1 PART A OF THE SUPPORTING STATEMENT
1. Identification of the Information Collection 1 (a) Title and Number of the Information Collection. “Information Collection Request Survey for the Aerospace Manufacturing and Rework Industry .” This is a new informati on collection request (I CR), and the EPA I CR number 2395.01
. The OMB Control number is 2060
-NEW
. 1 (b) Short Characterization
. This information collection survey for aerospace manufacturing and rework facilities was prepared by EPA’s Sector Policies and P rograms Division (SPPD) in the Office of Air Quality

Planning and Standards (OAQPS) , and they are the intended users of the collected data . Respondents are owners or operators of aerospace manufacturing and rework facilities
. Aerospace manufacturing and rework was listed as a source category under the Clean Air Act (CAA) on July 16, 1992 (57 FR 31576). The C AA requires that a risk and technology review (RTR) be conducted for this source category by September 1, 2003
. This information collection will pro vide SPPD with th e data necessary to conduct the RTR
. This survey

was developed specifically for aerospace manufacturing and rework facilities. This information collection has been tailored to the processes at aerospace facilities and uses an electroni c submission approach that will be less burdensome for both the facilities that must respond and for EPA personnel who must compile the responses. Respondents are asked to complete simple forms from available information and no request is made to create o r develop emission estimates from information in the literature.2 In formation is requested from approximately 1,000 aerospace manufacturing and rework facilities on general facility information, coatings and spray booth information, other process infor

mation (e.g., storage tanks, composite processing, etc.), emission control devices in place and their basic design and operating featu res, quantity

of air emissions, pollution prevention programs at each facility , and information regarding startup and shut down events . This information is necessary for EPA to adequately characterize residual risk at these facilities, to characterize emissions and control measures for operations not currentl y regulated , and to develop standards for new and existing aerospace facilities under section 112 of the CAA, if appropriate. The information will be collected from the electronic completion of simple forms, which will be compiled to develop a computer database. The completed forms and the computer database will become p art of the rulemaking docket. EPA estimates that there will be roughl y 1,000 survey respondents and that they will in cur a total burden of 46,955 hours at an estimated cost of $ 2,261,288 as a result of this one

- time collection. The cost to the Agency i s estimated to be approximately $ 47,633
. 2. Need For and Use of the Collection 2 (a) Need/Authority for the Collection
. The EPA is charged under section 112 of the CAA with developing national emission standards for 189 listed HAP. The Aerospace Manufacturing and Rework Facilities Maximum Achievable Control Technology (Aerospace MACT) standard (40 CFR 6 3 , subpart GG), is a National Emission Standard for Hazardous Air Pollutants (NESHAP) developed under the authority of section 112(d) of the CAA. EPA is re quired3

to review each MACT standard and to revise them “as necessary (taking into account developments in practices, processes and control technologies)” no less frequently than every eight years. These reviews are commonl y referred to as “technology revi ews.” In addition, EPA is required to assess the risk remaining (residual risk) after each MACT standard and promulgate more stringent standards if they are necessary

to protect public health. Under EPA’s RTR program, EPA is addressing these two requirem ents concurrently
. EPA is updating the information they currently possess and filling identified data gaps in that information in order to provide a thorough basis for the RTR efforts. The data collection effort will gather additional information to allo w comprehensive and technically sound anal ys es that will form the basis for future rulemaking decisions. The information is being collected under the authority of section 114 of the CAA. 2 (b) Practical Utility/Users of the Data

. The S PPD of the O AQPS use s the information gathered through the survey form to conduct the RTR , on which future rulemaking decisions will be based. 3. Nonduplication, Consultations and Other Collection Criteria 3 (a) Nonduplication . To the best of EPA’s knowledge, the data to be collected through this survey is not available elsewhere. A search of EPA’s ongoing information collections revealed no duplication of information gathering efforts, and the information that will be requested is not available through other sources. In 19 94 , EPA surveyed aerospace manufacturing and rework facilities to gather information to develop MACT s tandards for the aerospace industry . That survey was4

sent to a small portion of the industry and did not ask for information about certain aerospace m anufacturing operations and emission source types. The current survey does not duplicate the previous survey
. Furthermore, in response to changes in market conditions and regulatory requirements (such as the OSHA hexavalent chromium exposure limit), EPA expects that many aerospace facilities have changed their coatings , enclosed their spray

