SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart 

GG) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) 

(Renewal), EPA ICR Number 1687.09, OMB Control Number 2060-0314

1(b) Short Characterization/Abstract

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

Manufacturing and Rework Facilities were: proposed on June 6, 1994; promulgated on 

September 1, 1995; and last-amended on April 20, 2006. These regulations apply to existing and 

new aerospace manufacturing and rework facilities where the total hazardous air pollutants 

(HAP) emitted are greater than or equal to 10 tons per year of any combination of HAP, or where 

the total HAP emitted are greater than or equal to 25 tons per year of any combination of HAP. 

New facilities include those that commenced construction or reconstruction after the date of 

proposal. Operations covered include: cleaning, primer and top coat application, depainting, 

chemical milling maskant application, and handling and storage of waste. This information is 

being collected to assure compliance with 40 CFR part 63, subpart GG.

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 two 

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 136 respondents per year will be subject to these

standards, and no additional respondents per year will become subject to these standards. Each 

respondent may have one or more operations (e.g., cleaning, coating, or depainting operations) 

subject to these standards. 
2

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

All of the aerospace manufacturing and rework facilities in the United States are owned 

and operated by the Aerospace Manufacturing and Rework industry (aka: the “Affected Public”). 

None of the facilities in the United States are owned by either state, or local, or tribal entities or 

by the Federal government. They are all privately-owned, for-profit businesses. The “burden” to 

the Affected Public may be found below in Tables 1a through 1c: Annual Respondent Burden 

and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, 

Subpart GG) (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 Aerospace Manufacturing and 

Rework Facilities (40 CFR Part 63, Subpart GG) (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 aerospace manufacturing and 

rework 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 GG.
3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

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

collected information 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 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

GG.

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. 
4

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 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 these standards as it was being developed and these

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

compliance purposes. In developing this ICR, we contacted: 1) the Aerospace Manufacturing 

Technologies (AMT), at (360) 435-1119; and 2) Aerospace Industries Association, at (703) 358-

1000.

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.

(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 aerospace 

manufacturing and rework 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 for the respondents are listed below.

40 CFR Part 63, Subpart GG SIC Codes NAICS Codes

Aircraft and Parts 3720 None

Aircraft Manufacturing 3721 336411

Aircraft Engine and Engine Parts Manufacturing 3724 336412

Other Aircraft Part and Auxiliary Equipment 

Manufacturing

3728 336413

Fluid Power Valve and Hose Fitting Manufacturing 3728 332912

Aircraft Manufacturing 3728 336411

Guided Missiles, Space Vehicles, and Parts 3760 334511

Guided Missiles and Space Vehicles Manufacturing 3761 336414

Guided Missile and Space Vehicle Propulsion Unit and 

Propulsion Unit Parts Manufacturing

3764 336415

Other Guided Missile and Space Vehicle Parts and 

Auxiliary Equipment Manufacturing

3769 336419

Airports, Flying Fields, and Airport Terminal Services 4581 488119

 

4(b) Information Requested

(i) Data Items

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

Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG). 
6

A source must make the following reports:

Notifications/Reports

Notification of construction and modification

63.743(a)(2-3), 63.6(e), 

63.753(a), 63.5(d), 

63.10(d)(5)

Initial notification for existing sources 63.9(b)(2), 63.753(a)(2)

Notification of performance test and results 63.7(b), 63.7(g)(1), 63.9(e), 

63.10(d)(2), 63.753(a)

Notification and report of physical and operational changes 63.5(b)(6), 63.743(a)(2), 

63.753(a)

Notification and report of production capacity 63.9(b)(2), 63.753(a)

Notification and report of compliance status 63.9(h), 63.753(a)

Report of startup, shutdown, malfunction plan 63.10(a), 63.10(d)(5), 

63.743(b), 63.753(a)

Notification and report for waiver applications 63.7(h)(3), 63.753(a)

Semiannual report

63.6(e), 63.10(d)(5), 

63.10(e)(3), 63.753(b), 

63.753(c)(1), 63.753(d)(1) 

and (3), 63.753(e)

