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 ICR 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 apply 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 occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system 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 directly 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 years, an average of 144 respondents (143 private and 1 government

entities) per year will be subject to the standard, and no additional respondents per year will 

become subject to the standard. Of the 144 respondents, we expect that only one will choose to 

comply by limiting the HAP content of their fiberglass or aluminum boat manufacturing 

processes and operations. The one facility already has an add-on control device and will comply 
2

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 currently active ICR 

without any “Terms of Clearance.”

With the exception of one facility, all of the boat manufacturing plants in the United 

States are owned and operated by 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 businesses and none of 

these facilities in the United States are owned by either state, or local, or tribal governments. 

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 “burden”

to the Federal Government is attributed entirely to work performed by either Federal 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 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, HAP emissions from boat manufacturing processes and 

operations cause or contribute to air pollution 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 Data
3

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.

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

capability to comply with the emission standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 properly 

installed and operated, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

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

identify problems at the facility, verify operation/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 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, 

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 ICR was published 

in the Federal Register (78 FR 33409) on June 4, 2013. No comments were received on the 

burden published in the Federal 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 years have been considered. The 
4

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standards as they were being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing 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 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 or recordkeeping requirements do not violate any of the regulations 

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

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

notifications for at least five years. This is 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, any pattern of non-compliance and to 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, 
5

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).

3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are boat manufacturing 

facilities. The United States Standard Industrial Classification (SIC) code for the respondents 

affected by the standards and the corresponding North American Industry Classification System

(NAICS) codes are listed in the table below.

Standard (40 CFR Part 63, Subpart 

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 by the NESHAP for Boat 

Manufacturing (40 CFR Part 63, Subpart VVVV). 

A source must make the following reports:

Notifications

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 requirements 63.9(d)

Notification of performance test 63.9(e)

Notification of opacity and visible emission observation 63.9(f)
6

Notifications

Notification of sources with continuous monitoring systems 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 system performance evaluations

63.5767(d)

Records of monthly inspections and repairs 63.5755

Maintain records for 5 years 63.5764(b)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

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

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

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

systems to transmit data electronically. However, electronic reporting systems 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 

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.

Currently sources are using monitoring and reporting equipment that provide parameter 

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

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities
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, analyze, 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 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, 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.

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

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

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

government-owned facilities. EPA uses the OTIS 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

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 regulation. Due to technical considerations involving the process operations 

and the types 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 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 
9

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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever 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 displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 23,543 hours (Total Labor Hours from Table 1

below). These 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 ICR uses the following labor rates: 

Managerial $122.49 ($58.33+ 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 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 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 type of industry costs associated with the information collection activities in the 

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

associated with continuous monitoring. The capital/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 

monitors

N/A N/A N/A $800 1 $800

The total capital/startup costs for this ICR are zero. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR is estimated to be $800. 

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, 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 

$106,137. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 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 ICR, on average over the next three years, approximately

144 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 144 per year. 

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

years covered by this ICR. 

Number of Respondents

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

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. 

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 144. 

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

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 0
12

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, respectively, 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 response.

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 years 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 ICR compared to the previous ICR. This is due 

to two considerations. First, the regulations have not changed over the past three years and are 

not anticipated to change over the next three years. 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 

labor 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 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-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 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 Ave., NW, Washington, DC. The EPA Docket Center Public 

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

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

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

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

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2013-0339 and OMB Control Number 2060-0546 in any

correspondence. 

Part B of the Supporting 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

hours per

occurrence

(B) 

Occurrences 

per 

respondent

per year

(C) 

Person

hour per

respondent

per year

(C=AxB)

(D) 

Respondents

per year

(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 c25 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 g84 1 84 144 12,096 604.8 1,209.6 $1,360,612.51 

 2) Adhesive operations h12 1 12 144 1,728 86.4 172.8 $194,373.22 

 3) Aluminum coating operations i22 1 22 16 352 17.6 35.2 $39,594.54 

 c. Work practice requirements j2 12 24 16 384 19.2 38.4 $43,194.05 
15

Burden item

(A) 

Person

hours per

occurrence

(B) 

Occurrences 

per 

respondent

per year

(C) 

Person

hour per

respondent

per year

(C=AxB)

(D) 

Respondents

per year

(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

requirements

 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 l8 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 $0
16

Burden item

(A) 

Person

hours per

occurrence

(B) 

Occurrences 

per 

respondent

per year

(C) 

Person

hour per

respondent

per year

(C=AxB)

(D) 

Respondents

per year

(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 23,542.8 $2,302,782.69

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 $2,302,783

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 144 existing sources. There will 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, September 2012, “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.

c

 We have assumed that it will take the same length of time (25 hours) for both fiberglass and aluminum boat manufacturers to review the rules for each facility.

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, shutdown, and 

malfunction plan.

e

 We have assumed that all of the existing facilities except for one are complying with the regulations by using pollution prevention 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 operations 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 have 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

Total 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 hours 

per year 

(C=AxB)

(D) 

Plants per 

year (a)

(E) 

Technical 

hours per 

year 

(E=CxD) 

(F) 

Managerial 

hours per 

year

(E x 0.05) 

(G) 

Clerical 

hours per

year 

(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 d2 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 f2 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 g4 2 8 144 1,152 57.6 115.2 $59,701.82 

 b. Reports for sources with add-on control devices
19

Activity

(A) 

EPA Hours

per

occurrence

(B) 

No of

occurrences

per year

(C) 

EPA hours 

per year 

(C=AxB)

(D) 

Plants per 

year (a)

(E) 

Technical 

hours per 

year 

(E=CxD) 

(F) 

Managerial 

hours per 

year

(E x 0.05) 

(G) 

Clerical 

hours per

year 

(E x 0.1)

(H) 

Total

Cost per

Year a

 1. Quarterly compliance report for source with 

exceedances h 4 4 16 0 0 0 0$0 

 2. Request to return to semiannual 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

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 144 existing sources. There will be no additional sources over 

the three-year period of this ICR.

b

 This cost is based on the following labor rates which incorporates 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). These 

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 review the compliance status notification.

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 respondents 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.