booth operations and reduced HAP content in solvents since 19 94
. To the extent that some of the questions in this survey are similar to those in the previous survey , many of the answers that facilities will provide may have changed in the intervening ye ars. Because the current survey will collect different and updated information as compared to the previous survey , the data collected in 19 94 does not fulfill EPA’s cur

rent needs, and the current survey is not duplicative of the previous survey . 3 (b) Public Notice Required Prior to ICR Submission to OMB . Pursuant to the Paperwork Reduction Act (PRA) (44 U.S. C 3501 et seq. ), the EPA notified the public through a Federal Register notice ( see XX FR XXXX, date ) of the Agency ’s intent to submit the Aerospace Industry Survey I CR to OMB. The notice included a description of the entities to be affected by the proposed survey , a brief explanation of the need for the survey , identification of the statutory authority under which the survey

will be issued, and an estimate of burden to be incurred by survey respondents. Through the notice, the Agency requested comments and suggestions regarding the survey

and the reduction of data collection burden . A summary of the comments EPA received and EPA’s responses are included in Attachment 3
. 3 (c) Consultations .5 Under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with potential I CR respondents and data users about specific a spects of I CRs before submitting an original or renewal ICR to OMB for review and approval. EPA sent out a letter providing potential respondents with a list of the data elements that will be included in the survey and requested feedback on these data elements via written communication or by participation in a conference call with EPA. This teleconference meeting was held December 18, 2009 , at the EPA facilities in Research Triangle Park, NC. The list of data elements is included as Attachment 2 to this supporting statement. The letter was sent to relevant trade organizations and to over 1,200 facilities believed to be aerospace manufacturing or rework facilities. No feedback, either written or at the meeting, was provided b y potential respondents direc tly relating to the data elements of the survey
. Some facilities did respond to the letter to inform EPA that they were not aerospace manufacturing and rework facilities or were area sources. 3 (d) Effects of Less Frequent Collection . This survey

is to b e administered one time onl y. If this survey is not conducted, the specific data sought in this survey will not be available for EPA’s use in decision making about the need for and scope of potential residual risk rules for the aerospace industry
.6

3 (e) General Guidelines . This information collection complies with the guidelines in 5 CFR 1320. 5(d)(2)
. 3 (f) Confidentiality . All information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency pol icies 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 39999, September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979.) 3 (g) Sensitive Questions . This section is not applicable because this survey does not involve matters of a sensitive nature. 4. The Respondents and the Information Requested 4 (a) Respondents/

NAICS Codes . Respondents associated with this information coll ection are owners or operators of existing aerospace manufacturing and rework facilities. The North American Industrial Classification Codes (NAICS) associated with this industry are presented in Table 1. Table 1. North American Industrial Classification Codes for the

Aerospace Manufacturing and Rework Industry NAICS Code Description 336411 Aircraft Manufacturing 336412 Aircraft Engine and Engine Parts Manufacturing 336413 Other Aircraft Parts and Auxiliary Equipment Manufacturing 336414 Guided M issile and Space Vehicle Manufacturing7 336415 Guided Missile and Space Vehicle Propulsion Units and

Propulsion Units Parts Manufacturing 336419 Other Guided Missile and Space Vehicle Parts and Auxiliary Equipment Manufacturing 481111 Scheduled Passeng er Air Transportation 481112 Scheduled Freight Air Transportation 481211 Nonscheduled Chartered Passenger Air Transportation 481212 Nonscheduled Chartered Freight Air Transportation 481219 Other Nonscheduled Air Transportation
Approximately 1,000 aer ospace manufacturing and rework facilities have been identified to receive this survey . EPA p rojects a total of about 1,000 responses under this I CR. 4 (b) Information Requested. 4(b)( i) Data items, including recordkeeping requirements. A copy of the s urvey and instructions are provided as Attachment 1. There are no recordkeeping requirements associated with this request. Information is requested from each respondent on general facility information, coating and spray booth information, other processes (e.g., storage tanks, metal finishing, etc.), air emissions from these booths and other processes, and identification of capture and control devices. Part I (In troduction ) provides guidance to the respondent and highlights that no additional monitoring or testing is required to respond to the request. The introduction list s an EPA contact for questions and provide s the name and address to which the completed survey

should be mailed. Instructions are also provided for submitting the completed form elec tronically
. Finall y, an outline of the questionnaire form is provided. Part II (Instructions) provides instructions on how to complete each form in the questionnaire. There are general instructions and instructions specific to each form.8 Form A

