SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) 

(Renewal), EPA ICR Number 2025.06, OMB Control Number 2060-0481.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Friction 

Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ), were proposed on October 4, 

2001, (66 FR 50768) and promulgated on October 18, 2002 (67 FR 64506). These regulations 

apply to existing facilities and new facilities. New facilities include those that commenced 

construction or reconstruction after the date of proposal. 

A friction materials manufacturing facility is only subject to the regulation if it is a major 

source of hazardous air pollutant (HAP) emissions and emits, or has the potential to emit, any

single HAP at a rate of 9.07 megagrams (10 tons) or more per year or any combination of HAPs

at a rate of 22.68 megagrams (25 tons) or more per year. Consistent with the General Provisions 

(40 CFR Part 63, Subpart A), respondents do not include the owner or operator of any facility 

that is not a major source of HAP emissions or any facility that does not operate affected solvent 

mixers, even if the facility is a major source. This information is being collected to assure 

compliance with 40 CFR Part 63, Subpart QQQQQ.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

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

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U.S.

Environmental Protection Agency (EPA) regional office.

Approximately four respondents are currently subject to the regulation, and it is 

estimated that no additional respondents per year will become subject to the regulation in the 

next three years.
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The Office of Management and Budget (OMB) approved the currently active ICR 

without any Terms of Clearance.

Respondents are owners or operators of each new, reconstructed, or existing affected 

source. The NESHAP contains an emission limitation for solvent mixers at friction materials 

manufacturing facilities. Solvent mixers are the affected source. Friction materials 

manufacturing facilities manufacture friction material using a solvent-based process. Friction 

material is subsequently used to manufacture friction products that include, but are not limited to, 

disc brake pucks, disc brake pads, brake linings, brake shoes, brake segments, brake blocks, 

brake discs, clutch facings, and clutches. 

There are four friction materials manufacturing facilities in the United States, which are 

owned and operated by the friction material manufacturing industry. None of the four facilities 

in the United States are owned by state, local, tribal, or the Federal government. They are owned 

and operated by privately owned, for-profit businesses. The “burden” to the “Affected Public” 

may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Friction 

Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal). The “burden” to the 

Federal Government is attributed entirely to work performed by either Federal employees or 

government contractors and can be found below in Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) 

(Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from solvent mixers either cause or 
3

contribute to air pollution that may reasonably be anticipated to endanger public health and/or 

welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63,

Subpart QQQQQ.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. The 

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

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

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

ensure compliance with the standard 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 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, that leaks are being detected and repaired, and the standard is being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures, and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

QQQQQ.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.
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3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

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

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

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted the Motor and Equipment Manufacturers Association (MEMA) at (202) 

393-6362, and Dynax America Corporation at (540) 966-6010. 

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

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

notice. In this case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent the 

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

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

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 
5

action. EPA has found that the most flagrant violators have violations extending beyond five 

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

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency, for which a claim of confidentiality is made,

will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, 

Subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in 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 friction materials 

manufacturing facilities. The United States Standard Industrial Classification (SIC) codes for the 

respondents affected by the standards and their corresponding North American Industry

Classification System (NAICS) codes are listed below.

Standard (40 CFR Part 63, Subpart QQQQQ) SIC 

Codes

NAICS 

Codes

Motor Vehicle Brake System Manufacturing 3714 336340

All Other Miscellaneous Nonmetallic Mineral Product Manufacturing 3299 327999

Mechanical Power Transmission Equipment Manufacturing 3568 333613

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ).

A source must make the following reports:

Notifications
6

Notifications

Initial notifications, including construction/reconstruction 63.9535(a-d), 63.05, 63.09(b) 

Notification of compliance status 63.9535(e), 63.09(h)

Performance of sludge test and determine mercury 

emissions. 61.54(a), (c-e)

Reports

Semiannual compliance report on startup, shutdown, and 

malfunction

63.9540(b)(4) and (d), 

63.10(d)(5)

Semiannual compliance report on no deviations 63.9540(b)(5-6)

Annual report on deviations 63.9540(c)

A source must keep the following records:

Recordkeeping

Maintain records of all reports and notifications 63.9550, 63.10(b)(1)

Maintain records for initial notification and notification of 

compliance status

63.9545(a)(1), 63.10(b)(xiv)

Maintain records related to startup, shutdown or malfunction 63.9545(1)(2)

Monitor records showing solvent mixers meeting the 

emission limitation

63.9530, 63.9545(b), 

63.10(b)(2)(vi), (x-xi)

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
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Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate solvent mixers at friction material manufacturing 

facility.

