SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) 

(Renewal), EPA ICR Number 2115.03, OMB Control Number 2060-0535

1(b) Short Characterization/Abstract

Respondents are owners or operators of new and existing facilities that manufacture a 

miscellaneous coating and are either located at, or are part of, major sources of hazardous air 

pollutant (HAP) emissions. “Major source” means that the process equipment used to 

manufacture the miscellaneous coatings and any other operations or equipment at the facility

emit, or have the potential to emit, 10 tons per year or more of a single HAP or 25 tons per year 

or more of any combination of HAP. A facility is subject to the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing if it meets the 

following criteria:

1. Manufactures coatings, including inks, paints, or adhesives described by Standard 

Industrial Classification (SIC) codes 285, or 289, or North American Industrial 

Classification System (NAICS) codes 3255, or 3259;

2. Processes, uses, or produces HAP;

3. Not part of an affected source under another subpart of 40 CFR part 63.

An average of approximately 132 existing miscellaneous coating manufacturing 

respondents will be subject to the standard over the next three years. The number of respondents 

is expected to grow about two percent over the next three years (0.67 percent per year) which 

adds approximately one respondent per year to the inventory. An annual average of 

approximately 133 respondents would be subject to the standard over the three-year period 

covered by this ICR.

Owners or operators of miscellaneous coating manufacturing facilities subject to the 

standard must choose one of the compliance options described in the standard, or install and 

monitor control systems that reduce HAP emissions to the allowable emission rate. Specifically, 

owners, or operators are required to install, operate, and maintain a continuous monitoring 

system (CMS) to demonstrate compliance with the emission limitations in Tables 1 through 3 

and 5 through 6 in the standard and the operating limits in Table 7; and they also must record the 

values of equipment operating parameters as specified in Table 7. Owners, or operators are 

required to conduct equipment inspections and equipment leak monitoring to demonstrate 
2

compliance with the work practice standards in Tables 1 through 5.

Also, miscellaneous coating manufacturing facilities are subject to the general provisions 

at 40 CFR part 63, subpart A which apply to all NESHAP subject facilities. These requirements 

include those associated with the applicability determinations; notifications that the facilities are 

subject to the rule; notifications of performance tests; notifications of compliance status, 

including the results of performance tests and design evaluations; and semiannual compliance 

reports. In addition to the requirements of subpart A, many respondents are required to submit a 

precompliance report and leak detection and repair (LDAR) reports; and existing facilities that 

wish to implement emissions averaging provisions must submit an emissions averaging plan.

All reports are to be submitted to the respondent’s state, or local agency, or to the EPA 

regional office, whichever has been delegated enforcement authority by EPA. The information is 

used to determine whether or not all sources subject to the rule are achieving the emission 

limitations and work practice standards in the rule.

If the owner, or operator identifies any deviation from an emission limitation or work 

practice standard, a compliance report must be submitted that includes all records that the source 

is required to maintain that pertain to the periods during which such deviation occurred, as well 

as data regarding: the magnitude of each deviation; the reason for each deviation; a description of 

the corrective action taken for each deviation, including action taken to minimize each deviation 

and actions taken to prevent a recurrence; and a copy of all quality assurance activities performed 

on any monitoring protocol.

Owners, or operators of a miscellaneous coating manufacturing facility must maintain a 

copy of all monitored equipment operating parameter values that demonstrate compliance with 

the operating limits in the rule, as well as records of inspections and results of equipment leak 

monitoring that demonstrate compliance with the work practice standards in the rule. Also, 

owners, or operators are required to maintain records of the occurrence and duration of any

startup, shutdown, or malfunction in the operation of a source, or any period during which the 

monitoring system is inoperative. Those records must be maintained for a minimum of five 

years. At a minimum, the most recent two years of data must be retained onsite. The remaining 

three years of data may be retained offsite.

A previous Information Collection Request (ICR) incorrectly identifies “Federal 

Government” and “State, Local, or Tribal Government” as part of the “Affected Public.” 

The “Affected Public” is comprised entirely of “Business, or other for profit” entities as 

described in the previous approved ICR renewal.

The OMB approved the current ICR without any ”Terms of Clearance.” 