- 1 (Parent Company Information) asks for information about the parent company, and size of the parent company, in order for EPA to conduct an appropriate economic analy sis for this category and evaluate potential small entity impacts. Form A

- 2 (Facility Inform ation) is where the respondent (facility contact person), company and facility are identified. EPA will use this information to ensure that its facility list is current and accurate, a necessary component of achieving to represent the univer se of sources in any anal ys es. Coordinates are requested, along with a ty pical operating schedule for the facility. In addition, questions are asked about the products produced at the facility

and if the facility is a major source of HAP emissions. Form B

- 1 (Spray Bo oth Information) requests data for ea ch spray booth at the facility , including the typ e of booth, the location coordinates of each booth, and the dimensions of each booth. In formation is also requested on the ty pe of particulate filter sy stem used in the booth. Control device information should also be provided. Form C

- 1 and C

- 2 (Coatings) are the same form except one requests the information in English units and the other requests the information in metric units. Respondents do not have to fill out b oth forms, but can fill out whichever one utilizes the data they have easil y available. In formation is requested on the ty pe of coating, including specialty coatings and the HAP contained in each coating. The forms also include a section for the respondents to identify the spray booth that each coating was applied in and the amount of coating that was applied. Form D

- 1 (Chemical Milling and Metal Finishing Operations) requests HAP usage and emissions from chemical milling and metal finishing operations at the facility.9

Coordinates, dimensions and hours of operation are requested for each tank. Control device and work practice information is also requested. Form E

- 1 (Blast Depainting/Cleaning Operations) is where the respondent will report HAP emissio ns from blast depainting and cleaning operations that use blasting methods. In addition to emissions, coordinates, dimensions and hours of operation are also requested. Control device and work practice information should also be recorded on this form. F orm E

- 2 (Solvent Depainting Operations) is where the respondent will report HAP emissions from depainting operations that use solvent materials. The same information is requested (e.g., emissions, coordinates, control device) as in Form E

- 1. Form E

- 3 (So lvent Cleaning Operations) requests information on HAP emissions from solvent cleaning operations such as hand

- wipe cleaning of aerospace components, cleaning of spray

guns and cleaning of spray booths. In addition to HAP emissions, information is request ed on location coordinates, building dimensions, control devices and work practices. Form E

- 4 (Solvent Cleaning Operations) requests information similar to that requested on Form E

- 3, except that only cleaning operations subject to the Halogenated Solvent Cleaning NESHAP (40 CFR 63, subpart T) should be reported. Even though halogenated solvent cleaning operations are not subject to the aerospace NESHAP, the EPA is concerned that some aerospace facilities may have mistakenl y reported emissions from thes e operations as emissions from operations subject to the aerospace NESHAP in part reporting to s tate or local agencies. In order to estimate the residual risk accuratel y from each of these categories, the EPA is attempting to first develop accurate emissi ons10

estimates. The respondents’ efforts to properl y report halogenated solvent cleaning operations on Form E

- 4 and not on Form E

- 3 will play an important role in the EPA’s development of emissions estimates from these two categories. Form F

- 1 and F

- 2 ( Composite Processing Operations) are the same form except one requests the information in English units and the other requests the information in metric units. Respondents do not have to fill out both forms, but can fill out whichever one utilizes the dat a they

have easily

available. Information is requested on the ty pe of resins used in composite processing operations, the total volume of resin used and information related to the spray booth used to apply

the resins. Form G

- 1 (Storage Tanks) is where the respondent will provide HAP emissions from storage tanks used to store materials used in aerospace manufacturing and rework operations. The type of tank, the coordinates of the tank, the dimensions of the tank, the HAP component of the material in the tank and control device information are all requested. Form H

- 1 (Wastewater Treatment Operations) requests information on wastewater treatment operations as they pertain to aerospace manufacturing and rework operations. The coordinates, dimensions, ho urs of operation, HAP emissions and control device information are all requested. Form I

