# SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

Risk and Technology Review (RTR) for NESHAP for Aerospace M anufacturing and

Rework Facilities (40 CFR Part 63, Subpart GG)

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

RTR, EPA ICR Number 1687.10 OMB Control Number 2060-0314.

1(b) Short Characterization/Abstract

This supporting statement addresses information collection activities that will be imposed

by amendments to the National Emission Standards for H azardous Air Pollutants (NESHAP) for

Aerospace Manufacturing and Rework Facilities, 40 CFR part 63, subpart GG. Proposed on June

6, 1994; promulgated on September 1, 1995; and last-amended on Apri l 20, 2006, the NESHAP

applies to existing and new aerospace manufacturing and rewo rk facilities where the total

hazardous air pollutants (HAP) emitted are greater than or equal to 10 tons per year of any single

HAP, or where the total HAP emitted are greater than o r equal to 25 tons per year of any

combination of HAP. New facilities include those that c ommenced construction or

reconstruction after the date of proposal. Operations co vered include: cleaning, primer and

topcoat application, depainting, chemical milling maskant appl ication, and handling and storage

of waste.

As part of the residual risk review for the NESHAP and te chnology reviews for the

NESHAP, the proposed amendments add specialty coating appl ication operations to the rule and

remove the exemptions from the emissions limitations for periods of startup, shutdown and

malfunction (SSM) so that affected units would be subject to the emission standards at all times.

This information collection request documents the additio nal recordkeeping and reporting

requirements and burden imposed by the proposed amendments t o the rule.

In general, all NESHAP standards require initial notificati ons, performance tests, and

periodic reports by the owners/operators of the affected facilities. These notifications, reports,

and records are essential in determining compliance, and ar e required of all affected facilities

subject to NESHAP. This ICR includes the burden for activitie s that will be conducted in the

first three years following promulgation of the proposed am endments to the NESHAP for

Aerospace Manufacturing and Rework Facilities. The propos ed rule would add recordkeeping

and reporting provisions for specialty coating operations, b ut would not change the compliance

costs for operations already being regulated by the existin g emission standards.

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

notifications, reports, and records, and retain the file for at least five years following the date of

# such notifications, reports, and records. All reports are sent to the delegated state or local

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

United States Environmental Protection Agency (EPA) region al office.

Based on our consultations with industry representative s, there is an average of one

affected specialty coating operation (which is the total of all specialty coating applications) at

each plant site and that each plant site has only one respondent (i.e., the owner/operator of the

plant site).

Over the next three years, an average of 144 facilities per year will be subject to the

standard, and no additional respondents per year will becom e subject to the standard. However,

36 of these facilities are owned and operated by the Federa l government, and are not considered

respondents of this ICR. Therefore, the Affected Public o nly includes the 108 facilities that are

privately-owned, for-profit businesses. Each respondent ma y have one or more operations (e.g.,

cleaning, coating, depainting, or specialty coating operation s) subject to these standards. Of the

144 existing sources currently covered by this standard, 109 facil ities have specialty coating

operations. The EPA estimates that the total number o f potentially affected facilities with

specialty coating operations is approximately 27 Federal gove rnment-operated facilities and 82

privately-operated facilities.

All of the aerospace manufacturing and rework facilitie s in the United States are owned

and operated by the Aerospace Manufacturing and Rework indust ry. Thirty-six of the facilities in

the United States are owned by the Federal government and 108 facilities are privately-owned,

for-profit businesses (hereafter, the latter are refer red to as the “Affected Public”). The “burden”

to the Affected Public may be found below in Tables A1 to A3 of Attachment A. The cost of this

ICR to privately-operated aerospace manufacturing and rework facilities is $435,176 in labor

costs, averaged over the first 3 years after the amend ments are final.

The total average annual Agency cost during the three year s of the ICR is estimated to be

$207,135. The “burden” to the Agency may be found below in Tables B1 through C3 of

attachment A. The burden includes the cost to Federal gove rnment-operated aerospace

manufacturing and rework facilities to comply with the proposed amendments, and to the Federal

EPA and state agencies to implement the proposed amendm ents.

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 em ission reduction. In addition, section

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

of this Act to:

# (A) Establish and maintain such records; (B) make such repo rts;

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

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

accordance with such procedures or methods, at such locati ons, at

such intervals, during such periods, and in such manner as th e

Administrator shall prescribe); (E) keep records on contr ol

equipment parameters, production variables or other indir ect 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 Administrat or may

reasonably require.

In the Administrator's judgment, HAP emissions from aero space manufacturing and

rework facilities cause or contribute to air pollution that may reasonably be anticipated to

endanger public health or welfare. Therefore, the NESHA P were promulgated for this source

category at 40 CFR part 63, subpart GG.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard( s) ensure compliance with

the applicable regulations which where promulgated in accor dance with the Clean Air Act. The

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

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

capability to comply with the emission standard(s). Con tinuous emission monitors are used to

ensure compliance with the standard(s) at all times. Dur ing the performance test a record of the

operating parameters under which compliance was achieved ma y be recorded and used to

determine compliance in place of a continuous emission m onitor.

