Burden and Cost for Federal Government-Owned Facilities – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Depainting Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$73.46
3. Reporting requirements										Technical	$54.51
A. Familiarize with regulatory requirements c	1	1	1	1	1	0.05	0.1	$61.13		Clerical	$29.50
B. Required activities	N/A
Initial performance tests	280	1	280	0	0	0	0	$0
Repeat performance test	280	1	280	0	0	0	0	$0
C. Create information	See 3E & 4C
D. Gather existing information	See 3E & 4C
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical and operational changes	8	1	8	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of change in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report g	10	1	10	1	10	0.5	1	$611.33
Waiver application	4	1	4	0	0	0	0	$0
Preparation of site-specific test plan	N/A
Notification of initial performance test	2	1	2	0	0	0	0	$0
Report of initial test	See 3B
Annual and semiannual report – including report of periods of noncompliance d	12	2	24	1	24	1.2	2.4	$1,467.19
Subtotal for Reporting Requirements					40			$2,140
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	4	1	4	1	4	0.2	0.4	$244.53
C. Implement activities e
Chemical stripper records (demonstrating compliance)	8	1	8	1	8	0.4	0.8	$489.06
Chemical stripper usage log	1	12	12	1	12	0.6	1.2	$733.60
Depainting equipment malfunction log	4	3	12	0	0	0	0	$0
Exempt stripper usage log and reworked airplane log spot stripping and decal removal	1	12	12	1	12	0.6	1.2	$733.60
Record of parts removed for parts depainting	8	2	16	1	16	0.8	1.6	$978.13
Control device maintenance log	0.5	250	125	0	0	0	0	$0
D. Develop record system f	10	1	10	1	10	0.5	1	$611.33
E. Time to enter information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel	4	1	4	1	4	0.2	0.4	$244.53
G. Time for audits	10	1	10	1	10	0.5	1	$611.33
Subtotal for Recordkeeping Requirements					87			$4,646
TOTAL LABOR BURDEN AND COSTS (rounded) h					128			$6,790
TOTAL CAPITAL AND O&M COST (rounded) h, i								$0
GRAND TOTAL (rounded) h								$6,790
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR. Of the 144 facilites we assume 4 privately-owned facilities and 1 Federally-owned facility will have depainting operations.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (1 x 80% = 0.8, rounded to 1).
e We have assumed that 1 percent of facilities will use HAP containing chemical strippers as the primary stripping techniques, 29 percent will use media blasting equipment, 70 percent will use non-HAP chemical strippers, and 100 percent of facilities will use some HAP stripper for exempt processes.
f We have assumed that all respondents will need to develop a record keeping system.
g We have assumed that each respondent will write compliance status information report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
i The capital and O&M cost for this operation has be included in the table for cleaning operations (see Table 1a).

---

Sheet 10: Table 2d

Table 2d: Annual Burden and Cost for Federal Government-Owned Facilities – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal) (Specialty Coating Operations)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Applications										Labor Rates
2. Surveys and studies										Management	$73.46
3. Reporting requirements										Technical	$54.51
A. Familiarize with regulatory requirements c	1	1	1	27	27	1.35	2.7	$1,650.59		Clerical	$29.50
B. Required activities
Initial performance tests	N/A
Repeat performance test	N/A
C. Create information	See 4C
D. Gather existing information	See 4C
E. Write report e
Notification of construction/reconstruction	N/A
Notification of physical and operational changes	N/A
Notification of actual startup	N/A
Notification of change in production capacity	N/A
Compliance status information report	N/A
Waiver application	N/A
Preparation of site-specific test plan	N/A
Notification of initial performance test	N/A
Report of initial test	N/A
Annual and semiannual report – including report of periods of noncompliance	N/A
Subtotal for Reporting Requirements					31			$1,651
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities d	4	1	4	0	0	0	0	$0
C. Implement activities
Compliance coating records f	61.6	1	61.6	27	1,663.2	83.16	166.32	$101,676.41
Control device maintenance or rolling material balance log (organics) e	N/A
Control device maintenance log (inorganics) e	N/A
D. Develop record system d	10	1	10	0	0	0	0	$0
E. Time to enter information
Records of all measurements and information required by standard	See 4C
F. Time to train personnel d, g	2	3	6	0	0	0	0	$0
G. Time for audits h	10	1	10	27	270	13.5	27	$16,505.91
Subtotal for Recordkeeping Requirements					2,223			$118,182
TOTAL LABOR BURDEN AND COSTS (rounded) i					2,250			$120,000
TOTAL CAPITAL AND O&M COST (rounded) i, j								$0
GRAND TOTAL (rounded) i								$120,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR. Of the 144 facilities we assume 82 privately-owned facilities and 27 Federally-owned facilities will have specialty coating operations.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed all existing sources will have to re-familiarize with regulatory requirements each year.
d One-time cost that is only incurred during the first year of compliance.
e 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.
f These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. The 2015 amendment provides a separate worksheet which breaks down the assumed number of specialty coatings by facility based on 2011 ICR survey responses. This ICR averages the hours over the 27 facilities to get ~61.6 person hours per occurrence.
g We have assumed one person per shift will require training on recordkeeping requirements and system.
h 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.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
j The capital and O&M cost for this operation has be included in the table for cleaning operations (see Table 1a).

