**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Boat Manufacturing (40 CFR**  **Part 63,**  **Subpart VVVV)**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal) , EPA I CR Number 1966.05 , OMB Control Number 2060

- 0546 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Boat Manufacturing were proposed on July 14, 2000 , promulgated on August 22, 2001 , and corrected on October 3, 2001 . These regulations appl y to both existing and new boat manufacturing facilities that are a major source of hazardous air pollutant (HAP) emissions

. This regulation covers resin and gel coat operations at fiberglass boat manufacturers, paint and coating operations at aluminum boat manufacturers, and carpet and fabric adhesive operations at all boat manufacturers. Air toxics are released during application and curing from the resins, gel coats, adhesives, coating, and solvents used in boat manufacturing. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart VVVV

. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the oc currence and duration of an y startup, shutdown, or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance , and are required of all affected facilities subject to NESHAP

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

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

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of 1.7 affected facilities 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 ye ars, an aver age of 144 respondents (143 private and 1 government entities ) per ye ar will be subject to the standard , and no additional respondents per ye ar will become subject to the standard. Of the 144 respondents, we expect that only one will choose to comply by l imiting the HAP content of their fiberglass or aluminum boat manufacturing processes and operations. The one facility alread y has an add

- on control device and will compl y2

with the add

- on control device standards. The remaining respondents will comply by using pollution prevention measures. The Office of Management and Budget ( OMB) approved the currentl y active I CR without any

“Terms of Clearance.” With the exception of one facilit y, a ll of the boat manufacturing plants in the United States are owned and operated b y the boat manufacturing industry ( i.e. the “Affected Public”). An additional facility

is owned and operated by the Federal government (e.g., the U.S. Marine Corps). With this one exception, they are all privately

- owned , for

- profit business es and none of these facilities in the United States are owned b y either state, or local, or tribal government s
. The “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal). The “ bur den ” to the Federal Government is attributed entirely to work performed by either F ederal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (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 maintai n 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, duri ng such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certification s in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from boat manufacturing processes and operations cause or contribute to air pollutio n that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63, subpart VVVV. **2(b) Practical Utility/Users of the Dat** a3

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 is also used for targeting inspections and as evidence in legal proceedings. Performanc e tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard s
. Continuous emi ssion monitors are used to ensure compliance with the standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired, and the standard s ar e being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations.
**3. Non** 
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart VVVV

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 78 FR 33409) on June 4, 2013

. No comments were received on the burden published in the Fed eral Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three y ears have been considered. The4

primary source of information as reporte d by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maint enance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard s as they w ere being developed and the standard s have been reviewed previously to determine the minimum information needed for compliance purposes. Indeveloping this ICR, we contacted : 1) the National Marine Manufacturers Association (NMMA) , at (202) 737

- 9757 ; and 2) the American Boatbuilders Association, Incorporated , at (770) 792

- 3070

. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Colle ction**  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 maint enance practices are applied and emission limitations are met. I f 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**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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

- ye ar records retention requirement is consistent with the Part 70 permit program and the f ive

- ye ar 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, an y pattern of non

- compliance and to determine the appropriate level of enforcement a ction. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any in formation 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 2,5

subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 369 02, 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**
T he 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 boat manufacturing facilities . The United States Standard Industrial Classification ( SI C ) code for the respon dents affected b y the standards and the corresponding North American Industry Classification Sy stem (NAICS ) codes are listed in the table below.
**Standard ( 40 CFR**  **P art 63,**  **S ubpart** 

**VVVV )**  **SIC Codes NAICS Codes**  Boat Building 3732 336612 3731 336612 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV). A source must make the following reports:

**Notification s**  Initial notification for existing sources 63.9(b)(2) Notification to construct/reconstruct 63.9(b(4)(i) Notification of actual startup date 63.9(b)(4)(v) Request for extension of compliance 63.9(c) Notification that source is subject to special compliance requ irements 63.9(d) Notification of performance test 63.9(e) Notification of opacit y and visible emission observation 63.9(f)6
**Notification s**  Notification of sources with continuous monitoring s ys tems 63.9(g) Notification of compliance status 63.9(h)
**Reports** First compliance report 63.5764(b)(1) Semiannual compliance report 63.5764(b)(3) Startup, shutdown, and malfunction plan 63.5764( e) A source must keep the following records:
**Recordkeeping** Copy of each notification a report as submitted and associated documentation 63.5767(a

- b) Record of weighted

- average organic HAP content 63.5767(c) Recordkeeping relevant to startup, shutdown, and malfunction periods and continuous monitoring s ys tem performance evaluations 63.5767(d) Records of monthly

inspections and repairs 63.5755 Maintain records for 5 ye ars 63.5764(b) Electronic Reporting Some of the r espondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