- 1 (Startups and Shutdowns) provides examples of startup and shutdown events that would be reported on this form. Information on this form is requested if it is
readil y available. Additional testing or data gathering is not required to complete this form for startup and shutdown events.11 Forms J

- 1 to J

- 11 (Air Pollution Control Devices) provide a form for each control device likel y to be in use at aerospace manufact uring and rework facilities. If an air pollution control device is not in use at the facility, the relevant form does not need to be filled out. The information requested for these forms should be readily available. No additional testing or data gathering is required in order to complete these forms. Form K

- 1 (Air Pollution Control Device Costs) is where the respondent will enter readil y available information related to the cost of each air pollution control device for which information was provided in Forms J
- 1 to J
- 11
. 4(b)( ii) Respondent activities. The survey will be sent to each aerospace manufacturing and rework facility , who will be asked to complete and return the survey instrument. Completion of the survey involves the following steps:

 Revi ewing instructions : Respondents will need to read the instructions for the survey ;

 Search data sources : Respondents may need to consult records and review facility

information , in addition to gathering available data from files, regarding coating usage, booth ty pes, and other requested information prior to completing the survey ;

 Complete and review the collection of information : Respondents will need to complete the survey and review their answers; and

 Transmit or otherwise disclose the information : Res pondents will need to return the completed survey to EPA. The request does not require respondents to make measurements of emissions or otherwise create information, and it relies on information that should be readily available12

to the respondent. Consequently , it is consistent and compatible with existing reporting and recordkeeping requirements because the survey asks onl y for this existing information. There is no need for respondents to develop or acquire technology or sy stems to collect, process or di sclose the information. Non
- respondents will receive up to two reminder calls encouraging them to participate. If EPA decides to issue subpoenas because it does not receive a sufficient response rate to accurately characterize the industry, the initial n on - respondents will need to review the subpoena, as well as following the steps outlined above. This questionnaire asks for readil y obtainable information, e.g., information known or easil y accessible by technical, managerial or supervisory employees of the facility who are responsible for manufacturing, processing, technical services or marketing. The facility

does not need to generate new information to complete the survey . The collection will be a one

- time event, and there will be no requirement for respondents to maintain records to support their responses. However, EPA is suggesting that respondents keep a copy of the completed questionnaire for their files in case the Agency contacts them with any

follow

- up questions after reviewing their respons es. 5. The Information Collected

– Agency Activities, Collection Methodology and Information Management 5 (a) Agency Activities . Agency activities associated with the information collection include preparing the questionnaire, answering respondent ques tions about the questionnaire, reviewing data submissions, addressing requests for confidentiality and compiling the data into a database.13

5 (b) Collection Methodology and Management. Data collection will be accomplished using an electronic survey tool. Recipients of the letter announcing the survey ’s availability will be directed to an EPA web page to download the files. The respondent will be asked to complete and return the survey within a three

- month timeframe. Respondents will be encouraged to compl ete an electronic cop y of the survey and upload it to the EPA web page, which reduces transcription errors when EPA processes the responses. Non

- respondents will receive up to two reminder calls encouraging them to participate. The web page will also hav e instructions on how to submit data that is CBI
. A written survey

is being used because some of the information EPA is requesting may require the respondent to consul t records or other documents at the facility, which would be difficult to do during a te lephone survey given the typ e of information requested and the number of potential respondents. In addition, the written survey method will allow the respondent to complete the survey at his or her convenience. Electronic transmission of the empty and co mpleted survey

forms will lead to more efficient data collection, both in terms of reducing mailing costs and paper usage and reducing transcription errors. The survey has been designed to be easil y compiled into a database upon receipt of the completed survey files. For this information collection, the submissions will be monitored for completeness, and follow

- up calls will be made to maximize the response rate. Confidential information will be maintained in secure locations as required by procedures for handling CBI. C onfidential Business Information will not be entered into the computer database. Public access to non

