**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Automobile and Light**
**- duty Truck Surface Coating (40 CFR Part 63, Subpart**  **IIII) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Automobile and Light

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal) , EPA I CR Number 2045.0 5 , OMB Control Number 2060

- 0550 **1(b) Short Characterization/Abstract** The National Emission Standard s for Hazardous Air Pollutants (NESHAP) for Automobile and L ight

- duty Truck Surface Coating were proposed on December 24, 2002 , and promulgated on April 26, 2004

. The rule was amended on both December 22, 2006 and on April 24, 2007 , to further clarify what types of coating operations are subject to the NESHAP. These amendments neither affect ed n or altered the existing reporting, monitoring, or recordkeeping requirements previously published in the April 26, 2004 final rule. These r egulations appl y to new, reconstructed, or existing facilities that perform surface coating operations on automobiles and light

- duty trucks. New facilities include those that commenced construction after December 24, 2002

. This information is being colle cted to assur e compliance with 40 CFR part 63, subpart IIII

. 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 re cords of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determi ning compliance, and are required of all affected facilities subject t o NEHSAP. 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 m easurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

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

. S

. Environmental Protection Agency (EPA) regio nal office. Based on our consultations with industry representatives, there is an average of one affected facility 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 65 respondents per ye ar will be subject to the se standard s , and no additional respondents per year will become subject to the standard.2

The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance. ” The “Affected Public” are owners or operators of automobile and light

- duty truck surface coating facilities

. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Automobile and L i ght

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal)

. T he “burden ” to the Federal Government is attributed entirely to work performed by either F ederal employees or government contractor s , and may be found below in Table 2 : Average Annu al EPA Burden and Cost

– NESHAP for Automobile and Li ght

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (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 shal l require the maximum degree of emission reduction. Inaddition, 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 Admini strator may reasonabl y require. In the Administrator's judgment, hazards air pollutant (HAP) emissions from automobile and light

- duty truck surface coating operations cause or contribute to air pollution th at may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this s ource category at 40 CFR part 63, subpart IIII

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirement s in the standard s ensure s 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 ar e required in order to determine an affected facility ’ s initial3

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 s 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 , that leaks are being detected and repaired , and that the standard s 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 IIII

. **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) Publ ic 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 (77 FR 63813) on October 17, 2012

. No comments were received on the burden published in the Fed eral Register. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported b y 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 the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data.4

Consultations with industry representatives (i.e., respondents) were conducted to determine if there is an y way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard s to make it easier to compl y. In developing th is I CR, EPA contacted : 1) the Alliance of Automobile Manufacturers , at (202) 326

- 5500 , and 2) the American Coatings Association (ACA) , at (202) 462

- 6272 . EPA did not receive any comments from the consultations. It is our policy

to respond after a thorough review of comments received since the last ICR renewal , as well as to those submitted in response to the first Federal Register notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assuranc e 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 informatio n required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines** T hese reporting or recordkeeping requirement s do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the Ge neral 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. T h e retention of records for five years allow s 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 beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (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).5

**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 automobile and light

- duty truck surface coating operations

. The United States Standard Industrial Classification (SI C) codes and corresponding North American Industry Classification S ys tem (NAICS) codes for automobile and light

- duty truck surface coating operations are provided in the following table.
**Standard (**  **40 CFR Part 63, Subpart IIII )**  **SIC Codes NAICS Codes**  Automobile Manufacturing 3711 336111 Li ght Truck and Utility

Vehicle Manufacturing 3711 336112 Motor Vehicle Body Manufacturing 3711 336211 **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required b y the NESHAP for Automobile and L ight

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII)

. A source must make the following reports:
**Notification s**  Initial notification 63.3110(b), 63.5, 63.9(b) Notification of compliance status 63.3110(c), 63.9(h) Notification of construction/reconstruction 63.9(b), 63.5 Notification of actual startup 63.3110(a), 63.9(b) Notification of performance test 63.3110(a), 63.7(b), 63.8(e), 63.9(e)6
**Reports** Semiannual compliance report 63.3120(a) Excess emissions report 63.3120(a)(4