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

**(ii) Respondent Activities**7

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test, Reference Method 18, 25A, and 311 tests , 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing 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 equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem ) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipm ent has significantl y 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**8 **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the OTIS. **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintain ed by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and e nforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operato r for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulat ion. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum r equirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is9

shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (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 industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings b elieved to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recor dkeeping and reporting requirement s is estimated to be 23,543 hours ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously

- approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 2

. 4 9 ($5 8

. 3 3 + 110%) Technical $ 10 1

. 2 8 ($4 8

. 2 3 + 110%) Clerical $ 50

. 80 ($2 4

. 19 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the inform ation collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. Th e capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**10

**Capital/Startup vs. Operation and Maintenance (O&M) Costs**  (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)
Continuous parameter mo nitors N/A N/A N/A $800 1 $800
The total capital/startup costs for this I CR are zero
. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $800. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 800

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program i ncludes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emis sions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 106,137

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (G S

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal).

**6(d) Estimating the Respondent Universe and Total Burden and Costs**11

Based on our research for this I CR, on average over the next three ye ars, approximately 144 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 144 per year. The number of respondents is ca lculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 144 0 0 144
2 0 144 0 0 144
3 0 144 0 0 144 Average 0 144 0 0 144 1 New respondent include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 144

. The total number of annual responses per ye ar is calculated using the following table:
**Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D Initial notification that existing sources are subject to the standard 0 1 0 0 Notification of intent to construct and application for approval of construction 0 1 0 0 Notification of start of construction 0 1 0 0 Notification of anticipated startup date 0 1 0 0 Notification of actual startup date 0 1 0 0 Notification of compliance status 0 1 0 012 **Total Annual Responses** Semiannual compliance reports of all sources 144 2 0 288 Quarterly compliance report 0 4 0 0 Annual compliance report 1 1 0 1 **Total 289**  The number of Total Annual Responses is 289

. The total annual labor costs are $2,302,783

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal). **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 23,543 hours at a cost of $2,302,783

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 81 hours per respo nse
. The total annual capital/startup and O&M costs to the regulated entity are $800

. 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 y ears is estimated to be 2,355 labor hours at a cost of $106,137 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal). **6(f) Reasons for Change in Burden** There is no change in labor hours in this I CR compared to the previous I CR. This is due to two considerations. First, the regulations have not changed over the past three ye ars and are not anticipated to change over th e next three ye ars. Secondly , the growth rate for the industry is very low, negative or non

- existent, so there is no significant change in the overall burden.13

However, there is an adjustment increase in the respondent burden costs due to an increase in l abor rate . This ICR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 81 hours p er response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acqu ire, install, and utilize technology and s ys tems 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 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 display s 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 A gency '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 I CR under Docke t ID Number EPA

- HQ

- OECA

- 2013

- 0339. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for p ublic viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m. , Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

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

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affa irs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 13

- 0339 and OMB Control Number 2060

- 0546 in any correspondence. **Part B of the Support ing Statement**  This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1: Annual Respondent Burden and Cost** 

**– NESHAP for**  **Boat Manufacturing (40 CFR Part 63, Subpart VVVV) (Renewal)** 

**Burden item (A)**  **Person h**  **ours per**  **o ccurrence**  **(B)**

**Occurrences per**  **respondent per y**  **ear (C)** 

**Person hour per**  **respondent per year**  **(C=AxB) (D)** 

**Respondent s**  **p er y**  **ear (E)** 

**Technical person**  **hour per year**  **(E=CxD) (F)** 

**Managerial person**  **hour per year**  **(Ex0.05) (G)** 

**Clerical person**  **hour per year**  **(Fx0.1) (H)** 

**Total Cost per**  **Year a** 

1. Applications N/A 2. Surveys and studies N/A 3. Read instructions c 25 1 25 144 3,600 180 360 $404,944.20 4. Required activities for sources with add

- on control devices d a. Initial performance test and report 410 1 410 0 0 0 0 $0 b. Establish operating parameters See 4A c. Prepare startup, shutdown, and malfunction plan 40 1 40 0 0 0 0 $0 5. Required activities for sources using pollution prevention measures e, f a. Develop recordkeeping system 1) Fiberglass manufacturing operations 22 1 22 0 0 0 0 $0 2) Adhesive operations 1 1 1 0 0 0 0 $0 3) Aluminum coating operations 6 1 6 0 0 0 0 $0 b. Enter information into recordkeeping system 1) Fiberglass manufacturing operations g 84 1 84 144 12,096 604.8 1 , 209.6 $1,360,612.51 2) Adhesive operations h 12 1 12 144 1,728 86.4 172.8 $194,373.22 3) Aluminum coating operations i 22 1 22 16 352 17.6 35.2 $39,594.54 c. Work practice requirements j 2 12 24 16 384 19.2 38.4 $43,194.0515