The notifications required in the standard(s) are used to inform the Agency or delegated

authority when a source becomes subject to the requireme nts of the regulations. The reviewing

authority may then inspect the source to check if the pol lution control devices are properly

installed and operated, leaks are being detected and repaired, a nd the standard(s) are being met.

The performance test may also be observed.

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

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

determinations.

3. Nonduplication, Consultations, and Other Collection Crite ria

The requested recordkeeping and reporting are required under (40 C FR part 63, subpart

GG).

3(a) Nonduplication

# If the subject standards have not been delegated, the infor mation is sent directly to the

appropriate EPA regional office. Otherwise, the inform ation 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 sta te or local agency can be sent to the

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

A public notice of this collection is provided in the Feder al Register notice of proposed

rulemaking published for the Aerospace Manufacturing and Rewor k Facilities NESHAP RTR.

3(c) Consultations

The public will be provided the opportunity to review and comme nt on the burden

estimated in this Information Collection Request during the comment period for the proposed

rulemaking. In addition, industry representatives including A erospace Industries Association,

and several member companies, provided information concerning the NESHAP for Aerospace

Manufacturing and Rework Facilities at meetings with th e EPA prior to rule proposal.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the m argin of assurance that

facilities are continuing to meet the standards. Require ments 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 inform ation required by these standards was

collected less frequently, the proper operation and mainte nance 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 consist ent with the General Provisions as applied to

the standards. EPA believes that the five year records r etention requirement is consistent with the

40 CFR Part 70 permit program and the five year statute of limitations on which the permit

program is based. The retention of records for five yea rs allows EPA to establish the compliance

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

enforcement action. EPA has found that the most flagran t 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 f orth in Title 40, chapter 1, part 2,

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1,

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are aerospace

manufacturing and rework facilities. The United States St andard Industrial Classification (SIC)

code for the respondents affected by the standards and the c orresponding North American

Industry Classification System for aerospace manufactur ing and rework facilities are listed

below.

40 CFR Part 63, Subpart GG SIC Codes NAICS Codes

Aircraft and Parts 3720 None

Aircraft Manufacturing 3721 336411

Aircraft Engine and Engine Parts Manufacturing 3724 336412

Other Aircraft Part and Auxiliary Equipment

Manufacturing 3728 336413

Guided Missiles and Space Vehicles Manufacturing 3761 336414

Guided Missile and Space Vehicle Propulsion Unit and

Propulsion Unit Parts Manufacturing 3764 336415

Other Guided Missile and Space Vehicle Parts and

Auxiliary Equipment Manufacturing 3769 336419

Scheduled Passenger Air Transportation 4512 481111

Scheduled Freight Air Transportation 4512 481112

Nonscheduled Chartered Passenger Air Transportation 4522 481211

Nonscheduled Chartered Freight Air Transportation 4522 481212

Other Nonscheduled Air Transportation 4522 481219

# 4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reporte d are required by the proposed

amendments to the NESHAP for Aerospace Manufacturing a nd Rework Facilities (40 CFR Part

63, Subpart GG).

A source must make the following reports:

Notifications/Reports

Notification of construction and modification 63.743(a)(2-3),

63.753(a), 63.5(d),

63.10(d)(5)

Initial notification for existing sources 63.9(b)(2),

63.753(a)(2)

Notification of performance test and results 63.7(b), 63.7(g)(1),

63.9(e), 63.10(d)(2),

63.753(a)

Notification and report of physical and operational changes 63.5(b)(6),

63.743(a)(2),

63.753(a)

Notification and report of production capacity 63.9(b)(2), 63.753(a)

Notification and report of compliance status 63.9(h), 63.753(a)

Notification and report for waiver applications 63.7(h)(3), 63.753(a)

Semiannual report 63.10(e)(3),

63.753(c)(1),

63.753(d)(1) and (3),

63.753(e)

Annual report 63.753(c)(2),

63.753(d)(2)

# A source must keep the following records:

Recordkeeping

Records of daily and monthly inspections 63.10(b)(2),

63.743(a)(3),

63.752(a)

Emission testing 63.10(b)(2),

63.752(a)

Facility operation and maintenance including construction and

modification 63.5(b),

63.743(a)(2) and

(3), 63.752

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

coatings without averaging 63.752(c)(1-3),

63.752(f)(1)

Primers/topcoats/maskants/specialty coatings: Records using averaging 63.752(c)(1),

63.752(c)(4),

63.752(f)(2)

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

devices 63.752(c)(1),

63.752(c)(5-6),

63.752(d),

63.752(f)(3),

63.752(f)(4)

5-years retention of records 63.10(b)(1),

63.752(a)

Electronic Reporting

Some of the respondents are using monitoring equipment tha t automatically records

parameter data. Although personnel at the affected facili ty must still evaluate the data, internal

automation has significantly reduced the burden associated w ith monitoring and recordkeeping at

a plant site.