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent 

Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart 

HHHHH) (Renewal). The burden to the “Federal government” is attributed entirely to work 

performed by Federal employees or government contractors; this burden may be found below in 
3

Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating Manufacturing (40 

CFR Part 63, Subpart HHHHH) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

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

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

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

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

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables, or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, emissions from miscellaneous coating manufacturers 

cause, or contribute to air pollution that may reasonably be anticipated to endanger public health, 

or welfare. Therefore, the NESHAP for Miscellaneous Coating Manufacturing was promulgated 

at 40 CFR part 63, subpart HHHHH.

2(b) Practical Utility/Users of the Data

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

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

collected information also is 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 requirements. Continuous emission monitors are used to ensure 

compliance at all times.

The notifications required in the standards are used to inform the Agency, or delegated 

authority when a source becomes subject to the requirements of the standard. The reviewing 

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

installed and operated and the standards are being met. The performance test also may be 
4

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 

HHHHH.

3(a) Non-duplication

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

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

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

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

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

Therefore, no duplication exists.

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

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

in the Federal Register at 74 FR 32580 on July 8, 2009. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

An industry consultation was conducted with Carolyn A. Wacker, (651) 737-3627, 

Specialist, Environmental Engineer, 3M Company. The 3M Company has five facilities that are 

complying with applicable requirements of this NESHAP. 3M estimated that the burden hours to 

the five facilities for ongoing compliance activities (Table 1, burden items 3C for semiannual 

reports excluding emissions averaging, items 4H and 4I) would not exceed the EPA estimates. 

The cost for LDAR and reporting is 100 to 200 hours per 3M facility; this ICR indicates 250 

hours are spent for the same activities. Generally, the 3M estimates confirm the burden hour 

estimates in this ICR. One 3M facility contracts out the LDAR monitoring. The contractor cost 

to this facility is $1,300 higher based on the EPA hourly rate for 30 hours. 

In addition to an industry-based consultation, the Agency’s industry experts have been 

consulted during a previous renewal of this ICR. Our internal data sources and the Agency’s 

projections for industry growth over the next three years were also considered. Our most 

relevant data source was the Air Facility System (AFS) which is operated and maintained by

EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and 

retrieval of all compliance data. The growth rate for the industry was based on our consultations 

with the Agency’s internal industry experts. An annual average of approximately 133 
5

respondents would be subject to the standard over the three year period covered by this ICR.

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 and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes.

It is our policy to carefully review any comments received since the last ICR renewal 

including those submitted in response to the first Federal Register notice and respond 

appropriately. In this case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5.

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

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

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

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

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

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

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

beyond five years. In addition, EPA would be prevented from pursuing the violators due to the 

destruction or nonexistence of essential records.

3(f) Confidentiality

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

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

subpart B - Confidentiality of Business Information (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).
6

3(g) Sensitive Questions

The reporting and 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 the owners, or 

operators of miscellaneous coating manufacturing facilities. The United States Standard 

Industrial Classification (SIC) codes for such facilities are 285 and 289, which correspond to the 

North American Industry Classification System (NAICS) codes 3255 and 3259.

4(b) Information Requested

(i) Data Items

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

Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH).

A source must make the following reports:

Notifications/Reports Regulation References

Initial notifications (including 

construction/reconstruction)

63.5, 63.9(b), and 63.8070(a)-(c)

Notification of performance test, test plan, and emission 

profile

63.7(b)-(c), 63.9(e), and 

63.8070(a),(d)

Notification of CMS performance evaluation 63.8(e)(2) and 63.9(g)

Notification of compliance status (including 

performance test results)

63.9(h), 63.10(d)(2), and 

63.8070(e)

Notification of process change 63.8070(f)

Emissions averaging plan 63.1250-63.1260, 63.8060

Precompliance report 63.8075(c)
7

Notifications/Reports Regulation References

Semiannual compliance report

$ Startup, shutdown, and malfunction reports

$ Deviations/no deviations/out-of-control CMS

$ No out-of-control CMS

$ Heat exchange system reports (delay of repair)

$ Maintenance and inspection reports for storage tank 

control devices

$ Operating scenario reports

$ Equipment leak reports

$ Emissions averaging reports

63.10(e)(3) and 63.8075(b),(d)

63.10(d)(5) and 63.8075(d)(4)

63.8075(d)(5)

63.8(c)(7), 63.8075(d)(6)

63.104(e), (f)(2)(i)-(iv), 

63.8075(d)(7)

63.1063(c)(2)(iv)(B) or (e)(2), 

63.8075(d)(8)

63.8075(d)(9)

63.1039(b)(1)-(8) and 

63.8075(d)(10)