- CBI information will be provided through the14

rulemaking docket, which will contain the survey responses and a copy

of the resulting d atabase. 5 (c) Small Entity Flexibility . EPA has identified a list of roughly 1,000 U.S. facilities with aerospace manufacture or rework operations. Some of these manufacturers are small businesses as defined b y the Small Business Administration’s size st andards. EPA considered collecting data from onl y a sample of manufacturers, but determined that a census (a survey administered to the entire population of aerospace manufacturing and rework facilities, including small businesses) is appropriate. A census will more accuratel y characterize the industry . EPA needs to include small businesses in the survey so that it can better estimate potential small business impacts in the event the Agency ultimatel y decides to proceed with a regulatory action. In developing the information request, SPPD considered whether a separate request or no request for information should be made to small facilities. A major consideration was that the burden of responding to the questionnaire is not excessive for small faciliti es. Because they have fewer and simpler processes, smaller facilities will require less time to prepare a response than larger facilities. The information requested from the smaller facilities should be readil y available and no requests are made to perfo rm measurements or create information. Many of the aerospace manufacturing and rework facilities meet the definition of small business (e.g., companies with fewer than 1 , 00 0 or 1,500 employees total at all facilities for facilities in NAI CS 2
- digit code 3 3, and companies with less than $7 million in annual average receipts for facilities in NAI CS 2
- digit code 48 ), and information from15

small entities is important to this regulatory development. The information collected from small entities will improve the anal ys es that must be performed to assess the economic impact of a potential MACT standard on them. A Regulatory Flexibility Analy sis must be performed under the Regulatory Flexibility

Act of 1980 if a proposed regulation will have a significant economic impact on a substantial number of small entities. The information from small entities will also assist in addressing the requirements of the Small Business Regulatory Enforcement Fairness Act of 1996. Although many of these small businesses are not like ly to be major sources of HAP emissions, information on emissions and the level of control performance achieved is needed from all facilities in the industry to determine with reasonable accuracy the “average emission limitation achieved” b y the top

- perfor ming 12 percent of sources. The coverage of small facilities is especiall y important if any are in this top 12 percent. In addition, the best controlled sources may include some of the smaller facilities, which would affect the determination of MACT for new aerospace facilities. Information on smaller facilities will aid in determining if a facility size cutoff is warranted, and if so, which of the smaller facilities should be exempt from the MACT standard. The information on small facilities will also provide insight into pollution prevention measures that might be applicable to larger facilities. Even if the smaller facilities are not major sources, the information from their responses to the survey will be useful in determining if they

are significant area sources that may warrant regulation.16

5 (d) Collection Schedule . The proposed mailing date for the survey is XXXX
. The respondents are given three months to repl y , with XXXX being the anticipated date when all data is available for anal ys is by

EPA
. The data will be used to develop residual risk standards , if warranted, with proposal targeted for August 20 11 and promulgation in June 2010
. 6. Estimating the Burden and Cost of the Collection 6 (a) Estimating Respondent Burden . EPA will request that all U.S. aerospace manufacturing and rework facilities complete the questionnaire forms. Each section of the questionnaire is expected to be completed b y technical and clerical staff and reviewed b y managerial staff. Respondent activities include reading th e cover letter and downloading the forms, reading the instructions, gathering data, manipulating data for entry into the forms, entering data into the forms and uploading the forms. The exhibit reflects the assumption that technical and clerical staff wil l devote their time to reading instructions, gathering information, completing the questionnaire form s and transmitting the information ; managerial staff will devote their time to reading instructions and reviewing questionnaire responses. Table 2 presents the average number of hours required for each task for respondents of three sizes: small, medium and large. Due to the wide range in sizes of aerospace facilities, it was necessary to estimate the burden for each size of facility
. Based on the indus try ’s facility size breakdown contained in the proposal Background Information Document for the Aerospace NESHAP, it is assumed that 84 percent of the respondents are small facilities, 14 percent are medium facilities and two percent are17

large facilities. There are approximately 1,000 respondents expected to complete the questionnaire. A ty pical small

- size facility respondent is estimated to need an average of 30.75 hours to complete the questionnaire , while a typical medium

- size facility respondent is estimated to need an average of 86.74 hours to complete the questionnaire and a ty pical large

- size facility

respondent is estimated to need an average of 142.75 hours to complete the questionnaire. These burden estimates include technical, management and clerical hours. Table 3 presents the burden estimate for small