Also, regulatory agencies in cooperation with the respon dents continue to create reporting

systems to transmit data electronically. However, elec tronic reporting systems are still not widely

used. At this time, it is estimated that approximately 10 per cent of the respondents use electronic

reporting.

# (ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for press ure drop and liquid supply pressure for

control device.

Perform initial performance test, Reference Methods 1, 1A, 2, 2A, 2C, 2D, 3, 4,18, 24, 25A,

40, 301, or 319 tests, and repeat performance tests if necess ary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, an d utilizing technology and

systems for the purpose of collecting, validating, and ver ifying information.

Develop, acquire, install, and utilize technology and syste ms for the purpose of processing and

maintaining information.

Develop, acquire, install, and utilize technology and syste ms for the purpose of disclosing and

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipmen t that provide parameter

data in an automated way (e.g., continuous parameter monito ring system). Although personnel at

the source still need to evaluate the data, this type of m onitoring 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 te st reports, and excess emissions

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking I nformation System (OTIS).

# 5(b) Collection Methodology and Management

Facilities are expected to use purchase records and manuf acturer’s documentation of

HAP and VOC content, based on coating formulation, to e stablish compliance with the proposed

HAP and VOC content limit standards in the Aerospace N ESHAP for specialty coatings.

Facilities are not expected to measure the HAP or VOC c ontent of the coatings. If a facility is

using add-on controls to comply, performance test reports a re used by the Agency to discern a

source’s initial capability to comply with the emission standard. Data and records maintained by

the respondents used in compliance and enforcement programs. The semiannual reports

submitted by respondents are used for problem identification , as a check on source operation and

maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and

maintained by EPA's Office of Compliance. OTIS is EPA’ s database for the collection,

maintenance, and retrieval of compliance data for approxi mately 125,000 industrial and

government-owned facilities. EPA uses the OTIS for trac king air pollution compliance and

enforcement by local and state regulatory agencies, EPA r egional offices and EPA headquarters.

EPA and its delegated Authorities can edit, store, retri eve and analyze the data.

The records required by this regulation must be retained by t he owner/operator for five

years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) using specialty coatings and affected

by this regulation.

5(d) Collection Schedule

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

shown in below Tables A1 to B3 of Attachment A.

6. Estimating the Burden and Cost of the Collection

Tables A1 to A3 in Attachment A present an itemized breakdo wn of the reporting and

recordkeeping requirements in the first 3 years for the pr ivate sector respondents subject to the

proposed NESHAP. Tables B1to B3 presents the burden on Fede ral government-operated

aerospace manufacturing and rework facilities and is incl uded in the Agency burden discussed

below.

The individual burdens are expressed under standardized headings believed to be

consistent with the concept of burden under the Paperwor k Reduction Act. Where appropriate,

specific tasks and major assumptions have been identifi ed. 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 currentl y valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to respondents in the private sect or over the next three years

from these recordkeeping and reporting requirements is est imated to be 4,475 hours (Total Labor

Hours from Tables A1 to A3 of Attachment A). These hours a re based on Agency studies and

background documents from the development of the regulatio n, Agency knowledge and

experience with the NESHAP program, the previously approve d ICR, and any comments

received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $127.72 ($60.82 + 110%)

Technical $101.60 ($48.38 + 110%)

Clerical $38.58 ($18.37 + 110%)

These rates are from the United States Department of L abor, Bureau of Labor Statistics, May

2013, “National Occupational Employment and Wage Estimates U nited States” in the Aerospace

Product and Parts Manufacturing (NAICS code 336400). The rates have been increased by 110

percent to account for the benefit packages available to t hose employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenanc e Costs

The only costs to the regulated industry resulting from inf ormation collection activities

required by the subject standard(s) are labor costs. Ther e are no capital/startup or operation and

maintenance costs associated with the recordkeeping and r eporting requirements. EPA assumed

that the recordkeeping associated with the specialty coat ing operations will be accomplished with

the existing equipment (e.g., computer systems) used for co mpliance for existing coating

operations.

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

There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

Costs to the Agency include the costs for Federal governmen t-owned aerospace

# manufacturing and rework facilities associated with comp lying with the proposed amendments.

Tables B1 to B3 in Attachment A present an itemized breakdo wn of the reporting and

recordkeeping requirements in the first 3 years for the F ederal government-owned sources

subject to the proposed NESHAP. The average annual burden to t hese respondents over the next

three years from these recordkeeping and reporting requirem ents is estimated to be 2,439 hours

and $198,395 (Total Labor Burden and Cost from Tables B1 to B3).

The costs to the Agency also include those costs associ ated 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, period ic inspection of sources of

emissions, and the publication and distribution of collec ted information. The average annual

Agency cost for these activities during the three years of the ICR is estimated to be $8,740.

Details upon which this estimate is based appear below in T ables C1 to C3 of Attachment A.

The total average annual Agency cost during the three year s of the ICR is estimated to be

$207,135.