63.1250-63.1260, 63.8060

A source must keep the following records:

Recordkeeping Requirements Regulation Reference

Record retention 63.10(b)(1) and 63.8085

Documentation supporting initial notifications and 

notifications of compliance status

63.10(b)(2)(xiv) and 63.8080(a)(1)

Startup, shutdown, and malfunction plan 63.6(e)(3)

Records related to startup, shutdown, and malfunction 63.6(e)(3)(iii)-(iv) and 

63.8080(a)(2)

Records of performance tests and CMS performance 

evaluations

63.10(b)(2)(viii) and 63.8080(a)(3)

Records for equipment leaks 63.1038(b)-(c) and 63.8080(a)(4)

Daily schedule or log of each operating scenario 63.8080(a)(5)

Records for process vessels complying with percent 

reduction emission limitation

63.8080(a)(6)

Planned routine maintenance records for storage tank 

control devices

63.8080(a)(7)

Maintenance wastewater plan 63.8080(a)(8)

Records for safety device openings 63.8080(a)(9)

Results of each CMS calibration, validation check, and 

inspection

63.8035(c)(6)-(8), (d)(4)-(5), (e)(4)-

(7), (f)(3)-(4), 63.8080(a)(10)

Records for emissions averaging 63.1250-63.1260, 63.8060

Records for each CMS 3.8(d)(3), 63.8(f)(6)(i), 

63.10(b)(2)(vi)-(xi), and 63.8080(b)

Electronic Reporting

Also, regulatory agencies, in cooperation with the respondents, continue to create 
8

reporting systems to transmit data electronically. However, electronic reporting systems are still 

not widely used. At this time, it is estimated that approximately 20 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate opacity and/or parameter monitors

Perform initial performance test and repeat performance tests if necessary

Write the notifications and reports listed above

Enter information required to be recorded above

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

systems for the purpose of collecting, validating, and verifying information

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

maintaining information

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

providing information

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

Transmit, or otherwise disclose the information

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).
9

5(b) Collection Methodology and Management

Following the notification of startup, the reviewing authority may inspect the affected 

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

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

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

published for use in compliance and enforcement programs. Immediate startup, shutdown and 

malfunction notifications and reports alert the Agency to atypical operations conditions which 

result in violations of the emission limitations. Semiannual reports are used for problem 

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

determinations.

Information contained in the reports is entered into the Air Facility System (AFS), which 

is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the 

collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial 

and government-owned facilities. EPA uses the AFS for tracking air pollution compliance and 

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

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

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

years.

5(c) Small Entity Flexibility

Based on review of the following sources: Final Rule (71 FR 58499); Proposed Rule (71 

FR 28639); Summary of Public Comments and Responses (EPA 450/R-02-XXXX, August 

2003); and the Implementation Tool for the Miscellaneous Coating Manufacturing NESHAP 

(EPA-305-B-06-003, Sept. 2006), an estimate of the number of small entities affected by this rule 

could not be determined.

Based on the previous ICR renewal, there are few, if any, small entities (i.e., small 

businesses) affected by this regulation. However, any impact on small entities was taken into 

consideration during the development of the standard. Generally, only major sources of pollution 

are regulated under the standard.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost - NESHAP for Miscellaneous 

Coating Manufacturing (40 CFR part 63, subpart HHHHH) (Renewal).

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 respondents. The individual burdens are expressed 
10

under standardized headings believed to be consistent with the concept of burden under the 

Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been 

identified. Responses to this information collection are mandatory.

6(a) Estimating Respondent Burden

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

reporting requirements applicable to the respondents. 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. 

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $100.99 ($48.09 + 110%) 

Technical $87.97 ($41.89 + 110%)

Clerical $43.81 ($20.86 + 110%)

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

December, 2005, ”Table 2. Civilian Workers, by Occupational and Industry group.” The rates 

are from column 1, ”Total compensation.” The rates have been increased by 110 percent to 

account for the benefit packages available to those employed by private industry.

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

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

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

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

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

ongoing costs to maintain the monitors and include other costs, such as photocopying and 

postage.