- 8) Performance test report 63.3120(b) , 63.10(d)(2) Startup, shutdown, malfunction report 63.3120(c) , 63.10(d)(5) A source must keep the following records: **Recordkeeping** Copies of notifications and reports 63.3130(a) Material formulation data 63.3130(b) Records of HAP content calculations 63.3130(c) Records of names of materials used 63.3130(d) HAP fractions in each material used 63.3130(e) Density of materials used 63.3130(f) Documentation of deviations 63.3130(g) Startup, shutdown, and malfunction plan/records 63.3130(h), 63.6(e) Documentation of capture sy stem efficiency determination 63.3130(i), 63.3130( j ) Documentation of add

- on control device destruction or removal efficiency determination 63.3130(k) Documentation of control device performance test 63.3130(k), 63.10(b) Determination of capture sy stem and add

- on control operating limits and compliance 63.3130(l) Determination of transfer efficiency 63.3130(m) Work practice plan/records 63.3130(n)7 **Recordkeeping** Operating instructions for add

- on control devices and CMS 63.3130(o) Records should be retained for 5 ye ars 63.3131(b), 63.10(b) Electronic Reporting Some of the r espondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and re cordkeeping at a plant site. Also, regulatory

agencies , in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respondents us e electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for temperature, gas flow, or pressure drop for installed oxidizer, carbon adsorber, condenser, concentrator, or capture s ys tem. Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 24, 25, 25A, 204, 204A to F , 311, or ASTM Method D1475

- 98, D2697

- 86, D5066

- 91, D5087

- 02, D5965

- 02, D6093

- 97, D6266

- 00a t est 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.8 **Respondent Activities** Adjust the existing way s to comply with an y previously applicable instructions and requirements

. 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 Act ivities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. 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**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used by the Agency

to discern a source ’ s initial capability to compl y with the emission standard , and to note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in b oth compliance and enforcement programs. 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,9

maintenance, and retrieval of compliance data f or approximately

125,000 industrial and government
- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorit ies 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** The 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 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, therefo re, 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 collecti on activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Automobile and Li ght

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings 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 this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person i s 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 requirement s is estimated to be 26,685 hours (Total Labor Hours from Table 1 below )

. T hese hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the prev iously

approved ICR, and any

comments received.10

**6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 2

. 49 ($5 8

. 3 3 + 110%) Technical $ 10 1

. 2 8 ($4 8

. 2 3 + 110%) Clerical $ 50

. 80 ($2 4

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

. **(ii) Estimating Capital/Startup and Operation 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 one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance (O &M) costs are the ongoing costs to maintain the monito r and other costs su ch 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 $16,000 0 $ 0 $1,200 6 5 $ 78 , 0 00 **Total $0**  **$ 78**  **, 0**  **00** 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 O&M costs for this I CR are $ 78 , 0 00

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

over the next three years of the IC R is estimated to be $ 78 , 0 00

. These are the costs of recordkeeping.11

**6(c) Estimating Agency Bur den and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, peri odic 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 $1 1 4, 428

. 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 2 General Schedule , which excludes locality , rates of pay

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

– NESHAP for Automobile and L ight

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (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 65 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 respondent s, as shown in the table below, is 6 5 per year. The number of res pondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondent s (E) Number of Respondents (E=A+B+C

- D) 1 0 65 0 0 65 2 0 65 0 0 65 3 0 65 0 0 65 **Average 0**  **65 0**  **0 65**  1 New respondent include sources with constructed, reconstructed , and modified affected facilitie s.12