Annual report 63.753(c)(2), 3.753(d)(2)

A source must keep the following records:

Recordkeeping

Records of daily and monthly inspections 63.6(e)(3), 63.10(b)(2), 

63.743(a)(3), 63.752(a)

Emission testing 63.10(b)(2), 63.752(a)

Facility operation and maintenance including startup, 

shutdown, malfunction, construction and modification

63.5(b), 63.6(e), 

63.743(a)(2) and (3), 

63.743(b), 63.752

Cleaning solvents, all information records 63.752(b)(1)

Cleaning solvents, approved composition and vapor pressure, 

solvent usage records 63.752(b)(2)

Cleaning solvents, non-approved composition, approved vapor 

pressure, solvent usage records 63.752(b)(3)
7

Recordkeeping

Cleaning solvents, usage log for exempt processes 63.752(b)(4)

Cleaning solvents, log of spray gun cleaner leaks 63.752(b)(5)

Primers/topcoats/maskants: Records using compliant coatings 

without averaging 63.752(c)(1-3), 63.752(f)(1)

Primers/topcoats/maskants: Records using averaging 63.752(c)(1), 63.752(c)(4), 

63.752(f)(2)

Primers/topcoats/maskants: Records using control devices

63.752(c)(1), 63.752(c)(5-6), 

63.752(d), 63.752(f)(3), 

63.752(f)(4) 

Chemical strippers, records and parts removed 63.752(e)(1), 63.752(e)(4)

Chemical strippers, records using control devices 63.752(e)(2), 63.752(e)(3)

Depainting equipment malfunction log 63.752(e)(5)

Annual exempt chemical stripper usage log and reworked 

airplane log for spot stripping and decal removal 63.752(e)(6)

Depainting control device maintenance log 63.752(e)(7)

5-years retention of records 63.10(b)(1), 63.752(a)

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

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 Methods 1, 1A, 2, 2B, 2C, 2D, 3, 4,18, 24, 25A, 
8

Respondent Activities

40, 301, or 319 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

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 Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management
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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 

shown below in Tables 1a through 1c: Annual Respondent Burden and Cost – NESHAP for 

Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal).

6. Estimating the Burden and Cost of the Collection

Tables 1a through 1c below 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.
10

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 140,936 hours (Total Labor Hours from Tables 1a 

through 1c 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 $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

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

2013, “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 initial, 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(s) and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

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)

CEM $14,000 0 $0 $1,000 136 $136,000
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Capital/Startup vs. Operation and Maintenance (O&M) Costs

Total $0 $136,000

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 $136,000. 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 $136,000. These are 

recordkeeping costs.

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 

$233,003. 

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), 2013 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 

Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (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

136 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 136 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

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

0 136 0 0 136

2

0 136 0 0 136

3

0 136 0 0 136

Average 0 136 0 0 136

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 136. 

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

(A)

Information Collection Activity

(B)

Number of 

Respondents 1

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of 

construction/reconstruction 0 1 0 0

Notification of physical and 

operational changes 14 1 0 14

Notification of actual startup 0 1 0 0

Notification of change in 

production capacity 0 1 0 0

Compliance status information 

report 277 1 0 277

Waiver application 28 1 0 28

Startup, shutdown, 

malfunction plan 177 1 0 177

Startup, shutdown, 

malfunction report 55 1 0 55

Semiannual report – including 

report of periods of 

noncompliance

222 2 0 444

Total Number of Annual 

Responses Total 995

1 We estimate there are 136 existing respondents. Each respondent may have one or more operations (cleaning, 

coating, and/or depainting operations) that are subject to these standards. 

The number of Total Annual Responses is 995. 

The total annual labor costs are $13,785,987. Specific, individual details regarding these 

estimates may be found below in Tables 1a through 1c: Annual Respondent Burden and Cost –

NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) 

(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 below in Tables 1a through 1c and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 140,936 at a cost of $13,785,987. Specific details regarding these 

estimates may be found below in Tables 1a through 1c: Annual Respondent Burden and Cost –
14

NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) 

(Renewal), and a combined summary of Tables 1a through 1c may be found below in Table 1d: 

Summary of Annual Respondent Burden and Cost for Tables 1a, 1b, & 1c - NESHAP for 

Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal).