- size facilities, while Table 4 presents the burden estimate for medium

- size facilities and Table 5 presents the burden estimate for large

- size facilities. These unit burden estimates are aver age values. As with any average, some respondents will be above the average and others will be below. 6 (b) Estimating Respondent Costs . The information collection activities and estimated costs for all respondents are presented in Table s 3, 4 and 5
. The costs are based on hourl y rates estimated as follows: technical at $ 49.80/hr , management at $ 62.08/hr and clerical at $ 24.79/hr
. For a typical small

- size facility respondent , the costs are estimated as $ 1,703 ( 30.75 hours) , while for a ty pical medium

- size facility respondent the costs are estimated as $ 4, 804 ( 86.75 hours) , and for a typical large

- size facility the costs are estimated as $ 7, 90 6 ( 142.75 hours)
. There are no capital or operation and maintenance costs. A summary of the burden and costs for all respondents is presented in Table 6. 6 (c) Estimating Agency Burden and Cost. The costs the f

ederal government would incur would be for preparing the questionnaire, answering respondent questions about the questionnaire, reviewing data18

submissions, addressing requests for confidentiality and compiling the data into a database. The burden estimate is presented in Table 7 at the end of this supporting statement. Hourl y labor rates were taken from the Office of Personnel Management Salary Table 2010

- GS (effective January 2010) and are as follows: technical (GS

- 12, Step 5) at $ 32.73 /hour, management (GS

- 15, Step 5) at $ 54.10 /hr, and clerical (GS

- 5, Step 5) at $ 14.90 /hr. The total costs for the Agency are estimated as $ 47,633
. 6 (d) Estimating the Respondent Universe and Total Burden and Costs . For small

- size facilities, the total burden shown in Table 3 is estimated as 1,291.5 management hours, 25,830 technical hours and 2,583 clerical hours at a cost of $ 1,430,54 3 . The total burden and costs are based on 840 small

- size aerospace facilities completing the survey
. For medium

- size facilities, the total burden shown in Table 4 is estimated as 607.3 management hours, 12,145 technical hours and 1,214.5 clerical hours at a cost of $ 672,62 7 . The total burden and costs are based on 140 medium

- size aerospace facilities completing the survey
. For large

- size facilities, the total burden shown in Table 5 is estimated as 142.8 management hours, 2,855 technical hours and 285.5 clerical hours at a cost of $ 1 58,118
. The total burden and costs are based on 20 large

- size aerospace facilities completing the survey . 6 (e) Bottom Line Burden Hours and Cost Tables . 6(e)( i) Respondent tally . The total respondent burden s are given in Table 6 and
are estimated a s 29,704.5 hours and $ 1,430,54 3 for small

- size respondents, 13,966.8 hours and $ 672,62 7 for medium

- size respondents and 3,283.3 hours and19

$ 158,118 for large

- size respondents
. For all respondents, the t otal burden is estimated as 46, 954.6 hours and $2,261, 28 8
. 6(e)( ii) The Agency tally. The total Agency burden is given in Table 7 and is estimated as 1,483.5 hours and $ 47,633
. 6(e)( iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated. 6 (f) Reasons for Change in Burden . This section does not apply since this is a new collection. 6 (g) Burden Statement. The average respondent burden for each small

- size facility is estimated as 30.75 hours and a cost of $ 1,703
. The average respondent burden for each medium

- size facility is estimated as 86.75 hours and a cost of $4, 804 . The average respondent burden for each large

- size facility

is estimated as 142.75 hours and a cost of 7, 90 6
. This includes time to read the cover letter and download the forms, read the instructions, gather data, manipulate data for entry into forms, enter data into forms and upload forms. No capital costs or operation and maintenance costs will be incurred. Burden means the total time, effort or financial resources expended b y persons to generate, maintain, retain or disclose or provide information to or for a f ederal agency
. This includes the time needed to review instructions; develop, acquire, install and utilize technology

and sy stems for the purposes of collecting, validating and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a co llection of20

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 currentl y valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. Send comments on the Agency ’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, O ffice of Policy , Planning and Evaluation (O PPE ) Regulatory Information Division, U.S. Environmental Protectio n Agency (2137), 401 M St., S.W., Washington, DC 20460; and to the Office of Information and Regulatory Affairs, O MB , 725 17 th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA I CR number and OMB control number in any c orrespondence.