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

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

(A)

Continuous 

Monitoring

(B)

Capital/Startup 

Cost

(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)
11

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

(A)

Continuous 

Monitoring

(B)

Capital/Startup 

Cost

(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)

Process 

Vessels $30,000 1 $30,000 $16,000 132 $2,112,000

Transfer 

Operations N/A N/A N/A $3,100 132 $409,200

Wastewater 

Systems N/A N/A N/A $2,000 132 $264,000

Totals $30,000 $2,785,200

The total capital/startup costs for this ICR are $30,000. This is the total of column D in 

the above table. The total operation and maintenance (O&M) costs for this ICR are $2,785,200. 

This is the total of column G.

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

industry over the next three years of the ICR is estimated to be $2,815,000 per year.

6(c) Estimating Agency Burden and Cost

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

information. The EPA compliance and enforcement program includes activities such as the 

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

emissions, and the publication and distribution of collected information.

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

$41,417.

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

Managerial $57.20 (GS-13, Step 5, $35.75 x 1.6) 

Technical $42.45 (GS-12, Step 1, $26.53 x 1.6)

Clerical $22.96 (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) ”2006 General 

Schedule“ which excludes locality rates of pay. Details upon which this estimate is based appear

below in Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating 

Manufacturing (40 CFR part 63, subpart HHHHH) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 9 
12

of the 132 existing respondents will be subject to the standard. It is estimated that one additional 

respondent per year will become subject over the three-year period covered by this ICR.

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

years covered by this ICR.

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(D)

Number of Existing 

Respondents That 

Are Also New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 131 0 0 132

2 1 132 0 0 133

3 1 133 0 0 134

Average 1 133 0 0 133

1

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

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

average Number of Respondents over the three year period of this ICR is 133.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total Annual 

Responses

E=(BxC)+D

Notification of 

construction/reconstruction 1 1 N/A 1

Notification of anticipated 

startup

1 1 N/A 1

Notification of actual startup 1 1 N/A 1

Notification of applicability of 

standard

1 1 N/A 1

Emission averaging plan 1 0 N/A 0

Precompliance report 1 1 N/A 1

Notification of initial 

performance test 1 0 N/A 0
13

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 initial CMS 

performance evaluation 1 0 N/A 0

Notification of compliance 

status 1 1 N/A 1

Notification of process change 13 1 N/A 13

Semiannual report 132 2 N/A 264

Startup, shutdown, malfunction 

report 7 1 N/A 7

LDAR report 132 2 N/A 264

Emission averaging report 13 1 N/A 13

Total 567

The number of Total Annual Responses is 567.

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The annual labor hours are 167,572 per year over the three years of this ICR. The total 

annual labor costs are $14,192,714. The annual public reporting and recordkeeping burden for 

this collection of information is estimated to average 296 hours per response. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP 

for Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH) (Renewal).

The total annual capital/startup and O&M costs to the regulated entity are $2,815,200. 

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

1,001 labor hours at a cost of $41,416. See below Table 2: Average Annual EPA Burden -

NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63, subpart HHHHH)

(Renewal)
14

6(f) Reasons for Change in Burden

There is no change in the calculation methodology for labor hours or costs to the 

respondents in this ICR compared to the previous ICR. This is due to two considerations: (1) the 

regulations have not changed over the past three years and are not anticipated to change over the 

next three years; and (2) the growth rate for respondents is very low, negative, or non-existent. 

Therefore, the labor hours and cost figures in the previous ICR reflect the current burden to the 

respondents and are reiterated in this ICR. 

In the previous ICR renewal, the total respondent burden approved in the “Notice of 

Office of Management and Budget Action” was 167,832 hours. This burden does not match the 

total burden as calculated below in Table 1 of the Supporting Statement. This ICR uses the same 

calculation methodology as the past ICR renewal. This renewal requests approval of 167,572 

hours—260 less hours than previously approved.

6(g) Burden Statement

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

is estimated to average 296 hours per response. Burden means the total time, effort, or financial 

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

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

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

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

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

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

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

the information.

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

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

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

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

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

Docket ID Number EPA-HQ-OECA-2009-0405. An electronic version of the public docket is 

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

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

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

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

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

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

Room 3334, 1301 Constitution Avenue, N.W., Washington, D.C. 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 
15

telephone number for the docket center is (202) 566-1752. Also, you can send comments to the 

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

Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the 

EPA Docket ID Number EPA-HQ-OECA-2009-0405 and OMB Control Number 2060-0535 in 

any correspondence. 

