**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 I CR Number 2025.06, OMB Control Number 2060

- 0481

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Fri ction Materials Manufacturing (40 CFR P art 63, S ubpart 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 th ose that commenced construction or reconstruction after the date of proposal. A friction materials manufacturing facility is onl y 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 ye ar or any combination of HAP s at a rate of 22.68 megagrams (25 tons) or more per year. Consistent with the General Provisions (40 CFR Part 63, S ubpart 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 CF R 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subje ct 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 deleg ated state or local authority

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

. S

. Environmental Protection Agency (EPA) regional office. Approximately

four respondents are currently subject to the regulati on, and it is estimated that no additional respondents per year will become subject to the regulation in the next three years.2

The Office of Management and Budget ( OMB ) approved the currentl y active I CR 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 subsequentl y 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 b y the friction material manufacturing industry . None of the four faciliti es in the United States are owned b y state, local, tribal, or the Federal government. They are owned and operated b y private ly 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)

. T he “burden ” to the Federal Government is attributed entirel y to work performed b y either F ederal employees or government contractor s 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. Inaddition, 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 certification s in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from solvent mixers either cause or3

contribute to air pollution that may reasonably

b e 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 properl y installed and operated , that leaks are being detected and repaired , and the standard is being met. The perfor

mance 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 directl y to the app ropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the s tate or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist.4

**3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR 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 indus try

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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) 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 I CR, we contacted the Motor and Equipment Manufacturers Association ( MEMA) at (202) 393

- 6362, and Dy

nax 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 infor mation 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 frequentl y, the proper operati on 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 b y OMB under 5 CFR Part 132 0, 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

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allow s EPA to establish the compliance history of a source , any p attern of non - compliance and to determine the appropriate level of enforcement5

action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. 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, C hapter 1, P art 2, S ubpart 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 (SI C) codes for the respondents affected b y the standards and their corresponding North American Industry Classification System (NAI CS) codes are listed below.

**Standard (40 CF R**  **P art 63, Subpart QQQQQ)**  **SIC Codes**  **NAICS**

**Codes** Motor Vehicle Brake Sy stem 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 b y the NESHAP for Friction Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ ). A source must make the following reports:

**Notification s** 6
**Notification s**  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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**7

**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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing in formation. Adjust the existing way s 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 s ys tem. 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 emissions8 **Agency Activities** reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply

with the emission standard

. Data and records maintained by the respond ents 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y 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 ye ars. **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 ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and l arge 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 o verall 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 CF R Part 63, Subpart QQQQQ ) (Renewal).9

**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 IC R. 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 thi s 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 record

keeping and reporting requirement s 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 dev elopment 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 I CR uses the following labor rates: Managerial $1 2 8

. 0 2 ($ 60.98 + 110%) Technical $ 10 1

. 05 ($4 8

. 12 + 110%) Clerical $ 5 1

. 37 ($2 4

. 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 b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Main tenance Costs**  The ty pe 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/startu p 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** 10 **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 I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR 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 IC R 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 anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained 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 hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rat es are from the Office of Personnel Management (OPM) , 20 1 4 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 I CR, on average over the next three ye ars, approximately11

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 resp ondents, as shown in the table below, is four per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is four

. The total number of annual responses per ye ar 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 012 **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 th e 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 currentl y identified in the OMB Inventory of Approved Burdens. This decrease is due to a discrepancy identified in the previous ICR

. The previ ous ICR assumed all existing plants transmit one - time notification s , a burden13

item that applies to new sources onl y . Since no new sources are expected over the next three

ye ar period of the ICR, the I CR 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 b y 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 s ys tems for the purposes of collecting, validating, and verifying in formation, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of informati on; 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 t his I CR under Docket ID Number EPA

- HQ

- OECA

- 201 4

- 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 sy stem , 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 20 1 4

- 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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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/r econstruction 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 c 8 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
S tartup, shutdown, malfunction report e 8 2 16 0.4 6.4 0.32 0.64 $720.56 **Subtotal for Reporting Requirements 75**  **$7,386**16

**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)** 

**Managem ent**  **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 h 0.25 5 1.25 4 5 0.25 0.5 $562.94 F. Time to train personnel i 20 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**
**Assu mptions:**  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 Statis tics, 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 indu stry

. 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 accord ing 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 malfuncti on 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.18

**Table 2: Average Annual EPA Burden and Cos t** 

**– 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)**

**Managem ent**  **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 d 20 1 20 0.6 12 0.6 1.2 $628.08 Semiannual report of no deviation e 2 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**
**Assu mptions:** 
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 sourc e (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 w hich have been increased by 60 percent to account for the benefit package av ailable 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 exce ss emission s 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.