PART B OF THE SUPPORTING STATEMENT This section is not applicable because statistical methods are not used in the data collection associated with this information collection.21

TABLE 2. ESTIMATED RESPONDENT BURDEN FOR THE AEROSPACE ICR

Task Technical Labor Hours by Facility Size Small Medium Large Read cover letter/download forms 0.75 0.75 0.75 Read instructions 1.5 1.5 1.5 Gather data 20 60 100 Manipulate data for entry into forms 4 12 20 Enter data into forms 4 12 20 Upload f orms 0.5 0.5 0.5 TOTAL TECHNICAL LABOR HOURS 30.75 86.75 142.7522 TABLE 3. ANNUAL RESPONDENT BURDEN AND COST FOR SMALL FACILITIES
Burden It em (A)

Person hours per respondent a (B)

Number of respondents (C)

Technical person hours (C = A x B) (D)

Management person hours (0.05 x C) (E)

Clerical person hours (0.1 x C) (F)

Costb ($) Read cover letter/download forms 0.75 840 630.0 31.5 63.0 34,891 Read instructions 1.5 840 1,260.0 63.0 126.0 69,783 Gather data 20 840 16,800.0 840.0 1,680.0 930,434 Manipulate data for entry into forms 4 840 3,360.0 168.0 336.0 186,087 Enter data into forms 4 840 3,360.0 168.0 336.0 186,087 Upload forms 0.5 840 420.0 21.0 42.0 23,260.86 TOTAL LABOR BURDEN AND COST 30.75 n/a 25,830.0 1,291.5 2,583.0 1,430,543

a See values in Table 1. b Costs were taken from the Bureau of Labor Statistics, National Compensation Survey, Employer Costs for Employee Compensation Supplementary Tables December 2007. Supplementary Table 2

– Emp loyer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment size and bargaining status. December 2007. Available on

- line at http://www.bls.gov/ect . The cost for technical person hours is $49.80/hour, taken from the total compensation value for the “professional and related” occupational group. The cost for management person hours is $ 62.08/hr, taken from the total compensation value for the “management, business and financial” occupational group. The cost for clerical person hours is $24.79/hr, taken from the total compensation value for the “office and administ rative support” occupational group.23 TABLE 4. ANNUAL RESPONDENT BURDEN AND COST FOR MEDIUM FACILITIES
Burden It em (A)

Person hours per respondent a (B)

Number of respondents (C)

Technical person hours (C = A x B) (D)

Management person hours (0.05 x C) (E)

Clerical person ho urs (0.1 x C) (F)

Costb ($) Read cover letter/download forms 0.75 140 105.0 5.3 10.5 5,815 Read instructions 1.5 140 210.0 10.5 21.0 11,630 Gather data 60 140 8,400.0 420.0 840.0 465,217 Manipulate data for entry into forms 12 140 1,680.0 84.0 168.0 93 ,043 Enter data into forms 12 140 1,680.0 84.0 168.0 93,043 Upload forms 0.5 140 70.0 3.5 7.0 3,877 TOTAL LABOR BURDEN AND COST 86.75 n/a 12,145.0 607.3 1,214.5 672,627

a See values in Table 1. b Costs were taken from the Bureau of Labor Statistics, National Compensation Survey, Employer Costs for Employee Compensation Supplementary Tables December 2007. Supplementary Table 2

– Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment size and bargaining status. December 2007. Available on

- line at http://www.bls.gov/ect . The cost for technical person hours is $49.80/hour, taken from the total compensation value for the “professional and related” occupational group. The cost for management person hours is $62.08/hr, taken from the total compensation value for the “management, business and financial” occupational group. The cos t for clerical person hours is $24.79/hr, taken from the total compensation value for the “office and administrative support” occupational group.24 TABLE 5. ANNUAL RESPONDENT BURDEN AND COST FOR LARGE FACILITIES
Burden It em (A)

Person hours per resp ondent a (B)

Number of respondents (C)

Technical person hours (C = A x B) (D)

Management person hours (0.05 x C) (E)

Clerical person hours (0.1 x C) (F)