Part B of the Supporting Statement

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

information.
Table 1: Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, 

Subpart HHHHH) (Renewal)

A B C D E F G H I

Burden 

hours per 

occurrence

Number of 

occurrences 

per year

Technical 

hours per 

respondent 

per year

Respondents 

per yeara

Technical 

hours per 

respondent

Management 

hours per year

Clerical hours 

per year

Respondent 

hours per year

Labor Cost, $

 Burden item

(C = A * B) (E = C * D) (F = E * 0.05) (G = E * 0.1) (H = E + F + G)

1 Applications N/A 

2 Surveys and Studies N/A 

3 Reporting Requirements

A. Read Instructionsc1.0 1.0 1.0 1 1.0 0.1 0.1 1.2 97

B. Required Activities 

Initial CMS performance 

evaluationd

10.0 1.0 10.0 0 0.0 0.0 0.0 0.0 0

Create Information Included in item 4 

Gather Existing Information Included in item 4 

C. Write Reports

Notification of 

construction/reconstruction

2.0 1.0 2.0 1 2.0 0.1 0.2 2.3 195

Notification of anticipated 

startup

2.0 1.0 2.0 1 2.0 0.1 0.2 2.3 195

Notification of actual startup 2.0 1.0 2.0 1 2.0 0.1 0.2 2.3 195

Notification of applicability of standard

1. Existing sources 2.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0

2. New sources 2.0 1.0 2.0 1 2.0 0.1 0.2 2.3 195
17

Emissions averaging plane40.0 1.0 40.0 0 0.0 0.0 0.0 0.0 0

Precompliance reportf40.0 1.0 40.0 1 40.0 2.0 4.0 46.0 3,896

Notification of initial 

performance testg

2.0 1.0 2.0 0 0.0 0.0 0.0 0.0 0

Notification of initial CMS 

performance evaluationd

2.0 1.0 2.0 0 0.0 0.0 0.0 0.0 0

Notification of compliance status

1. With performance testg80.0 1.0 80.0 0 0.0 0.0 0.0 0.0 0

2. Without performance testg120.0 1.0 120.0 1 120.0 6.0 12.0 138.0 11,688

Notification of process changeh8.0 1.0 8.0 13 104.0 5.2 10.4 119.6 10,130

Semiannual compliance report

 1. No Deviationsi8.0 1.0 8.0 119 952.0 47.6 95.2 1,094.8 92,725

 2. Deviationsi24.0 1.0 24.0 13 312.0 15.6 31.2 358.8 30,389

Startup, shutdown and 

malfunction reportj

8.0 1.0 8.0 7 56.0 2.8 5.6 64.4 5,454

LDAR reportk125.0 2.0 250.0 132 33,000.0 1,650.0 3,300.0 37,950.0 3,214,217

Emission averaging reportl20.0 1.0 20.0 13 260.0 13.0 26.0 299.0 25,324

Subtotal Reporting 40,081 40,081 $3,394,700

4 Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities N/A 

C. Implement Activities N/A

D. Develop Record Systemm40.0 1.0 40.0 1 40.0 2.0 4.0 46.0 3,896

E. Develop Startup, Shutdown, 

Malfunction Plann

100.0 1.0 100.0 1 100.0 5.0 10.0 115.0 9,740
18

F. Develop QA/QC Plan for 

CMSo

40.0 1.0 40.0 0 0.0 0.0 0.0 0.0 0

G. Time for Audits N/A

H. Time to Enter Information

 1. Records of startup, 

shutdown and malfunction

1.5 1.0 1.5 132 198.0 9.9 19.8 227.7 19,285

 2. Records of CMS data

 a. Record Continuously 

monitored parameters

1.0 365.0 365.0 132 48,180.0 2,409.0 4,818.0 55,407.0 4,692,756

 b. Compile data 24.0 2.0 48.0 132 6,336.0 316.8 633.6 7,286.4 617,130

 c. Information for semiannual 

reports

16.0 2.0 32.0 132 4,224.0 211.2 422.4 4,857.6 411,420

 d. LDAR recordkeeping Included in 3C

I. Calibration of CMS 376.0 1.0 376.0 132 49,632.0 2,481.6 4,963.2 57,076.8 4,834,182

J. Personnel Trainingp40.0 1.0 40.0 1 40.0 2.0 4.0 46.0 3,896

K. Refresher Coursep16.0 1.0 16.0 132 2,112.0 105.6 211.2 2,428.8 205,710

L Time for Audits N/A 0.0 0.0 0.0 0.0 0

Subtotal Recordkeeping 127,491 127,491 $10,798,014

Totals 167,572 167,572 $14,192,714

Assumptions:

a

132 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b Labor cost assumes a rate of $87.97/hour for technical labor, $100.99/hour for management labor, and $43.81/hour for clerical labor.