This ICR uses the following labor rates for the costs f or Federal government-owned

sources to comply with the proposed amendments:

Managerial $89.49 ($55.93 + 60%)

Technical $86.16 ($53.85 + 60%)

Clerical $29.04 ($18.15 + 60%)

These rates are from the United States Department of L abor, Bureau of Labor Statistics, May

2013, “National Occupational Employment and Wage Estimates U nited States” in the Federal

Executive Branch (NAICS code 999100).

The average hourly labor rate used for the EPA Region an d States to review reports and

compliance and enforcement is as follows:

Managerial $62.90 (GS-13, Step 5, $39.61 + 60%)

Technical $46.67 (GS-12, Step 1, $28.17 + 60%)

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

These rates are from the Office of Personnel Manageme nt (OPM), 2014 General Schedule,

which excludes locality rates of pay.

Both sets of the above rates have been increased by 60 percent to account for the benefit

packages available to government employees.

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

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

# 144 existing facilities will be subject to the standard. Thi rty-six of the facilities in the United

States are operated by the Federal government and 108 facilit ies are privately-owned, for-profit

businesses. Thus, only the 108 privately-owned businesses are considered respondents to this

ICR. Of the 144 existing sources currently covered by this s tandard, 109 facilities have specialty

coating operations. The EPA estimates that the total n umber of potentially affected facilities with

specialty coating operations is approximately 27 Federal gove rnment-operated facilities and 82

privately-operated facilities. This number of sources is expected to remain constant over the

period of this ICR as no sources are expected to start-up ov er the next three years. This is based

on a comprehensive ICR that was sent to all known aeros pace facilities in February 2011.

While there are no additional reports that are required t o be submitted by the respondents

due to the proposed Amendments, additional time is need to c omplete the annual reports and are

therefore considered as one additional annual response for the 82 privately-operated facilities.

Details regarding these estimates may be found in Attachme nt Tables A1 to B3.

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculation s for the respondents and the

Agency are shown in Tables A1 to A3, B1 to B3, and C1 to C3 r espectively, and summarized

below.

(i) Respondent Tally

The total annual labor hours for privately-owned facilities are 4,475 hours at a cost of

$435,176. Details regarding these estimates may be found in Tabl es A1 to A3 of Attachment A.

Attachment A also presents the burden on Federal governmen t-operated facilities and is

discussed below in section (ii).

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

information is estimated to average 54.6 hours per respons e.

There are no total annual capital/startup and O&M costs t o the regulated entity. The cost

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

(O&M) Costs.

(ii) The Agency Tally

The total average annual Agency cost during the three year s of the ICR is estimated to be

$207,135. This includes the average annual Agency burden and cost over next three years for

Federal government-operated facilities (2,439 labor hours at a cost of $198,395) and EPA

Regions and States (148 labor hours at a cost of $8,740). See Tables B1 to B3 and C1 to C3 for

details.

6(f) Reasons for Change in Burden

# There is no change in the labor hours or cost in this ICR as it is for the proposed

Aerospace Manufacturing and Rework Facilities NESHAP and is considered new burden.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this c ollection of information

is estimated to average approximately 54.6 hours per response. This burden is estimated by

dividing the average annual burden hours for privately-owned f acilities over the three-year

period (4,475) hours by the total number of responses during the three-year period (82). Burden

means the total time, effort, or financial resources ex pended by persons to generate, maintain,

retain, or disclose or provide information to or for a Fe deral agency. This includes the time

needed to review instructions; develop, acquire, install, an d utilize technology and systems for

the purposes of collecting, validating, and verifying inform ation, processing and maintaining

information, and disclosing and providing information; adjus t the existing ways to comply with

any previously applicable instructions and requirements; tra in personnel to be able to respond to

a collection of information; search data sources; comple te and review the collection of

information; and transmit or otherwise disclose the inf ormation.

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 OM B 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, t he accuracy of the provided

burden estimates, and any suggested methods for minimizing res pondent burden, including the

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

Docket ID Number EPA-HQ-OECA-2014-0830. An electronic version of the public docket is

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft

collection of information, submit or view public comments , access the index listing of the

contents of the docket, and to access those documents in the public docket that are available

electronically. When in the system, select “search,” then key in the docket ID number identified

in this document. The documents are also available for public viewing at the Enforcement and

Compliance Docket and Information Center in the EPA Do cket Center (EPA/DC), EPA West,

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal

holidays. The telephone number for the Reading Room is ( 202) 566-1744, and the telephone

number for the docket center is (202) 566-1927. Also, you can sen d 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. Plea se include the EPA Docket ID

Number EPA-HQ-OECA-2014-0830 and OMB Control Number 2060-0314 in any

correspondence.

# Part B of the Supporting Statement

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

information.

