### SUPPORTING STATEMENT **ENVIRONMENTAL PROTECTION AGENCY**
**NES HAP 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 I CR 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 a erospace m anufacturing and r ework faci lities where the total hazardous air pollutants (HAP) emitted are greater than or equal to 10 tons per year of an y combination of HAP, or where the total HAP emitted are greater than or equal to 25 tons per y ear of any combination of HAP

. New facilities i nclude 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 inform ation 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 requi red to maintain records of the occurrence and duration of an y startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essent ial 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 th e date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

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

. S

. Environmental Protection Ag ency (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 ye ars, an average of 136 respondents per ye ar will be subject to the se standard s , and no additional respondents per y ear will become subject to the se standard s
. Each respondent may

have one or more operations (e.g. , cleaning, coating, or depainting operations) subject to the se standard s
.

### 2

The Office of Management and Budget ( OMB) approved the currentl y active I CR without any

“Terms of Clearance.” All of the aerospace manufacturing and rework facilities in the United States are owned and operated b y the A erospace M anufacturing and R ework 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 privatel y - owned , for

- profit businesses. The “ burden ” to the Affected Public may

be found below in Table s 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 entirel y to work performed b y either F ederal employ ees 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 subcate gor y 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, produc tion 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 reasonabl y require.
In the Administrator's judgment, HAP emissions from aerospace manu f acturing 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 sourc e category at 40 CFR part 63, subpart GG

.

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**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 e mission 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 c ontinuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , leaks are being detected and repaired , and the standard are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of exce ss 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 78 FR 33409 ) on June 4, 2013

. No comments were received on the burden published in the 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 y ears have been considered.

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The primary

source of information as r eported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (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 com ment on the burden associated with the se standard s as it was being developed and the se standard s have been reviewed previously to determine the minimum information needed for compliance purposes. Indevelopi ng this ICR, we contacted: 1) the Aerospace Manufacturing Technologies (AMT) , at (360) 435

- 1119 ; and 2) A erospace 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. I f the information required by these standards was collected less frequently , the proper operation and maintenance of control equipment and the possibility

of detecting violations w ould be less likely

. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications , for at least five y ears. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

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

- ye ar statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, an y pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending bey ond five ye ars. 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 mad e 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 3 6902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are aerospace manufacturing and rework facilities . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards and the corresponding North American Industry Classification Sy stem (NAICS ) codes for the respondents are listed below.

**40 CFR P**  **art 63, S**  **ubpart 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, Fl yi ng Fields, and Airport Terminal Services 4581 488119 **4(b) Information Requested (i) Data Items** 
I n this ICR , all the data that is recorded or reported is require d by the NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR P art 63, S ubpart GG )

.

### 6

A source must make the following reports:

**Notification s**  **/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 phy sical and operational changes 63.5(b)(6), 63.743(a)(2), 63.753(a) Notification and report of production capacit y 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 dail y 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) Facilit y 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 reco rds 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 device s 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

- ye ars retention of records 63.10(b)(1), 63.752(a) Electronic Reporting Some of the r espondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents 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 Method s 1, 1A, 2, 2B, 2C, 2D, 3, 4,18, 24, 25A,

### 8 **Respondent Activities** 40, 301, or 319 test s , and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem ) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S).

**5(b) Collection Methodology and Management** 

### 9

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agenc y to discern a source ’ s initial capability to comp ly 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 e nforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

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

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enf orcement 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employ ed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the mi nimum 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 Sch edule**  The specific frequency

for each information collection activity within this request is shown below in Table s 1 a 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** Table s 1 a 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to th is 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 display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three y ears from these recordkeeping and reporting requirement s is estimated to be 140,936 hours ( Total Labor Hours from Table s 1 a through 1c below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously

- approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the followin g labor rates: Managerial $ 123.04 ($5 8

. 59 + 110%) Technical $ 10 1

. 2 2 ($4 8

. 2 0 + 110%) Clerical $ 51

. 18 ($2 4

. 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 b y 110 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and O peration and Maintenance Costs**  The ty pe 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. Th e capital/startup costs are initial, one - time costs when a facilit y 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 photocop ying and postage.

**(iii) Ca pital/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

### 11 **Capital/Startup vs. Operation and Maintenance (O&M) Costs** Total $0 $136,000 

### The total capital/startup costs for this I CR are zero . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 136,000

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry

over th e next three y ears of the IC R 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 anal ys is of the reported information. EPA's overall complian ce and enforcement program i ncludes activities such as the examination of records maint ained 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 y ears of the ICR is estimated to be $ 233,003

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

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

. 21 (GS

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

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

. The rates have been increased b y 60 percent to account for the benefit packages available to government employ ees
. 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 I CR, on average over the next three ye ars, approximately 136 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 136 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.

### 12

**Number of Respondents**

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

Number of Existing Respondents (C)

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

Number of Respondents (E=A+B+C

- D)

1 0 136 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. 

### C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 136

. The total number of annual responses per ye ar is calculated using the following table:

### 13 **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 Com pliance 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 Sem iannual 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 th e s e standard s
. 

