SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, 

Subpart II) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, 

Subpart II) (Renewal), EPA ICR Number 1712.09, OMB Control Number 2060-0330.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Shipbuilding and Ship Repair Facilities - Surface Coating were proposed on December 6, 1994 

and promulgated on December 15, 1995. This standard was most recently amended on 

November 21, 2011; this amendment finalized the residual risk and technology review by readopting existing MACT standards, eliminated the startup, shutdown, and malfunction (SSM) 

exemption, removed SSM plan requirement, and revised SSM-associated recordkeeping and 

reporting requirements for periods of malfunctions. The shipbuilding and ship repair industry

consists of establishments that build, repair, repaint, convert and alter ships which are marine or 

fresh-water vessels used for military or commercial operations. These regulations apply to only

the shipbuilding and repair surface coating operations that occur at facilities that are major 

sources of hazardous air pollutants (HAPs). 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 II.

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 United 

States Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 56 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. 

The previous ICR had the following Terms of Clearance (TOC): 
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In accordance with 5 CFR 1320, the information collection is approved for 

3 years. Upon resubmission, the agency should continue to assess the 

actual burden imposed by the collection relative to the agency's estimated 

burden. Also, the agency should briefly summarize in the supporting 

statement public comments received and responses to the information 

collection in addition to providing a link to the rulemaking docket. 

Finally, the agency shall update labor cost estimates with the most recent 

available labor cost reference (it is noted that though submitted in late 

2011, this collection utilized 2002 data). 

The EPA has addressed each item of concern in the TOC by consulting with industry, 

indentifying and addressing any comments received, and updating labor rates used in the burden 

calculations. EPA did not receive any public comments associated with this ICR renewal. 

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

Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 

CFR Part 63, Subpart II) (Renewal). The “Federal Government” burden is attributed entirely to 

work performed by federal employees or government contractors and may be found in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities -

Surface Coating (40 CFR Part 63, Subpart II) (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.
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In the Administrator's judgment, HAP emissions from surface coating operations at 

shipbuilding and repair facilities 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 II.

2(b) Practical Utility/Users of the Data

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

applicable regulations which were 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 standard. Continuous emission monitors are used to 

ensure compliance with the standard 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 standard is 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. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

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

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

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

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

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

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

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

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 
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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 

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 the EPA Office of Compliance. OTIS is the EPA 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 standard as it was being developed. In developing 

this ICR, we contacted both BAE Systems Ship Repair at (757) 419-9615 and Northrop 

Grumman Corporation at (703) 280-2900.

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

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

subpart B - Confidentiality of Business Information (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 shipbuilding and 

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

respondents affected by the standards is SIC 3731, which corresponds to the North American 

Industry Classification System (NAICS) code 336611 for Ship Building and Repairing. 

4(b) Information Requested

(i) Data Items

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

Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II).

A source must make the following reports:

Notifications

Construction/reconstruction 63.5 

Initial notifications 63.9(b), 63.787(a) 

Report of performance test results 63.10(d)(2), 

63.788(a)

Initial performance test 63.7(b), 63.9(e)

Rescheduled initial performance test 63.7(b)(2)

Continuous monitoring system notifications 63.9(g) 

Request for extension of compliance, adjustments in time periods, and 

changes in information

63.9(c), (i), and (j), 

63.787(a)

Special compliance requirements 63.9(d), 63.787(a)
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Notifications

Compliance status 63.9(h)

Opacity or visible emissions 63.10(d)(3), 

63.788(a)

Startup, shutdown, malfunction reports 63.10(d)(5), 

63.788(a)

Progress reports 63.10(d)(4), 

63.788(a)

Additional reports for sources with continuous monitoring systems 63.10(e), 63.788(a)

Implementation plan 63.787(b)

Semiannual report of coating and thinner usage 63.788(c)

Request for waiver of recordkeeping or reporting requirements 63.10(f), 63.788(a)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative

63.10(b)(2), 

63.788(a)

All reports and notifications 63.10(a), 63.10(b), 

63.788(a), 63.788(b)

Record of applicability 63.10(b)(3), 

63.788(a)

Records for sources with continuous monitoring systems 63.10(c), 63.788(a)

Records of coating applied 63.788(b)(1)

Records related to initial notification and implementation plan 63.788(b)(2)

Records related to coatings and containers used 63.788(b)(2)

Records related to coatings and thinners used 63.788(b)(3)

Records are required to be retained for five years. The first 2 years of 

records must be retained at the facility.

63.788(b)

Electronic Reporting

This collection does not make use of automated, mechanical, or other technical collection 

techniques. Respondents will most likely submit hard copy reports, although some may submit 

electronic versions. The rule allows records to be maintained in hard copy or electronic format 

to allow flexibility and minimize burden.
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(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device, if approved and used.