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 65

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

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D
Initial notification 0 1 0 0 Notification of compliance status 0 1 0 0 Notification of construction/ reconstruction 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of performance test 1 0 1 .2 0 0 Report of performance test 1 0 1 .2 0 0 Semiannual report 65 2 0 130 Excess emission report 65 2 0 130 Startup, shutdown, malfunction report 2 16 1 0 16 Total 2 76 1 This ICR assumes 20 percent of respondents will need to repeat the performance test

. 2 This ICR assumes 25 percent of respondents (25%* 65 = 16. 25 ) will complete startup, shutdown, malfunction report. The number of Total Annual Responses is 276

. The to tal annual labor costs are $2,610,147

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

– NESHAP for Automobile and Li ght

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 (below) , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 26,685 hours at a cost of $2,610 , 147

. Details regarding these estimates may

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

– NESHAP for Automobile and Light

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII)13

(Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 9 7 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 7 8, 0 00

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 2, 539 labor hours at a cost of $1 1 4, 428 . See Table 2 below : Average Annual EPA Burden and Cost

– NESHAP for Automobile and L ight

- duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal). **6(f) Reasons for Change in Burden** There is an increase in respondent labor hours from the previous I CR. Thi s is not due to any program changes. The increase is due to a mathematical correction in the per

- respondent technical labor hours associated with burden item 4(d) in Table 1. Additionally , there is also an increase in the respondent and Agency costs due to use of updated labor rates. This I CR references recent labor rates from the Bureau of Labor Statistics to calculate respondent burden costs, and references recent labor rates from OPM to calculate Agency burden costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 9 7 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose o r 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 verifying information, processing and ma intaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

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

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 C FR 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 responde nt burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under14

Docket ID Number EPA

- HQ

- OECA

- 2012

- 0690

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

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

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

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

- 17 52

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

- HQ

- OECA

- 2012

- 0690 and OMB Control Number 2060

- 0550 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.15

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

**– NESHAP for Automobile and Light** 
**- duty Truck Surface Coating (40 CFR**  **Part 63, Subpart IIII) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per**  **respondent per year**  **Technical**

**person -**  **hours per respondent**  **per year (**  **C= AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year**  **( E=**  **CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year b**  **($)**
1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements a. Read rule and instructions 4 1 4 65 260 13 26 $ 29,245.97 b. Required activities i. Initial performance test c 24 1 24 0 0 0 0 $ 0 ii. Repeat performance test d 24 0.2 4.8 0 0 0 0 $ 0 iii. Compile and process data e 4 4 16 65 1,040 52 104 $ 116,983.88 c. Write reports i. Initial notification 2 1 2 0 0 0 0 $ 0 ii. Notification of compliance status 2 1 2 0 0 0 0 $ 0 iii. Notification of construction/ reconstruction 2 1 2 0 0 0 0 $ 0 iv. Notification of actual startup 2 1 2 0 0 0 0 $ 0 v. Notification of performance test d 2 1 2 0 0 0 0 $ 0 vi. Report of performance test d 10 1 10 0 0 0 0 $ 0 vii. Semiannual report f 6 2 12 65 780 39 78 $ 87,737.91 viii. Excess emissions report g 2 2 4 65 260 13 26 $ 29,245.9716

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per**  **respondent per year**  **Technical**

**person -**  **hours per respondent**  **per year (**  **C= AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year**  **( E=**  **CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year b**  **($)**
ix. Startup, shutdown, malfunction report h 2 1 2 16 32 1.6 3.2 $ 3,599.50 **Subtotal for R**  **eporting Requirements**  **2,72 7.8**  **$ 266,813**  **.23** 4. Recordkeeping Requirements a. Read rule and instructions 4 1 4 65 260 13 26 $ 29,245.97 b. Plan activities 12 1 12 65 780 39 78 $ 87,737.91 c. Implement activities 12 1 12 65 780 39 78 $ 87,737.91 d. Maintain record system for material used i 20 2 40 65 2,600 130 260 $ 292,459.70 e. Time to enter information i. Material usage j 0.5 365 182.5 65 11,862.5 593.13 1,186.25 $ 1,334,347.38 ii. Compliance calculation 2 12 24 65 1,560 78 156 $ 175,475.82 f. Time to train personnel 10 1 10 65 650 32.5 65 $ 73,114.9 0 g. Store, file and maintain records k 2 12 24 65 1,560 78 156 $ 175,475.82 h. Retrieve records/reports l 1 12 12 65 780 39 78 $ 87,737.91 **Subtotal for Recordkeeping Requirements 23,957**  **.38 $**  **2,343,333 .32**  **TOTAL ANNUAL BURDEN AND COST ( rounded**  **) 26,685**  **$ 2,610,147**  **Assu mptions:**  a. We estimate that an average of 65 existing sources will be subject to the rule over the three