**Burden item (A)**  **Person h**  **ours per**  **o ccurrence**  **(B)**

**Occurrences per**  **respondent per y**  **ear (C)** 

**Person hour per**  **respondent per year**  **(C=AxB) (D)** 

**Respondent s**  **p er y**  **ear (E)** 

**Technical person**  **hour per year**  **(E=CxD) (F)** 

**Managerial person**  **hour per year**  **(Ex0.05) (G)** 

**Clerical person**  **hour per year**  **(Fx0.1) (H)** 

**Total Cost per**  **Year a** 

6. Create information See 5B 7. Gather information See 5B 8. Notification requirements a. Initial notification that existing sources 24 1 24 0 0 0 0 $0 are subject to the standard k b. Notification for new major sources 1) Intent to construct and application for 80 1 80 0 0 0 0 $0 approval of construction 2) Start of construction 2 1 2 0 0 0 0 $0 3) Anticipated startup date 2 1 2 0 0 0 0 $0 4) Actual startup date 2 1 2 0 0 0 0 $0 c. Request for compliance extension N/A d. Notification of special compliance N/A

r equirements e. Notification of performance tests 2 1 2 0 0 0 0 $0 f. Notification of compliance status 4 1 4 0 0 0 0 $0 9. Reporting requirements a. Semiannual compliance reports for all sources l 8 2 16 144 2,304 115.2 230.4 $259,164.29 b. Additional reports for sources with add

- on control devices 1) Quarterly compliance report for sources 16 4 64 0 0 0 0 $016

**Burden item (A)**  **Person h**  **ours per**  **o ccurrence**  **(B)**

**Occurrences per**  **respondent per y**  **ear (C)** 

**Person hour per**  **respondent per year**  **(C=AxB) (D)** 

**Respondent s**  **p er y**  **ear (E)** 

**Technical person**  **hour per year**  **(E=CxD) (F)** 

**Managerial person**  **hour per year**  **(Ex0.05) (G)** 

**Clerical person**  **hour per year**  **(Fx0.1) (H)** 

**Total Cost per**  **Year a** 

with exceedences 2) Request to return to semiannual compliance 8 1 8 1 8 0.4 0.8 $899.88 Reporting m 3) Control device performance test report See 4A 4) Operating range for monitored parameters See 4B 5) Startup, shutdown, malfunction 8 1 8 0 0 0 0 $0 **Subtotal for Reporting Requirements 23,54**  **2.8 $2,302,782.6**  **9** 10. Recordkeeping requirements a. Read instructions See 3 b. Plan and develop record system See 5A c. Record information See 5B d. Records for area sources not subject to the N/A standard 11. Time to train personnel N/A 12. Time for audits N/A **Subtotal for Recordkeeping Requirements 0**  **$0 TOTAL LABOR BURDEN AND COST**  **(rounded) 23,543**  **$2,302,78 3** 

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 144 existing sources. There wil l be no additional sources over the three

- year period of this ICR.17

b This ICR uses the following labor rates: $122.49 per hour for Executive, Administrative, and Managerial labor; $101.28 per hour for Technical labor, and $50.80 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, S eptember 2012, “Table 2. Civilian Wo rkers, by Occupational and Industry group”. The rates are from column 1, “Total Compensation”. The rates have been increase d by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that it wi ll take the same length of time (25 hours) for both fiberglass and aluminum boat manufacturers to review the rules for each f

acility. d We have assumed that sources with add

- on control devices will be required to perform initial performance test and report, and to prepare startup, shutdow n, and malfunction plan. e We have assumed that all of the existing facilities except for one are complying with the regulations by using pollution prev ention measures. f We have assumed that there will be no new sources expected over the three

- year period of this ICR. g We have assumed that each of the respondents will take 84 hours to complete the fiberglass manufacturing operations. h We have assumed that each respondent will take 12 hours to complete the adhesive op erations requirements. i We have assumed that 16 respondents will take 22 hours each to complete the aluminum coating operations requirements. j We have assumed that 16 respondents will take 2 hours each to complete the work practice requirements. k We have assumed that all of the existing respondents will each take 24 hours to complete initial notification requirements. l We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report.
m We h ave assumed that one respondent will request to return to semiannual compliance reporting.