---

Sheet 11: Table 2e

Table 2e: Summary of Annual Burden and Cost for Federal Government-Owned Facilities for Tables 2a, 2b, 2c, & 2d – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal)
Burden	Burden Hours per Year for Reporting	Burden Hours per Year for Recordkeeping	Total Burden Hours per Year (rounded) a	Total Annual Labor Costs ($) (rounded) a	Total Annual Costs ($) (rounded) a, b
2a. Cleaning Operations	1,707	11,146	12,900	$683,000	$739,000
2b. Coating Operations	1,550	22,346	23,900	$1,270,000	$1,270,000
2c. Depainting Operations	40	87	128	$6,790	$6,790
2d. Specialty Coating Operations	31	2,223	2,250	$120,000	$120,000
Total Burden and Costs (rounded)	3,330	35,800	39,200	$2,080,000	$2,140,000		193.103448275862	hr/response
Assumptions:
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
b The total annual costs includes both labor and capital and O&M costs

---

Sheet 12: Table 3

Table 3: Average Annual EPA Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) Person hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost Per Year b
1. Initial performance test	80	1	80	4	320	16	32	$19,562.56		Labor Rates
2. Repeat performance test										Management	$73.46
Retesting preparation c	16	1	16	1	16	0.8	1.6	$978.13		Technical	$54.51
Retesting d	80	1	80	1	80	4	8	$4,890.64		Clerical	$29.50
3. Report review
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of physical or operational changes e	2	1	2	14	28	1.4	2.8	$1,711.72
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of changes in production capacity	2	1	2	0	0	0	0	$0
Compliance status information report f	6	1	6	293	1,758	87.9	175.8	$107,471.81
Waiver application g	6	1	6	30	180	9	18	$11,003.94
Review of site specific test plan	N/A
Notification of initial performance test h	2	1	2	4	8	0.4	0.8	$489.06
4. Report review
Report of initial test	8	1	8	0	0	0	0	$0
Review of annual and semiannual reports i	3	2	6	234	1,404	70.2	140.4	$85,830.73
TOTAL (rounded) j					4,360			$232,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 144. Of the 144 respondents, 108 are privately-owned and 36 are Federally-owned. There will be no new additional sources during the next three years of this ICR.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that it will take 16 hours to prepare for retesting.
d We have assumed that 20 percent of respondents will fail the initial performance test and will have to be retested.
e We have assumed that it will take two hours once per year to review the notification of physical or operational change.
f We have assumed that it will take six hours to review the compliance status information report.
g We have assumed that the Agency will take 6 hours to review the waiver application for each facility.
h We have assumed that it will take 2 hours to review the notice of initial performance test.
i We have assumed that it will take 3 hours to review each semiannual report.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 13: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M b	Total O&M, (E X F)
Privately-Owned Facilities									2007 Average CEPCI	2022 CEPCI
CEM a	$21,743	0	$0	$1,553	108	$167,735			525.4	816
Total (rounded) b			$0			$168,000
Federal Government-Owned Facilities
CEM a	$21,743	0	$0	$1,553	36	$55,912
Total (rounded) b			$0			$55,900		$224,000
a Costs have been increased from 2007 to 2022 $ using the CEPCI Equipment Cost Index.
b Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

---

Sheet 14: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Privately-owned facilities
Notification of construction/reconstruction	0	1	0	0
Notification of physical and operational changes	10	1	0	10
Notification of actual startup	0	1	0	0
Notification of change in production capacity	0	1	0	0
Compliance status information report	220	1	0	220
Waiver application	22	1	0	22
Semiannual report – including report of periods of noncompliance	175	2	0	350
Subtotal				602
Federal government-owned facilities
Notification of construction/reconstruction	0	1	0	0
Notification of physical and operational changes	4	1	0	4
Notification of actual startup	0	1	0	0
Notification of change in production capacity	0	1	0	0
Compliance status information report	73	1	0	73
Waiver application	8	1	0	8
Semiannual report – including report of periods of noncompliance	59	2	0	118
Subtotal				203
			Total	805

---

Sheet 15: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	144	0	0	144
2	0	144	0	0	144
3	0	144	0	0	144
Average	0	144	0	0	144
a New respondents include sources with constructed, reconstructed, and modified affected facilities.