 

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

information is estimated to average 142 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $136,000. 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 

5,170 labor hours at a cost of $233,003. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 63, Subpart 

GG) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment decrease in respondent burden hours and an increase in Agency

hours in this ICR compared to the previous ICR; however, this adjustment is not due to any

program changes. The changes are a result of several corrections; specifically, this ICR: 1) 

corrects discrepancies in the number of compliance status reports and SSM reports between the 

respondent and the Agency burden tables; 2) corrects rounding errors in respondent burden Table 

1b in the previous ICR; and 3) changes the frequency of reviewing semiannual reports from one 

to two for the Agency. This ICR also uses updated labor rates in calculating all costs, which 

results in an overall increase in burden costs. 

Furthermore, this ICR corrects the number of responses to be consistent with the burden 

calculations. This results in an adjustment increase in the total number of responses. 

6(g) Burden Statement

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

is estimated to average 142 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.
15

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-2013-0335. 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), WJC 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-2013-0335 and OMB Control Number 2060-0314 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 1a: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part

63, Subpart GG) (Renewal) (Cleaning Operations)

Burden item (A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(A x B)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(C x D)

(F) 

Management 

person hours 

per year 

(E x 0.05)

(G) 

Clerical 

person 

hours per 

year 

(E x 0.1)

(H) 

Total Cost 

Per Year b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c1 1 1 136 136 6.8 13.6 $15,298.64 

 B. Required activities N/A

 C. Create information See 3E & 4C

 D. Gather existing information See 3E & 4C

 E. Write report

 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0

 Notification of physical and operational 

changes d

8 1 8 7 56 2.8 5.6 $6,299.44 

 Notification of actual startup 2 1 2 0 0 0 0 $0 

 Notification of change in production 

capacity

2 1 2 0 0 0 0 $0 

 Compliance status information report e20 1 20 136 2,720 136 272 $305,972.80 

 Waiver application f4 1 4 14 56 2.8 5.6 $6,299.44 

 Startup, shutdown, malfunction plan g4 1 4 136 544 27.2 54.4 $61,194.56 

 Preparation of site-specific test plan N/A

 Notification of initial performance test N/A

 Report of initial test N/A

 Startup, shutdown, malfunction report h2 1 2 27 54 2.7 5.4 $6,074.46 
17

 Semiannual report – including report of 

periods of noncompliance i

12 2 24 109 2,616 130.8 261.6 $294,273.84 

Subtotal for Reporting Requirements 7,109.3 $695,413.18

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities 4 1 4 136 544 27.2 54.4 $61,194.56 

 C. Implement activities

 Solvent information records 4 2 8 136 1,088 54.4 108.8 $122,389.12 

 Approved composition solvent records 

(demonstrating compliance) j

4 1 4 41 164 8.2 16.4 $18,448.36 

 Non-approved list solvent usage records k1 12 12 122 1,464 73.2 146.4 $164,685.36 

 Solvent usage log for exempt processes l0.5 12 6 95 570 28.5 57 $64,119.30 

 Log of gun cleaner leaks m1 6 6 27 162 8.1 16.2 $18,223.38 

 D. Develop record system n20 1 20 136 2,720 136 272 $305,972.80 

 E. Time to enter information

 Records of startup, shutdown, and 

malfunction

2 1 2 27 54 2.7 5.4 $6,074.46 

 Records of all measurements and 

information required by standard

 F. Time to train personnel o4 50 200 136 27,200 1,360 2,720 $3,059,728.00 

 G. Time for audits 20 1 20 136 2,720 136 272 $305,972.80 

Subtotal for Recordkeeping Requirements 42,188.9 $4,126,808.14

TOTAL LABOR BURDEN AND COST (rounded) 49,298 $4,822,221 

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 136. There will be no new additional sources during the next three 

years of this ICR.