# ATTACHMENT A

TABLES A, B, and C

Tables A1 - A3: Annual Respondent Burden and Cost of Recordkeeping and R eporting

Requirements for Specialty Coating Operations at Privately-Opera ted Aerospace

Manufacturing and Rework Facilities – Years 1-3

Tables B1 - B3: Annual Respondent Burden and Cost of Recordkeeping and Report ing Requirements

for Specialty Coating Operations at Federal Government-Operated Aer ospace

Manufacturing and Rework Facilities – Years 1-3

Tables C1 - C3: Annual Designated Administrator Burden and Cost of Recor dkeeping and Reporting

Requirements of Aerospace Specialty Coating Operations – Years 1-3(A) (B) (C) (D) (E) (F) (G) (H)Person hoursper occurrenceNo. ofoccurrences perrespondent peryearPerson hoursper respondentper yearRespondentsper yearaTechnical personhours per yearManagementperson hours peryearClerical personhours per yearTotal Cost PerYearb(A x B) (C x D) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and studiesN/A3. Reporting requirementsA. Read instructionsc, d1 1 1 82 82 4.1 8.2 9,171.03$B. Required activitiesInitial performance testsN/ARepeat performance testN/AC. Create informationSee 4CD. Gather existing informationSee 4CE. Write reportNotification of construction/reconstructionN/AeNotification of physical and operational changesN/AeNotification of actual startupN/AeNotification of change in production capacityN/AeCompliance status information reportN/AeWaiver applicationN/AeStartup, shutdown, malfunction planN/AePreparation of site-specific test planN/AeNotification of initial performance testN/AeReport of initial testN/AeStartup, shutdown, malfunction reportN/AeSemiannual report – including report of periods of noncomplianceN/AeSubtotal for Reporting Requirements9,171$4. Recordkeeping requirementsA. Read instructionsSee 3AB. Plan activitiesd4 1 4 82 328 16.4 32.8 36,684.11$C. Implement activitiesCompliance coating records82 2497 124.85 249.7 279,268.97$N/AeControl device maintenance log (inorganics)N/AeD. Develop record systemd, f10 1 10 82 820 41 82 91,710.28$E. Time to enter/maintain informationRecords of startup, shutdown, and malfunctionN/AeRecords of all measurements and informationSee 4Crequired by standardF. Time to train personneld, g2 3 6 82 492 24.6 49.2 55,026.17$G. Time for auditsh10 1 10 82 820 41 82 91,710.28$Subtotal for Recordkeeping Requirements554,400$TOTAL LABOR BURDEN AND COST (rounded)563,571$Table A1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operationsat Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 15794.85Burden itemControl device maintenance or rolling material balance log (organics)5700.5594.3See NOTE 1aAssumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.cWe have assumed that there will be no net growthfor the industry, only existing sources will read instructions.dOne-time cost that is only incurred during the first year of compliance.fWe have assumed that all facilities will need to develop a record keeping system.gWe have assumed one person per shift will requiretraining on recordkeeping requirements and system.hWe have assumed auditing activities will coincidewith similar activities for coating operations, sowould entail about half the effort assumed for thesame activity in coating operations.bAssumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses meanhourly wage forthe following labor categories from the United States Department of Labor, Bureau of Labor Statistics,May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace Product and PartsManufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers forTechnical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 110 percent to accountfor the benefit packages available to those employed by private industry.eWe have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coatingNOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICRsurvey responses.(A) (B) (C) (D) (E) (F) (G) (H)Person hoursper occurrenceNo. ofoccurrences perrespondent peryearPerson hours perrespondent peryearRespondentsper yearaTechnical personhours per yearManagementperson hours peryearClericalpersonhours peryearTotal Cost PerYearb(A x B) (C x D) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and studiesN/A3. Reporting requirementsA. Read instructionsc, dN/A-$B. Required activitiesInitial performance testsN/AeRepeat performance testN/AeC. Create informationSee 4CD. Gather existing informationSee 4CE. Write reportNotification of construction/reconstructionN/AeNotification of physical and operational changesN/AeNotification of actual startupN/AeNotification of change in production capacityN/AeCompliance status information reportN/AeWaiver applicationN/AeStartup, shutdown, malfunction planN/AePreparation of site-specific test planN/AeNotification of initial performance testN/AeReport of initial testN/AeStartup, shutdown, malfunction reportN/AeSemiannual report – including report of periods of noncomplianceN/AeSubtotal for Reporting Requirements-$4. Recordkeeping requirementsA. Read instructionsSee 3AB. Plan activitiesdN/A-$C. Implement activitiesCompliance coating records82 2497 124.85 249.7 279,268.97$N/AeControl device maintenance log (inorganics)N/AeD. Develop record systemd, fN/A-$E. Time to enter/maintain informationRecords of startup, shutdown, and malfunctionN/AeRecords of all measurements and informationSee 4Crequired by standardF. Time to train personneld, gN/A-$G. Time for auditsh10 1 10 82 820 41 82 91,710.28$Subtotal for Recordkeeping Requirements370,979$TOTAL LABOR BURDEN AND COST (rounded)370,979$Table A2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operationsat Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 23814.55Burden item0See NOTE 1Control device maintenance or rolling material balance log (organics)3814.55aAssumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.cWe have assumed that there will be no net growthfor the industry, only existing