Costb ($) Read cover letter/download forms 0.75 20 15.0 0.8 1.5 831 Read instructions 1.5 20 30.0 1.5 3.0 1,661 Gather data 100 20 2,000.0 100.0 200.0 110,766 Manipulate data for entry into forms 20 20 400.0 20.0 40.0 22,153 Enter data into forms 20 20 400.0 20.0 40.0 22,153 Upload forms 0.5 20 10.0 0.5 1.0 554 TOTAL LABOR BURDEN AND COST 142.75 n/a 2 ,855.0 142.8 285.5 158,118

a See values in Table 1. b Costs were taken from the Bureau of Labor Statistics, National Compensation Survey, Employer Costs for Employee Compensation Supplementary Tables December 2007. Supplementary Table 2

– Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufact uring industries, by occupational group, establishment size and bargaining status. December 2007. Available on

- line at http://www.bls.gov/ect . The cost for technical person hours is $49.80/hour, taken from the total compensation value for the “professional and related” occupational group. The cost for management person hours is $62.08/hr, ta ken from the total compensation value for the “management, business and financial” occupational group. The cost for clerical person hours is $24.79/hr, taken from the total compensation value for the “office and administ rative support” occupational group.25

TABLE 6. SUMMARY OF ESTIMATED RESPONDENT BURDEN FOR THE AEROSPACE ICR

Value b y Facility Size Small Medium Large Total Number of Respondents 840 140 20 Total Labor Hours 29,704.5 13,966.8 3,283.3 Labor Hours Per Respondent 30.75 86.75 142.75 Total Labor Cost ($) 1,430,543 672,62 7 158,118 Labor Cost Per Respondent ($) 1,703 4,804 7,90 626 TABLE 7 . ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT
Burden It em (A) EPA Hrs/Occurrence (B)

Contractor Hrs/Occurrence (C)

Number of Occurrences (D)

Total EPA Hrs (AxC) (E)

Total Contractor Hrs (B xC) (F)

Total Hrs (D+E) c Develop survey

and industry mailing list 50.0 350.0 1 50.0 350.0 400.0 Distribute survey 40.0 0.0 1 40.0 0.0 40.0 Answer questions a 0.1 0.25 200 20.0 50.0 70.0 Audit/review sub missions 0.25 0.1 1000 250.0 100.0 350.0 Enter into database/QA check 0.0 0.3 1000 0.0 300.0 300.0 Analyze submissions and summarize results 0.0 80.0 1 0.0 80.0 80.0 Respond to requests for confidentiality

b 0.3 0.2 100 30.0 20.0 50.0 TOTAL LABOR BURDEN AND COST n/a n/a n/a 390.0 900.0 1,290.0

a Itis assumed that questions will need to be answered for 20 percent of the respondents. b Itis assumed that responses to requests for confidentiality will be needed for 10 percent of the respondents. c For the purposes of the cost calculations in this table, it is assumed that EPA and Contractor hours for technical, management, and c lerical positions cost the same amount.27 TABLE 7. ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT (cont.)
Burden It em (G)

Technical person hours (=F) (GS12) (H)

Management person hours (G x 0.05) (GS15) (I)

Clerical person hours (G x 0.1) (GS5) (J) Cost d ($) Develop survey

and industry mailing list 400.0 20.0 40.0 14,770.00 Distribute survey 40.0 2.0 4.0 1,477.00 Answer qu estions a 70.0 3.5 7.0 2,584.75 Audit/review submissions 350.0 17.5 35.0 12,923.75 Enter into database/QA check 300.0 15.0 30.0 11,077.50 Analyze submissions and summarize results 80.0 4.0 8.0 2,954.00 Respond to requests for confidentiality

b 50.0 2.5 5 .0 1,846.25 TOTAL LABOR BURDEN AND COST 1 , 290.0 64.5 129.0 47,633.25 d Costs were taken from the U.S. Office of Personnel Management, Salary Table 2010

- GS, effective January 2010, available on

- line at http://www.opm.gov/oca/10tables/html/gs_h.asp . All hourly rates are baseline values. I

t was assumed that the technical person is a GS

- 12, Step 5 employee with a rate of $32.73 per hour, that the management person is a GS

- 15, Step 5 employee with a rate of $54.10 per hour, and that the clerical person is a GS

- 5, Step 5 employee with a rate of $14.90 per hour.