b

 This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 per 

hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, 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 there will be no net growth for the industry over the three-year period of this ICR, only existing sources will read instructions.
18

d

 We have assumed that 5 percent of the total existing facilities will write the physical and operational changes report (136 x 5% = 6.8, rounded to 7).

e

 We have assumed that each respondent will write compliance status information report.

f

 We have assumed that 10 percent of the respondents will request a waiver (136 x 10% = 14).

g

 This is based on the number of facilities with add-on control systems that require the development of inspection and maintenance and startup, shutdown, malfunction 

plan. We have assumed that all of the facilities will have enclosed gun cleaners.

h

 We have assumed that 20 percent of facilities with add-on control system will have a malfunction (136 x 20% = 27).

i

 We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way (136 x 80% = 109).

j

 We have assumed that 30 percent of facilities will use the approved list of solvents (136 x 30% = 41).

k

 We have assumed that 90 percent of facilities will use some solvents not on the approved list (136 x 90% = 122).

l

 We have assumed that 70 percent of facilities will use some solvents for exempt processes.

m

 We have assumed that 20 percent of facilities will have a leak in their enclosed gun cleaner.

n

 We have assumed that all facilities will need to develop a record keeping system.

o

 We have assumed that each respondent will take 4 hours 50 times per year to complete task.
19

Table 1b: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part

63, Subpart GG) (Renewal)(Coating Operations)

Burden item (A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(A x B)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(C x D)

(F) 

Management 

person hours 

per year

(E x 0.05)

(G) 

Clerical 

person 

hours per 

year 

(E x 0.1)

(H) 

Total Cost 

Per Year b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c1 1 1 136 136 6.8 13.6 $15,298.64

 B. Required activities 

 Initial performance tests d280 1 280 4 1,120 56 112 $125,988.80

 Repeat performance test e280 1 280 1 280 14 28 $31,497.20

 C. Create information See 3E & 4C

 D. Gather existing information See 3E & 4C

 E. Write report

 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0

 Notification of physical and operational 

changes f

8 1 8 7 56 2.8 5.6 $6,299.44

 Notification of actual startup 2 1 2 0 0 0 0 $0

 Notification of change in production capacity 2 1 2 0 0 0 0 $0

 Compliance status information report 10 1 10 136 1,360 68 136 $152,986.40

 Waiver application g4 1 4 14 56 2.8 5.6 $6,299.44

 Startup, shutdown, malfunction plan h4 1 4 41 164 8.2 16.4 $18,448.36

 Preparation of site-specific test plan See 3B

 Notification of initial performance test 2 1 2 4 8 0.4 0.8 $899.92

 Report of initial test See 3B
20

 Startup, shutdown, malfunction report i4 1 4 27 108 5.4 10.8 $12,148.92

 Semiannual report – including report of 

periods of noncompliance j

11 2 22 109 2,398 119.9 239.8 $269,751.02

Subtotal for Reporting Requirements 6,538.9 $639,618.14

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities 4 1 4 136 544 27.2 54.4 $61,194.56

 C. Implement activities

 Compliance coating records 1 12 12 136 1,632 81.6 163.2 $183,583.68

 Daily records of weighted average mass k1 250 250 14 3,500 175 350 $393,715.00

 Control device maintenance or rolling 

material

0.5 250 125 4 500 25 50 $56,245.00

 balance log (organics)

 Control device maintenance log (inorganics) 0.25 250 62.5 136 8,500 425 850 $956,165.00

 D. Develop record system l10 1 10 136 1,360 68 136 $152,986.40

 E. Time to enter/maintain information

 Records of startup, shutdown, and 

malfunction

2 1 2 27 54 2.7 5.4 $6,074.46

 Records of all measurements and information See 4C

 required by standard

 F. Time to train personnel 8 50 400 136 54,400 2,720 5,440 $6,119,456.00

 G. Time for audits 20 1 20 136 2,720 136 272 $305,972.80

Subtotal for Recordkeeping Requirements 84,191.5 $8,235,392.90

TOTAL LABOR BURDEN AND COST (rounded) 90,730 $8,875,011

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 136. There will be no new additional sources during the next three 

years of this ICR.