c This will occur only in the first year after a facility becomes subject to the rule.

d Assumes 10 hours to conduct a CMS performance evaluation and 2 hours to prepare a notification.

e Assumes that all existing facilities have complied with the emissions averaging requirements; new facilities are not allowed to use emissions averaging.

f Assumes 50 percent of the new facilities will submit a precompliance report [50% x 1= 1 (rounded)].

g Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. 

h Assumes 10 percent of the facilities will implement process changes [(10% x 132= 13 (rounded)].
19

i Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations [90% x 132=119 (rounded), 10% x 132 = 13 (rounded)]. 

j Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan [5% x 132 = 7 (rounded)}.

k Assumes all facilities will be subject to the equipment leak standards with an average of 125 hours per report.

l Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply [10% x 132 = 13 (rounded)].

m Assumes 40 hours to develop a record system for recording parameter monitoring information.

n Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours.

o Assumes 40 hours to develop/review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule.

Assumes no facilities will use the alternative standard, which requires CEMS and QA/QC plans.

p Assumes 40 hours to train personnel and 16 hours for an annual refresher course.
20

Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, 

Subpart HHHHH) (Renewal)

Activity

A B C D E F G

Agency 

hours per 

occurrence

Occurrences 

per yeara

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours per 

year

Total hours per 

year

Labor 

Costb, $

(C = A * B) (D = C * 

0.05) 

(E = C * 

0.1) 

(F = C + D 

+ E) 

Notifications/Reports

A. Performance Testc

8 0 0 0 0 0 0

B.

 Repeat Performance Testd8 0 0 0 0 0 0

C. CMS Performance Evaluatione

4 0 0 0 0 0 0

D. Review Notification of 

Construction/Reconstruction 2 1 2 0.1 0.2 2.3 95

E. Review Notification of 

Anticipated Startup 2 1 2 0.1 0.2 2.3 95

F. Review Notification of 

Actual Startup 2 1 2 0.1 0.2 2.3 95

G. Review Notification of 

Applicability of Standard 2 1 2 0.1 0.2 2.3 95

H. Review Emissions 

Averaging Planf 12 13 156 7.8 15.6 179.4 7,427

I. Review Precompliance 

Reportg 4 1 4 0.2 0.4 4.6 190

J. Review Notification of

Initial Performance Test 2 0 0 0 0 0 0

K. Review Notification of 

Initial CMS Performance 

Evaluatione

2 0 0 0 0 0 0
21

L. Review Notification of 

Compliance Status

 1. With performance testh

4 0 0 0 0 0 0

 2. Without performance 

testi 4 1 4 0.2 0.4 4.6 190

M. Review Notification of 

Process Changej 6 13 78 3.9 7.8 89.7 3,713

N. Review Semiannual 

Compliance Report

O. No deviationsk

2 119 238 11.9 23.8 273.7 11,330

P. Deviationsk

4 13 52 2.6 5.2 59.8 2,476

Q. Startup, shutdown, and 

malfunction reportl 2 7 14 0.7 1.4 16.1 666

R. LDAR reportm

2 132 264 13.2 26.4 303.6 12,568

S. Emissions averaging reportf

4 13 52 2.6 5.2 59.8 2,476

Totals 870 44 87 1,001 $41,416

Assumptions:

a

132 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b Labor cost assumes a rate of $42.45/hour for technical labor, $57.20/hour for management labor, and $22.96/hour for clerical labor.

c Assumes no initial performance tests because all facilities will comply by submitting engineering calculations.

d Assumes no repeat performance tests.

e Assumes no performance evaluations are required for the parameter monitoring systems included in the rule.

f Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply [10% x 132 = 13 (rounded)].

g Assumes 50 percent of the new facilities will submit a precompliance report [50% x 1= 1 (rounded)].

h Assumes one new facility will conduct initial performance tests.

i Assumes all existing facilities have complied by submitting engineering calculations.

j Assumes 10 percent of the facilities will implement process changes [(10% x 132= 13 (rounded)].
22

k Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations [90% x 132=119 (rounded), 10% x 132 = 13 (rounded)]. 

l Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan [5% x 132 = 7 (rounded)}.

m Assumes all facilities will report the specified information for processes subject to the equipment leak standards.