sources will read instructions.eWe have assumed that all facilities will need to develop a record keeping system.fWe have assumed one person per shift will requiretraining on recordkeeping requirements and system.gWe have assumed auditing activities will coincidewith similar activities for coating operations, sowould entail about half the effort assumed for thesame activity in coating operations.hOne-time cost that is only incurred during the first year of compliance.bAssumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses meanhourlywage for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the AerospaceProduct and Parts Manufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have beenincreased by 110 percent to account for the benefitpackages available to those employed by private industry.dWe have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs forcoating operations.NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011ICR survey responses.(A) (B) (C) (D) (E) (F) (G) (H)Person hoursper occurrenceNo. ofoccurrencesper respondentper yearPerson hours perrespondent peryearRespondentsper yearaTechnicalperson- hoursper yearManagementperson hours peryearClericalpersonhours peryearTotal Cost PerYearb(A x B) (C x D) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and studiesN/A3. Reporting requirementsA. Read instructionsc, dN/A-$B. Required activitiesInitial performance testsN/AeRepeat performance testN/AeC. Create informationSee 4CD. Gather existing informationSee 4CE. Write reportNotification of construction/reconstructionN/AeNotification of physical and operational changesN/AeNotification of actual startupN/AeNotification of change in production capacityN/AeCompliance status information reportN/AeWaiver applicationN/AeStartup, shutdown, malfunction planN/AePreparation of site-specific test planN/AeNotification of initial performance testN/AeReport of initial testN/AeStartup, shutdown, malfunction reportN/AeSemiannual report – including report of periods of noncomplianceN/AeSubtotal for Reporting Requirements-$4. Recordkeeping requirementsA. Read instructionsSee 3AB. Plan activitiesdN/A-$C. Implement activitiesCompliance coating records82 2497 124.85 249.7 279,268.97$N/AeControl device maintenance log (inorganics)N/AeD. Develop record systemd, fN/A-$E. Time to enter/maintain informationRecords of startup, shutdown, and malfunctionN/AeRecords of all measurements and informationSee 4Crequired by standardF. Time to train personneld, gN/A-$G. Time for auditsh10 1 10 82 820 41 82 91,710.28$Subtotal for Recordkeeping Requirements370,979$TOTAL LABOR BURDEN AND COST (rounded)370,979$Table A3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for SpecialtyCoating Operationsat Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 3Burden item0See NOTE 1Control device maintenance or rolling material balance log (organics)3814.553814.55aAssumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.cWe have assumed that there will be no net growthfor the industry, only existing sources will read instructions.eWe have assumed that all facilities will need to develop a record keeping system.fWe have assumed one person per shift will requiretraining on recordkeeping requirements and system.gWe have assumed auditing activities will coincidewith similar activities for coating operations, sowould entail about half the effort assumed for thesame activity in coating operations.hOne-time cost that is only incurred during the first year of compliance.bAssumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses meanhourly wage forthe following labor categories from the United States Department of Labor, Bureau of Labor Statistics,May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace Product and PartsManufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers forTechnical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 110 percent toaccount for the benefit packages available to thoseemployed by private industry.dWe have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coatingoperations.NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICRsurvey responses.(A) (B) (C) (D) (E) (F) (G) (H)Person hoursper occurrenceNo. ofoccurrences perrespondent peryearPerson hoursper respondentper yearRespondentsper yearaTechnical personhours per yearManagementperson hours peryearClerical personhours per yearTotal Cost PerYearb(A x B) (C x D) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and studiesN/A3. Reporting requirementsA. Read instructionsc, d1 1 1 27 27 1.35 2.7 2,525.54$B. Required activitiesInitial performance testsN/ARepeat performance testN/AC. Create informationSee 4CD. Gather existing informationSee 4CE. Write reportNotification of construction/reconstructionN/AeNotification of physical and operational changesN/AeNotification of actual startupN/AeNotification of change in production capacityN/AeCompliance status information reportN/AeWaiver applicationN/AeStartup, shutdown, malfunction planN/AePreparation of site-specific test planN/AeNotification of initial performance testN/AeReport of initial testN/AeStartup, shutdown, malfunction reportN/AeSemiannual report – including report of periods of noncomplianceN/AeSubtotal for Reporting Requirements2,526$4. Recordkeeping requirementsA. Read instructionsSee 3AB. Plan activitiesd4 1 4 27 108 5.4 10.8 10,102.15$C. Implement activitiesCompliance coating records27 1662 83.1 166.2 155,460.82$N/AeControl device maintenance log (inorganics)N/AeD. Develop record systemd, f10 1 10 27 270 13.5 27 25,255.37$E. Time to enter/maintain informationRecords of startup, shutdown, and malfunctionN/AeRecords of all measurements and informationSee 4Crequired by standardF. Time to train personneld, g2 3 6 27 162 8.1 16.2 15,153.22$G. Time for auditsh10 1 10 27 270 13.5 27 25,255.37$Subtotal for Recordkeeping Requirements231,227$TOTAL LABOR BURDEN AND COST (rounded)233,752$Burden