b

 This ICR uses the following labor rates: : $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, 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 
21

available to those employed by private industry.

c

 We have assumed that there will be no net growth for the industry over the three-year period of this ICR, only existing sources will read instructions.

d

 We assume that 4 facilities will use add-on control equipment for maskant application.

e

 We have assumed that 1 facility with add-on control equipment will repeat performance test.

f

 We have assumed that 5 percent of existing facilities will write the physical and operational changes report (136 x 5% = 7).

g

 We have assumed that 10 percent of facilities will request a waiver (136 x 10% = 14).

h

 We have assumed that 30 percent of facilities will be required to submit operational plans due to deviations from manufacturers’ specifications, and based on the 

number of facilities with add-on control systems that require the development of inspection, maintenance, startup, shutdown, and malfunction plans.

i

 We have assumed that 20 percent of facilities with add-on control system (including particulate filters) will have a malfunction.

j

 We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way.

k

 The final rule required monthly records. Daily averaging was included in the cost analysis because 90 percent of the industry is located in non-attainment areas and 

will be required to use daily averaging by the permitting agency.

l

 We have assumed that all facilities will need to develop a record keeping system.
22

Table 1c: Annual Respondent Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part

63, Subpart GG) (Renewal) (Depainting Operations)

Burden item (A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(A x B)

(D) 

Respondents 

per year 

a

(E) 

Technical 

person- hours 

per year 

(C x D)

(F) 

Management 

person hours per 

year 

(E x 0.05)

(G) 

Clerical 

person 

hours per 

year 

(E x 0.1)

(H) 

Total Cost 

Per Year b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c1 1 1 5 5 0.25 0.5 $562.45

 B. Required activities N/A

 Initial performance tests 280 1 280 0 0 0 0 $0

 Repeat performance test 280 1 280 0 0 0 0 $0

 C. Create information See 3E & 

4C

 D. Gather existing information See 3E & 

4C

 E. Write report

 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0

 Notification of physical and operational 

changes 

8 1 8 0 0 0 0 $0

 Notification of actual startup 2 1 2 0 0 0 0 $0

 Notification of change in production 

capacity

2 1 2 0 0 0 0 $0

 Compliance status information report 10 1 10 5 50 2.5 5 $5,624.50

 Waiver application 4 1 4 0 0 0 0 $0

 Startup, shutdown, malfunction plan 5 1 5 0 0 0 0 $0

 Preparation of site-specific test plan N/A
23

 Notification of initial performance test2120000 $0

 Report of initial test See 3B

 Startup, shutdown, malfunction report 

d

41414 0.2 0.4 $450

 Semiannual report – including report of 

periods of Noncompliance 

e

122 244 96 4.8 9.6 $10,799.04

Subtotal for Reporting Requirements 178.25 $17,435.95

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities4145 2012 $2,249.80

 C. Implement activities 

f

 Chemical stripper records (demonstrating 

compliance)

8184 32 1.6 3.2 $3,599.68

 Chemical stripper usage log1 12 124 48 2.4 4.8 $5,399.52

 Depainting equipment malfunction log43 122 24 1.2 2.4 $2,699.76

 Exempt stripper usage log and reworked 

airplane

1 12 125 6036 $6,749.40

 log spot stripping and decal removal

 Record of parts removed for parts 

depainting

82 165 8048 $8,999.20

 Control device maintenance log 0.5 250 1252 250 12.5 25 $28,122.50

 D. Develop record system 

g

101 105 50 2.55 $5,624.50

 E. Time to enter information

 Records of startup, shutdown, and 

malfunction

2120000 $0

 Records of all measurements and 

information required by standard

See 4C

 F. Time to train personnel 4145 2012 $2,249.80

 G. Time for audits 101 105 50 2.55 $5,624.50

Subtotal for Recordkeeping Requirements 729 $71,318.6

6

TOTAL LABOR BURDEN AND COST (rounded) 907 $88,75

5
24

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 136. There will be no new additional sources during the next three 

years of this ICR. Of the 136 facilities, we assume 5 facilities have depainting operations. 