Perform initial performance test, Reference Method 24 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

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

reports, required to be submitted by industry.

Audit facility records.
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Agency Activities

Input, analyze, and maintain data in the Online Tracking Information System (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 to 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

The recordkeeping and reporting requirements were selected within the context of this 

specific subpart and the specific process equipment and pollutants. The requirements reflect the 

burden on small businesses. To the extent that larger businesses can use economies of scale to 

reduce their burden, the overall burden will be reduced. Although the recordkeeping and 

reporting requirements are the same for small and larger businesses, the Agency considers these 

requirements the minimum needed to ensure compliance and, therefore, cannot reduce them 

further for small businesses. However, there is a “low usage” exemption, which may reduce the 

recordkeeping and reporting burden for some small businesses. This “low usage” exemption 

stipulates that the provisions of the regulation do not apply to coatings used in volumes of less 

than 200 liters per year.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and 

Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal).
9

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. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

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 28,594 (Total Labor Hours from Table 1). 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 $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

2014, “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 only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

The only type of industry costs associated with the information collection activity in the 

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

6(c) Estimating Agency Burden and Cost

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

$11,724. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

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

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

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

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

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 

Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II)

(Renewal).

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

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

56 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 56 per year. 

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

years covered by this ICR. 
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Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 56 0 0 56

2

0 56 0 0 56

3

0 56 0 0 56

Average 0 56 0 0 56

1

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

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

average Number of Respondents over the three year period of this ICR is 56. 

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

Semiannual Report/Notification 56 2 0 112

The number of Total Annual Responses is 112. 

The total annual labor costs are $2,799,388. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and 

Ship Repair Facilities - Surface Coating (40 CFR Part 63, Subpart II) (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
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The total annual labor hours are 28,594. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and Ship Repair 

Facilities - Surface Coating (40 CFR Part 63, Subpart II) (Renewal).

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

information is estimated to average 255 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. 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 258

labor hours at a cost of $11,724. See Table 2: Average Annual EPA Burden and Cost –

NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 CFR Part 63, 

Subpart II) (Renewal).

6(f) Reasons for Change in Burden

There is an increase of $1,059,007.46 in respondent burden costs from the most recently 

approved ICR. This is due to an adjustment in the labor rates and an adjustment in the burden 

calculation method. The previous ICR did not estimate management and clerical burden hours, 

which were added to this ICR to maintain consistency in burden calculation methodology.

6(g) Burden Statement

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

is estimated to average 255 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 
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Docket ID Number EPA-HQ-OECA-2014-0056. 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) 566-1927. 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-2014-0056 and OMB Control Number 2060-0330 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 

CFR Part 63, Subpart II) (Renewal)

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

a. Read Instructions 1 1 1 0 0 0 0 $0

b. Required Activities See 3e

c. Create Information See 3e

d. Gather Existing Information See 3e

e. Write Report

Notification of Construction/Reconstruction 2 1 2 0 0 0 0 $0

Notification of Demonstration of CMS N/A

Report of Performance Test N/A

Initial Notification and Implementation 14 1 14 0 0 0 0 $0

Semiannual Notification 8 2 16 56 896 44.8 89.6 $100,878.85

Subtotal for Reporting Requirements 1,030.4 $100,878.85

4. Recordkeeping Requirements

a. Read Instructions See 3a

b. Plan Activities N/A

c. Implement Activities 8 50 400 56 22,400 1,120 2,240 $2,521,971.20

d. Develop Record System 8 1 8 0 0 0 0 $0
15

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

e. Train Personnel 28 1 28 56 1,568 78.4 156.8 $176,537.98

g. Audits N/A

Subtotal for Recordkeeping Requirements 27,563.2 $2,698,509.18 

TOTAL ANNUAL BURDEN (rounded) 28,594 $2,799,388 

Assumptions:

a Number of affected facilities per year is 56.

b Costs assume a rate of $101.05 for technical, $128.02 for management, and $51.37 for clerical.
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Shipbuilding and Ship Repair Facilities - Surface Coating (40 

CFR Part 63, Subpart II) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

person 

hours per 

plant per 

year 

(AxB)

(D) 

Plants 

per 

year a 

(E) 

Technical 

personhours per 

year (CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost, $ b

INITIAL PERFORMANCE TESTS N/A

REPEAT PERFORMANCE TEST N/A

REPORT REVIEW

Notification of Construction 2 1 2 0 0 0 0 $0

Review of Initial Notification and Implementation 

Plan 2 1 2 0 0 0 0 $0

Review of Semiannual/Notification of Compliance 

Status 2 2 4 56 224 11.2 22.4 $11,724.16

TOTAL ANNUAL HOURS (rounded) 258 $11,724

Assumptions:

a Number of affected facilities per year is 56.

b Costs assume a rate of $46.67 for technical, $62.90 for management, and $25.25 for clerical.