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.

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.

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 
8

Agency Activities

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

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

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

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

emission standard. Data and records maintained by the respondents are tabulated and published 

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

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

determinations.

Information contained in the reports is 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

The majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The EPA considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Friction Materials 

Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal).
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6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, 

a collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 1,291 (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Monitoring 

Control 

Device

$2,139 0 $0 $272 4 $1,088

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $1,088. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $1,088. These are recordkeeping 

costs. 

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$2,680. 

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

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

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

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

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

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

Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately
11

four existing respondents will be subject to the standard. It is estimated that no additional 

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

the table below, is four per year.

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

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1

0 4 0 0 4

2

0 4 0 0 4

3

0 4 0 0 4

Average 0 4 0 0 4

1

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

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

average Number of Respondents over the three year period of this ICR is four. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of applicability 0 1 N/A 0

Notification of 

construction/reconstruction 0 1 N/A 0

Notification of anticipated 

startup 0 1 N/A 0

Notification of actual startup 0 1 N/A 0

Notification of compliance 

status 0 1 N/A 0
12

Total Annual Responses

Annual report of deviation 0.6 1 N/A 0.6

Semiannual report with no

deviation 3.4 2 N/A 6.8

Unplanned startup, shutdown, 

malfunction report 0.4 2 N/A 0.8

Total (rounded) 8

The number of Total Annual Responses is eight. 

The total annual labor costs are $126,414. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Friction Materials 

Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 1,291. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Friction Materials 

Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal). 

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

information is estimated to average 162 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,088. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 59 

labor hours at a cost of $2,680. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal). 

6(f) Reasons for Change in Burden

There is a small decrease in the total estimated burden as currently identified in the OMB 

Inventory of Approved Burdens. This decrease is due to a discrepancy identified in the previous 

ICR. The previous ICR assumed all existing plants transmit one-time notifications, a burden 
13

item that applies to new sources only. Since no new sources are expected over the next threeyear period of the ICR, the ICR was revised to remove this burden, which resulted in a decrease 

in burden hours. 

There is also an increase in the estimated burden cost due to the use of updated labor 

rates. This ICR references the most recent labor rates available from the Bureau of Labor 

Statistics and OPM to calculate burden costs.

6(g) Burden Statement

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

is estimated to average 162 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

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

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

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

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

Docket ID Number EPA-HQ-OECA-2014-0085. 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) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0085 and OMB Control Number 2060-0481 in any

correspondence. 

Part B of the Supporting Statement
14

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

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart 

QQQQQ) (Renewal)

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 

personhours

per year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person hours 

per year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, installation and 

utilization of technology and 

systems

54 1 54 0 0 0 0 $0

 4. Reporting requirements

 A. Read instructions 0.5 1 0.5 0 0 0 0 $0

 B. Required activities

Startup, shutdown, malfunction 

plan

32 1 32 0 0 0 0 $0

 C. Create information See 4B

 D. Gather existing information See 4E

 E. Write Report

Notification of applicability 2 1 2 0 0 0 0 $0

Notification of 

construction/reconstruction 

2 1 2 0 0 0 0 $0

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 compliance 

status

4 1 4 0 0 0 0 $0

Annual report of deviation c8 1 8 0.6 4.8 0.24 0.48 $540.42

Semiannual report of no 

deviation d

8 2 16 3.4 54.4 2.72 5.44 $6,124.79

Startup, shutdown, malfunction 

report e

8 2 16 0.4 6.4 0.32 0.64 $720.56

Subtotal for Reporting Requirements 75 $7,386
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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 

personhours

per year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person hours 

per year

(Ex0.1)

(H)