item31.05See NOTE 1Table B1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operationsat Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 1Control device maintenance or rolling material balance log (organics)2842.82873.85aAssumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.cWe have assumed that there will be no net growthfor the industry, only existing sources will read instructions.eWe have assumed that all facilities will need to develop a record keeping system.fWe have assumed one person per shift will requiretraining on recordkeeping requirements and system.gWe have assumed auditing activities will coincidewith similar activities for coating operations, sowould entail about half the effort assumed for thesame activity in coating operations.hOne-time cost that is only incurred during the first year of compliance.bAssumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04per hour for Clerical labor. This ICR uses mean hourly wage for thefollowing labor categories from the United States Department of Labor, Bureau of Labor Statistics, May2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch (NAICScode 999100): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, andOffice Clerks, General for Clerical labor. The rates have been increased by 60 percent to account forthe benefit packagesavailable to government employees.dWe have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coatingoperations.NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICRsurvey responses.(A) (B) (C) (D) (E) (F) (G) (H)Person hoursper occurrenceNo. ofoccurrencesper respondentper yearPerson hours perrespondent peryearRespondentsper yearaTechnicalperson- hoursper yearManagementperson hours peryearClericalpersonhours peryearTotal Cost PerYearb(A x B) (C x D) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and studiesN/A3. Reporting requirementsA. Read instructionsc, dN/A-$B. Required activitiesInitial performance testsN/AeRepeat performance testN/AeC. Create informationSee 4CD. Gather existing informationSee 4CE. Write reportNotification of construction/reconstructionN/AeNotification of physical and operational changesN/AeNotification of actual startupN/AeNotification of change in production capacityN/AeCompliance status information reportN/AeWaiver applicationN/AeStartup, shutdown, malfunction planN/AePreparation of site-specific test planN/AeNotification of initial performance testN/AeReport of initial testN/AeStartup, shutdown, malfunction reportN/AeSemiannual report – including report of periods of noncomplianceN/AeSubtotal for Reporting Requirements-$4. Recordkeeping requirementsA. Read instructionsSee 3AB. Plan activitiesdN/A-$C. Implement activitiesCompliance coating records27 1662 83.1 166.2 155,460.82$N/AeControl device maintenance log (inorganics)N/AeD. Develop record systemd, fN/A-$E. Time to enter/maintain informationRecords of startup, shutdown, and malfunctionN/AeRecords of all measurements and informationSee 4Crequired by standardF. Time to train personneld, gN/A-$G. Time for auditsh10 1 10 27 270 13.5 27 25,255.37$Subtotal for Recordkeeping Requirements180,716$TOTAL LABOR BURDEN AND COST (rounded)180,716$Burden item0See NOTE 1Table B2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for SpecialtyCoating Operationsat Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 2Control device maintenance or rolling material balance log (organics)2221.82221.8aAssumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.cWe have assumed that there will be no net growthfor the industry, only existing sources will read instructions.eWe have assumed that all facilities will need to develop a record keeping system.fWe have assumed one person per shift will requiretraining on recordkeeping requirements and system.gWe have assumed auditing activities will coincidewith similar activities for coating operations, sowould entail about half the effort assumed for thesame activity in coating operations.hOne-time cost that is only incurred during the first year of compliance.bAssumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04per hour for Clerical labor. This ICR uses mean hourly wage for thefollowing labor categories from the United States Department of Labor, Bureau of Labor Statistics, May2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch(NAICS code 999100): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 60 percent to account for the benefitpackages available to government employees.dWe have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coatingoperations.NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICRsurvey responses.(A) (B) (C) (D) (E) (F) (G) (H)Person hoursper occurrenceNo. ofoccurrencesper respondentper yearPerson hours perrespondent peryearRespondentsper yearaTechnicalperson- hoursper yearManagementperson hours peryearClericalpersonhours peryearTotal Cost PerYearb(A x B) (C x D) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and studiesN/A3. Reporting requirementsA. Read instructionsc, dN/A-$B. Required activitiesInitial performance testsN/AeRepeat performance testN/AeC. Create informationSee 4CD. Gather existing informationSee 4CE. Write reportNotification of construction/reconstructionN/AeNotification of physical and operational changesN/AeNotification of actual startupN/AeNotification of change in production capacityN/AeCompliance status information reportN/AeWaiver applicationN/AeStartup, shutdown, malfunction planN/AePreparation of site-specific test planN/AeNotification of initial performance testN/AeReport of initial testN/AeStartup, shutdown, malfunction reportN/AeSemiannual report – including report of periods of noncomplianceN/AeSubtotal for Reporting Requirements-$4. Recordkeeping requirementsA. Read instructionsSee 3AB. Plan activitiesdN/A-$C. Implement activitiesCompliance coating records27 1662 83.1 166.2 155,460.82$N/AeControl device maintenance log (inorganics)N/AeD. Develop record systemd, fN/A-$E. Time to enter/maintain informationRecords of startup, shutdown, and malfunctionN/AeRecords of all measurements and informationSee 4Crequired by standardF. Time to train personneld, gN/A-$G. Time for auditsh10 1 10 27 270 13.5 27 25,255.37$Subtotal for Recordkeeping Requirements180,716$TOTAL LABOR BURDEN AND COST (rounded)180,716$Burden item0See NOTE 1Table B3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for SpecialtyCoating Operationsat Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 3Control device maintenance or rolling material balance log (organics)2221.82221.8aAssumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.cWe have assumed that there will be no net growthfor the industry, only existing sources will read instructions.eWe have assumed that all facilities will need to develop a record keeping system.fWe have assumed one person per shift will requiretraining on recordkeeping requirements and system.gWe have assumed auditing activities will coincidewith similar activities for coating operations, sowould entail about half the effort assumed for thesame activity in coating operations.hOne-time cost that is only incurred during the first year of compliance.bAssumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04per hour for Clerical labor. This ICR uses mean hourly wage for thefollowing labor categories from the United States Department of Labor, Bureau of Labor Statistics, May2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch(NAICS code 999100): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 60 percent to account for the benefitpackages available to government employees.dWe 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 coatingoperations.NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICRsurvey responses.46.67 62.90 25.25(B) (C) (D) (E) (F)EPATechManagementClericalEPAHoursHoursHoursHoursCostPerPer YearPer YearPer YearPer Year (a, b)Occurrence@$46.67@$62.90@$25.25Burden Item(Tech Hours)(C=AxB)(D=Cx0.05)(E=Cx0.1)1. Applications02.Read and Understand Rule Requirementsc, d1 60 3 6 $4,0653. Required ActivitiesA. Observe initial performance testsB. Observe annual performance testsC. Excess emissions -- Enforcement ActivitiesD. Create InformationE. Gather InformationF. Report Reviews1)Initial Notificationd0.5 0 0 0 $02)Notification of Compliance Statusd0.5 0 0 0 $03) Review annual and semiannual compliance report1 109 5 11 $7,3854. Travel expenses:TOTAL:169 8 17 $11,450Total Hours Labor Non-Labor Total194 $11,450 $0 $11,450aWe have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.dOne-time only costs.Per YearN/ATable C1. Annual Designated Administrator Burden andCost of Recordkeeping and Reporting Requirementsof Aerospace Specialty Coating Operations - Year 1(A)Number ofOccurrencescAssume that each State and EPA region reviews the rule anddevelops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10Regions = 60 occurrences.bAssumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office ofPersonnel 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 togovernment employees. These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.60N/AN/AN/AN/AN/A00109N/A47 63 25(B)(C)(D)(E)(F)EPATechManagementClericalEPAHoursHoursHoursHoursCostPerPer YearPer YearPer YearPer Year (a, b)Occurrence@$46.67@$62.90@$25.25Burden Item(Tech Hours)(C=AxB)(D=Cx0.05)(E=Cx0.1)1. Applications02.Read and Understand Rule Requirementsc, d1 0 0 0 $03. Required ActivitiesA. Observe initial performance testsB. Observe annual performance testsC. Excess emissions -- Enforcement ActivitiesD. Create InformationE. Gather InformationF. Report Reviews1)Initial Notificationd0.5 0 0 0 $02)Notification of Compliance Statusd0.5 0 0 0 $03) Review annual and semiannual compliance report1 109 5 11 $7,3854. Travel expenses:TOTAL:109 5 11 $7,385Total Hours Labor Non-Labor Total125 $7,385 $0 $7,385aWe have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.dOne-time only costs.of Aerospace Specialty Coating Operations - Year 2bAssumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office ofPersonnel 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 togovernment employees. These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.cAssume that each State and EPA region reviews the rule anddevelops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10Regions = 60 occurrences.N/AN/AN/AN/AN/APer YearN/A(A)Number ofOccurrencesN/A000109Table C2. Annual Designated Administrator Burden andCost of Recordkeeping and Reporting Requirements47 63 25(B)(C)(D)(E)(F)EPATechManagementClericalEPAHoursHoursHoursHoursCostPerPer YearPer YearPer YearPer Year (a, b)Occurrence@$46.67@$62.90@$25.25Burden Item(Tech Hours)(C=AxB)(D=Cx0.05)(E=Cx0.1)1. Applications02.Read and Understand Rule Requirementsc, d1 0 0 0 $03. Required ActivitiesA. Observe initial performance testsB. Observe annual performance testsC. Excess emissions -- Enforcement ActivitiesD. Create InformationE. Gather InformationF. Report Reviews1)Initial Notificationd0.5 0 0 0 $02)Notification of Compliance Statusd0.5 0 0 0 $03) Review annual and semiannual compliance report1 109 5 11 $7,3854. Travel expenses:TOTAL:109 5 11 $7,385Total Hours Labor Non-Labor Total125 $7,385 $0 $7,385aWe have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.dOne-time only costs.of Aerospace Specialty Coating Operations - Year 3bAssumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office ofPersonnel 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 togovernment employees. These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.cAssume that each State and EPA region reviews the rule anddevelops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10Regions = 60 occurrences.0N/AN/AN/AN/A(A)Number ofOccurrencesPer Year109N/AN/AN/A00Table C3. Annual Designated Administrator Burden andCost of Recordkeeping and Reporting Requirements