- year peri od of this ICR, and no new sources will become subject. b. This I CR uses the following labor rates: $101.28 for technical, $122.49 for managerial, and $50.80 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “T otal compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those em ployed by private industry. c. We assume it will take 24 hours to complete the initial performance test. d. We assume 20 percent of respondents will need to repeat the performance test

. e. We assume each respondent will take four hours to compile and process data. This will occur four times per year. f. We assume each respondent will take six hours to complete each semiannual report. g. We assume each respondent will take two hours to complete excess emissions reports. This will occur two times per year.17

h. We assume 25 percent of respondents (25%*65 = 16. 25 ) will use add

- on controls, and that each will take two hours per year to complete the startup, shutdown, malfunction report. i. We assume it will take each respondent twenty hours to maintain the record system for materials us ed. This will occur two times per year. j. We assume each respondent will take 30 minutes to enter information on material usage. This will occur 365 times per year. k. We assume it will take each respondent two hours to store, file, and maintain record s. This will occur twelve times per year. l. We assume it will take each respondent one hour to retrieve records or reports. This will occur twelve times per year.18

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

**– NESHAP for Automobile and Light** 
**- duty Truck**  **Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person -**  **hours per occurrence**  **No. of**

**occurrences per**  **respondent per year**  **Technical**

**person -**  **hours per**  **respondent per year**  **( C=** **AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **( E=**  **CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year b**  **($)**

1. Initial performance test c 24 1 24 0 0 0 0 $ 0 2. Repeat performance test d 24 0.2 4.8 0 0 0 0 $ 0 3. Report review a. Initial notification 8 1 8 0 0 0 0 $ 0 b. Notification of compliance status 8 1 8 0 0 0 0 $ 0 c. Notification of construction/ reconstruction 8 1 8 0 0 0 0 $ 0 d. Notification of actual startup 8 1 8 0 0 0 0 $ 0 e. Notification of performance test d 8 1 8 0 0 0 0 $ 0 f. Report of performance test d 8 1 8 0 0 0 0 $ 0 g. Semiannual report e 12 2 24 65 1,560 78 156 $ 80,846.22 h. Excess emissions report f 4 2 8 65 520 26 52 $ 26,948.74 i. Startup, shutdown, ma lfunction report g 8 1 8 16 128 6.4 12.8 $ 6,633.54 **TOTAL ANNUAL BURDEN AND COST ( rounded**  **) 2,539**  **$ 114,428**  Assumptions: a. W e estimate that 65 existing sources will be subject to the rule over the three

- year period of this ICR, and that no new sources will become subject to the standard. b. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, an d $25.01 for clerical labor. These rates are from the Office of Personnel Management (OPM), 201 2 General Schedule, which excludes locality , rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to governm ent employees. c. We assume it will take 24 hours to complete the initial performance test review

. d. We assume 20 percent of respondents will need to repeat the performance test. e. We assume it will take twelve hours to review semiannual reports. f. We assume it will take four hours to review excess emissions reports. This will occur twice per year. g. We assume 25 percent of respondents (25%*65 = 16. 25 ) will use add

- on controls, and that each report will take eight hours to review.