Cost, $ b

5. Recordkeeping requirements

 A. Read instructions 4 1 4 0 0 0 0 $0

 B. Plan activities See 5E

 C. Implement activities See 5E

 D. Develop record system See 5E

 E. Time to enter information 

Records of solvent weight 

measurements f

0.033 2,600 85.8 4 343.2 17.16 34.32 $38,640.2

Records of block average 

solvent weight g

2 52 104 4 416 20.8 41.6 $46,836.61

Records of startup, shutdown, 

malfunction g

1 52 52 4 208 10.4 20.8 $23,418.30

Copies of notifications/reports h0.25 5 1.25 4 5 0.25 0.5 $562.94

 F. Time to train personnel i20 1 20 4 80 4 8 $9,007.04

G. Time to transmit or disclose

information h

0.25 5 1.25 4 5 0.25 0.5 $562.94

 H. Time to audit N/A

Subtotals for Recordkeeping Requirements 1,216 $119,028

TOTAL LABOR BURDEN AND COST (rounded) 1,291 $126,414

Assumptions:

a

 We have assumed that there are 4 existing sources, and that no additional new or reconstructed sources will become subject to the rule over the next three 

years. Within those four existing sources, there is a total of seven existing solvent mixers for an average of 1.75 mixers per source (7/4=1.75), with no 

additional new or reconstructed solvent mixers expected to be constructed over the three-years of the ICR.

b

 This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and 

$51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, Table 2. Civilian 

Workers, by Occupational and Industry group. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

c

 We have assumed that 15 percent of respondents will report deviation.

d

 We have assumed that 85 percent of respondents will report no deviation.
17

e

 We have assumed that 10 percent of respondents will have a startup, shutdown, or malfunction occur that is not managed according to the regulation.

f

 We have assumed that solvent weights are recorded once per hour (2 minutes [0.033 hr] per record) for 2,600 hours per year (industry average annual operating 

hours for solvent mixers).

g

 It is assumed that information would be entered once per week for 52 weeks per year.

h

 We have assumed that a typical plant transmits the startup, shutdown, and malfunction plan semiannually; deviation report once a year; and no deviation report 

semiannually for a total of five times per year.

i

 We have assumed that it will take 20 hours per plant once a year to train personnel.
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart 

QQQQQ) (Renewal)

Activity

(A)

EPA 

person-hours 

per occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

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

(Ex0.05)

(G)

Clerical 

person-hours 

per year

(Ex0.1)

(H)

Cost, 

$ b

1. Excess emissions enforcement 

activities c 48 1 48 0.2 9.6 0.48 0.96 $502.46

2. Report review

 Notification of applicability 2 1 2 0 0 0 0 $0

Notification of construction/

reconstruction 2 1 2 0 0 0 0 $0

 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 compliance status 40 1 40 0 0 0 0 $0

 Annual report of deviation d20 1 20 0.6 12 0.6 1.2 $628.08

 Semiannual report of no deviation e2 2 4 3.4 13.6 0.68 1.36 $711.82

 Startup, shutdown, malfunction 

report f 20 2 40 0.4 16 0.8 1.6 $837.44

TOTAL ANNUAL BURDEN AND COST (rounded) 59 $2,680

Assumptions:

a

 We have assumed that there are 4 existing sources, and that no additional new or reconstructed sources will become subject to the rule over the next three years. 

Within those four existing sources, there is a total of seven existing solvent mixers for an average of 1.75 mixers per source (7/4=1.75), with no additional new or 

reconstructed solvent mixers expected to be constructed over the three-years of the ICR.

b

 This cost is based on the following labor rates which have been increased by 60 percent to account for the benefit package available to government employees: 

$62.90 Managerial rate (GS-13, Step 5, $39.31 + 60%), $46.67 Technical rate (GS-12, Step 1, $29.17 + 60%), and $25.01 Clerical rate (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.

c

 We have assumed that 5 percent of plants will be involved in excess emissions enforcement activities.

d

 We have assumed that 15 percent of respondents will report deviation.

e We have assumed that 85 percent of respondents will report no deviation.

f We have assumed that 10 percent of respondents will have a startup, shutdown, or malfunction occur that is not managed according to the regulation.