**“Affected Public” Broken Down According to Number of Facilities in Each Category**
**Respondents Number of Respondents**  **Responses Capital/Startup**  **& O&M Cost Labor Costs**  Private Sector (Business for

- profits) 143 286 $0 $2,286,791 Federal Government 1 3 $800 $15,992

**Total 144**  **289 $800**  **$2, 302**  **, 783**  **(rounded)**

**Reporting and Recordkeeping Hours for Each Category Respondents**  **Total Reporting Hours Recordkeeping Hours**  **Labor Hours** Private Sector (Business for

- profits) 23,380 0 23,380 Federal Government 163 0 163

**Tota** l **23,543 0**  **23,543 (rounded)**18

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for**  **Boat Manufacturing (40 CFR Part 63, Subpart VVVV)**  **(Renewal)**

**Activity (A)**  **EPA Hours per**  **occurrence (B)** 

**No of occurrences**  **per year (C)** 

**EPA h**  **ours per y**  **ear (**  **C= AxB)**  **(D)**

**Plants per**  **y ear (a)**  **(E)**

**Technical h**  **ours per**  **y ear**  **( E=Cx**  **D) (F)** 

**Managerial h**  **ours per**  **year (E x 0.05)**  **(G)**

**Clerical h**  **ours per**  **y ear**  **(E x 0.1) (H)** 

**Total Cost per**  **Year a** 
1. Read instructions 25 1 25 0 0 0 0 $0 2. Enter and update information into agency recordkeeping system c 4 1 4 144 576 28.8 57.6 $29,850.91
3. Notification review a. Review

initial notification for existing sources d 2 1 2 0 0 0 0 $0 b. Notification for new major sources e 1. Review intent to construct and application to construct 12 1 12 0 0 0 0 $0 2. Start of construction 2 1 2 0 0 0 0 $0 3. Anticipated startup date 2 1 2 0 0 0 0 $0 4. Actual startup date 2 1 2 0 0 0 0 $0 c. Review

request for compliance extension N/A d. Review

special compliance requirements N/A e. Review

initial performance test and test plan 20 1 20 0 0 0 0 $0 f. Review compliance status f 2 1 2 144 288 14.4 28.8 $14,925.46 g . Area sources not subject to standard N/A h. Review waiver application N/A 4. Reporting requirements a. Semiannual compliance reports for all sources g 4 2 8 144 1,152 57.6 115.2 $59,701.82 b. Reports for sources with add

- on control devices19

**Activity (A)**  **EPA Hours per**  **occurrence (B)** 

**No of occurrences**  **per year (C)** 

**EPA h**  **ours per y**  **ear (**  **C= AxB)**  **(D)**

**Plants per**  **y ear (a)**  **(E)**

**Technical h**  **ours per**  **y ear**  **( E=Cx**  **D) (F)** 

**Managerial h**  **ours per**  **year (E x 0.05)**  **(G)**

**Clerical h**  **ours per**  **y ear**  **(E x 0.1) (H)** 

**Total Cost per**  **Year a**  1. Quarterly compliance report for source with exceed ances h 4 4 16 0 0 0 0 $0 2. Request to return to s emiannual compliance reporting i 4 2 8 1 8 0.4 0.8 $414.60
3. Review

control device performance test report and operating range 20 1 20 1 20 1 2 $1,036.49
4. Review

startup, shutdown, malfunction reports j 4 1 4 1 4 0.2 0.4 $207.30

**TOTAL LABOR BURDEN AND COST (rounded)**  **2,355 $106,**  **137**

**Assu mptions:** 
a We have assumed that the average number of respondents that will be subject to the rule will be 144 existing sources. There wil l be no additional sources over the three

- year period of this ICR. b This cost is based on the following labor rates w hich incor

porates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial rate (GS

- 13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS

- 6, Step 3, $15.63 x 1.6). The se rates are from the Office of Personnel Management (OPM) “2012 General Schedule”, which excludes locality rates of pay.
c We have assumed that 144 respondents will each take 4 hours to enter and update information into agency recordkeeping system. d We have assumed that all existing sources will be in compliance in the third year.
e We have assumed that there will be not new sources over the three

- year period of this ICR. f We have assumed that it will take 2 hours to revie w the compliance status not ification. g We have assumed that it will take four hours two times per year to review the semiannual compliance report. h we have assumed that 20 percent of the quarterly compliance reports will be reviewed for exceedences. i We have assumed that two r espondents will request to return to semiannual compliance reporting. j We have assumed that it will take 4 hours to review the startup, shutdown, malfunction report.