b

 This ICR uses the following labor rates: : $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, 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 there will be no net growth for the industry over the three-year period of this ICR, only existing sources will read instructions..

d

 We have assumed that 20 percent of facilities will have a malfunction (20% x 5 = 1).

e

 We have assumed that 80 percent of facilities will have excess emissions or will change their process in some way and will submit semiannual reports (5 x 80% = 4).

f

 We have assumed that 1 percent of facilities will use HAP containing chemical strippers as the primary stripping techniques, 29 percent will use media blasting 

equipment, 70 percent will use non-HAP chemical strippers, and 100 percent of facilities will use some HAP stripper for exempt processes.

g

 We have assumed that all respondents will need to develop a record keeping system.
25

Table 1d: Summary of Annual Respondent Burden and Cost for Tables 1a, 1b, & 1c - NESHAP for Aerospace Manufacturing

and Rework Facilities (40 CFR Part 63, Subpart GG) (Renewal)

Burden 

Burden Hours per 

Year for

Reporting

Burden Hours per 

Year for 

Recordkeeping

Total Burden 

Hours per 

Year 

Annual

Costs in

$ (rounded) 

1a. Cleaning Operations 7,109.3 42,188.9 49,298.2 $4,822,221 

1b. Coating Operations 6,538.9 84,191.5 90,730.4 $8,875,011 

1c. Depainting Operations 178.25 729.1 907.35 $88,755 

Total Burden and Cost (rounded) 13,826 127,110 140,936 $13,785,987 
26

Table 2: Average Annual EPA Burden and Cost – NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 

63, Subpart GG) (Renewal)

Activity

(A) 

EPA person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

Person 

hours per 

plant per 

year 

(A x B)

(D) 

Plants 

per 

year 

a

(E) 

Technical 

personhours per 

year 

(C x D)

(F) 

Management 

person hours 

per year 

(E x 0.05)

(G) 

Clerical 

person 

hours per 

year 

(E x 0.1)

(H) 

Total Cost 

Per Year b

1. Initial performance test 80 1 80 0 0 0 0 $0 

2. Repeat performance test

 Retesting preparation c16 1 16 1 16 0.8 1.6 $829.19 

 Retesting d80 1 80 0 0 0 0 $0 

3. Report review

 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 

 Notification of physical or operational changes e2 1 2 14 28 1.4 2.8 $1,451.09 

 Notification of anticipated startup 2 1 2 0 0 0 0 $0 

 Notification of actual startup 2 1 2 0 0 0 0 $0 

 Notification of changes in production capacity 2 1 2 0 0 0 0 $0 

 Compliance status information report f6 1 6 277 1,662 83.1 166.2 $86,132.32 

 Waiver application g6 1 6 28 168 8.4 16.8 $8,706.52 

 Review of startup, shutdown, malfunction plan h6 1 6 177 1,062 53.1 106.2 $55,037.62 

 Review of site specific test plan N/A

 Notification of initial performance test i2 1 2 4 8 0.4 0.8 $414.60 

4. Report review

 Report of initial test 8 1 8 0 0 0 0 $0 

 Review of startup, shutdown, malfunction 

reports

4 1 4 55 220 11 22 $11,401.39 

 Review of semiannual reports j3 2 6 222 1,332 66.6 133.2 $69,030.23 

TOTAL ANNUAL BURDEN AND COST (rounded) 5,170 $233,003 
27

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 136. There will be no new additional sources during the next three 

years 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) 2013 General Schedule which excludes locality rates of pay.

c

 We have assumed that it will take 16 hours to prepare for retesting.

d

 We have assumed that 20 percent of respondents will fail the initial performance test and will have to be retested.

e

 We have assumed that it will take two hours once per year to review the compliance status information report..

f

 We have assumed that it will take six hours to review the compliance status information report.

g

 We have assumed that the Agency will take 6 hours to review the waiver application for each of 28 respondents.

h

 We have assumed that it will take six hours to review the startup, shutdown, malfunction plan.

i

 We have assumed that it will take 2 hours to review the initial performance test.

j

 We have assumed that it will take 3 hours to review each semiannual report.