### The number of Total Annual Responses is 995

. The total annual labor costs are $ 13,785, 987

. Specific, individual d etails regarding these estimates may

be found below in Table s 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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 140,93 6 at a cost of $13,785,987

. Specific d etails regarding these estimates may

be found below in Table s 1a through 1c: Annual Respondent B urden 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 y ears 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, S ubpart 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 I CR 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 I CR : 1) corrects discrepancies in the number of compliance status reports and SSM reports between the respondent and the Agency burden tables; 2) corr ects rounding errors in respondent burden Table 1b in the previous I CR; and 3) changes the frequency of reviewing semiannual reports from one to two for the Agency . This I CR also uses updated labor rates in calculating all costs, which results in an overa ll increase in burden costs. Furthermore, this I CR 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 b y persons to generate, maintain, retain, or discl ose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verify ing information, processing an d maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

### 15

An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the 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 I CR 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 sy st em , 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 holiday s. The telephone number for the Reading Room is (202) 566

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

- 1752 . Also, y ou can send comments to the Office of In formation 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.

### 16

**Table 1 a**  **: 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 person**  **** **hours per year**  **(C x D) (F)** 

**Managem ent**  **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 c 1 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 e 20 1 20 136 2,720 136 272 $305,972.80 Waiver application f 4 1 4 14 56 2.8 5.6 $6,299.44 Startup, shutdown, malfunction plan g 4 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 h 2 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 k 1 12 12 122 1,464 73.2 146.4 $164,685.36 Solvent usage log for exempt processes l 0.5 12 6 95 570 28.5 57 $64,119.30 Log of gun cleaner leaks m 1 6 6 27 162 8.1 16.2 $18,223.38 D. Develop record system n 20 1 20 136 2,720 136 272 $305,972.80 E. Time to enter information Records of startup, shutdow n, 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 o 4 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 42,18**  **8. 9**  **$4,126,808.14 TOTAL LABOR BURDEN AND COST**  **(rounded) 49,298**  **$4,822,221**

**Assu mptions:**  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 a dditional 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, Bu reau of Labor Statistics, March 2013 , T able 2. Civilian Workers, by Occupational and Industry group. The rates are from column 1, Total Compensation. The rates have been increased by 110 perc ent to account for the benefit packages available to those empl oy ed 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 ass umed 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 exces s 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.

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**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)** 

**T echnical**  **person**   ** hours per** **year (C x D)**  **(F)**

**Managem ent**  **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 c 1 1 1 136 136 6.8 13.6 $15,298.64 B. Required activities Initial performance tests d 280 1 280 4 1,120 56 112 $125,988.80 Repeat performance test e 280 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 g 4 1 4 14 56 2.8 5.6 $6,299.44 Startup, shutdown, malfunction plan h 4 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 i 4 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 w eighted average mass k 1 250 250 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 l 10 1 10 136 1,360 68 136 $152,986.40 E. Time to enter/maintain information Records of startup, shutdow n, 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** 

**Assu mptions:**  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 a dditional 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 perc ent to account for the benefit packages

### 21

available to those e mp loy ed 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 mas kant 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 w aiver (136 x 10% = 14)

. h We have assumed that 30 percent of facilities will be required to submit operational plans due to deviations from manufacture rs’ specifications, and based on the number of facilit ies 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 malfu nction. 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.

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**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)**

**Managem ent**  **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 c 1 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 test 2 1 2 0 0 0 0 $0 Report of initial test See 3B Startup, shutdown, malfunction report d 4 1 4 1 4 0.2 0.4 $450 Semiannual report

– including report of periods of Noncompliance e 12 2 24 4 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 activities 4 1 4 5 20 1 2 $2,249.80 C. Implement activities f Chemical stripper records (demonstrating compliance) 8 1 8 4 32 1.6 3.2 $3,599.68 Chemical stripper usage log 1 12 12 4 48 2.4 4.8 $5,399.52 Depainting equipment malfunction log 4 3 12 2 24 1.2 2.4 $2,699.76 Exempt stripper usage log and rew orked airplane 1 12 12 5 60 3 6 $6,749.40 log spot stripping and decal removal Record of parts removed for parts depainting 8 2 16 5 80 4 8 $8,999.20 Control device maintenance log 0.5 250 125 2 250 12.5 25 $28,122.50 D. Develop record system g 10 1 10 5 50 2.5 5 $5,624.50 E. Time to enter information Records of startup, shutdow n, and malfunction 2 1 2 0 0 0 0 $0
Records of all measurements and information required by standard See 4C F. Time to train personnel 4 1 4 5 20 1 2 $2,249.80 G. Time for audits 10 1 10 5 50 2.5 5 $5,624.50 **Subtotal for Recordkeeping Requirements 729**  **$71,318.6** 6 **TOTAL LABOR BURDEN AND COST (rounded)**  **907 $88,75**  **5**

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**Assu mptions:**  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 a dditional sources during the next three years of this ICR. Of the 136 facilities , we assume 5 facilities have depainting operatio ns. 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 perc ent 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 malf unction ( 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 w ill 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.

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**Table 1d: Summary of Annual Respondent Burden and Cost for Tables 1a, 1b, & 1c**
**- NES**  **HAP 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**

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**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 person**  **** **hours per year**  **(C x D) (F)** 

**Managem ent**  **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 c 16 1 16 1 16 0.8 1.6 $829.19 Retesting d 80 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 e 2 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 f 6 1 6 27 7 1,662 83.1 166.2 $86,132.32 Waiver application g 6 1 6 28 168 8.4 16.8 $8,706.52 Review of startup, shutdown, malfunction plan h 6 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 i 2 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 j 3 2 6 222 1,332 66.6 133.2 $69,030.23
**TOTAL ANNUAL BURDEN AND COST (rounded)**  **5,170 $233,00**  **3**

### 27

**Assu mptions:**  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 a dditional sources during the next three years of this ICR. b This cost is based on the following labor rates w hich 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) 20 13 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 p erformance test and w ill 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 repo rt. 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 h ours to review the initial performance test. j We have assumed that it will take 3 hours to review each sem iannual report.