SUPPORTING STATEMENT FOR

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)

FOR PAINT STRIPPING AND MISCELLANEOUS SURFACE COATING OPERATIONS

AT AREA SOURCES (40 CFR PART 63, SUBPART HHHHHH)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

December 2007
1

PART A OF THE SUPPORTING STATEMENT 

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection.

This Information Collection Request (ICR) is entitled 

“NESHAP for Paint Stripping and Miscellaneous Surface Coating 

Operations at Area Sources (40 CFR PART 63, SUBPART HHHHHH)”. The

ICR number for this is 2268.02.

1(b) Short Characterization/Abstract.

The National Emissions Standards for Hazardous Air 

Pollutants for Paint Stripping and Miscellaneous Surface Coating 

Operations at Area Sources (40 CFR part 63, subpart HHHHHH) are 

being made final. These standards are part of EPA’s Integrated 

Urban Strategy to reduce cancer risk from area sources under 

section 112(k)(3)(C) of the CAA. The affected sources will have 

to comply with recordkeeping and reporting requirements of the 

new rule.

This ICR includes the burden for activities that will be 

conducted in the first three years following promulgation of the 

National Emissions Standards for Hazardous Air Pollutants for 

Paint Stripping and Miscellaneous Surface Coating Operations at 

Area Sources. The owners or operators of facilities with these 

operations would read instructions to determine how they will be 

affected by the rule. 

New and existing sources will also have to submit an initial

notification. New sources will also be required to submit a 

notification of compliance status and maintain records. Because 

the compliance date for existing sources is 3 years after the 

NESHAP is promulgated, other recordkeeping and reporting 

activities for existing sources do not begin until 3 years after 

promulgation. Therefore, they are not included in the burden 

estimate for the first 3 years. 
2

Although not necessary for this ICR, respondent burden 

estimates for year 4 are included in Attachment A4, B3, C4, and 

the agency burden estimates are provided in Attachment D4 to 

provide perspective on the annual burden when the rule is fully 

implemented. 

This information is being collected to assure compliance 

with 40 CFR part 63, subpart HHHHHH. Owners or operators will 

keep records and submit required reports to EPA or the delegated 

State regulatory authority. Notifications, reports, and records 

are essential in determining compliance; and are required, in 

general, of all sources subject to NESHAP. Owners or operators 

subject to the miscellaneous surface coating NESHAP will maintain

records and retain them for at least 5 years following the date 

of such reports and records. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires EPA to 

develop NESHAP for both new and existing major and area sources. 

A major source is defined in section 112(a) as any stationary 

source or group of stationary sources located within a contiguous

area and under common control that emits, or has the potential to

emit, considering controls, in the aggregate, 10 tons per year 

(tons/yr) of any one HAP or 25 tons/yr of any combination of HAP.

An area source is defined in section 112(a) as any stationary 

source that is not a major source. Thus, area sources do not emit

nor have the potential to emit HAP at or above the 10 or 25 

tons/yr thresholds. 

The CAA further requires EPA to determine the HAP emitted by 

area sources that pose the greatest threat to public health in 

urban areas. Specifically, section 112(k)(3)(B) instructs EPA to 

develop a list of at least 30 HAP emitted by area sources that

pose the greatest threat to public health in the largest number 
3

of urban areas. Once that is accomplished, sections 112(c)(3) and

112(k)(3)(B)(ii) direct EPA to identify source categories of area

sources that represent 90 percent of the emissions of the 30 

identified HAP. Section 112(k)(3)(C) requires EPA to also develop

a strategy under section 112 or other laws to reduce the 

incidence of cancer attributable to exposure to HAP emitted by 

stationary sources by not less than 75 percent, considering 

control of emissions of HAP from all stationary sources and 

resulting from measures implemented by EPA or by the States under

the Act or other laws. On July 19, 1999, EPA published its 

Integrated Urban Strategy, which included both the list of 30 HAP

and the initial list of area source categories (64 FR 38706), 

which included “Paint Stripping Operations”. On June 26, 2002 

and November 22, 2002, EPA added “Autobody Refinishing Paint 

Shops” (67 FR 43112) and “Plastic Parts and Products (Surface 

Coating)” (67 FR 70427), respectively, to the list of area source

categories. The scope of the autobody refinishing category has 

since been revised to include all motor vehicle and mobile 

equipment refinishing to reflect the fact that sources that 

perform mobile equipment refinishing use many of the same 

coatings as used in motor vehicle refinishing, and motor vehicles

and mobile equipment are often refinished at the same or similar 

sources. The scope of the plastic parts and products (surface 

coating) source category has also been revised to include metal 

parts and products to more accurately reflect the scope of the 

sources analyzed in identifying that area source category as a 

source of urban HAP.

Since the development of the area source category list, EPA 

has determined that it is technically feasible to regulate 

emissions from these three source categories by a single set of 

emission standards. The processes, emission points, emission 

characteristics, and emission controls for plastic parts and 

products surface coating and autobody refinishing are very 
4

similar. Additionally, paint stripping is often performed as 

part of the surface preparation for both plastic parts and 

autobody refinishing which, by regulating within the scope of a 

single set of standards, reduces the burden of complying with 

multiple standards on the sources performing both the paint 

stripping and subsequent coating. This single set of emission 

standards to address all three categories also minimizes the cost

of developing, permitting, and enforcing the standards. 

In summary, the information obtained during the data 

gathering phase of the project demonstrated that the processes, 

emission characteristics, and applicable control technologies for

facilities in these categories are similar. Based on these 

factors, EPA concluded that these three categories are to be 

treated as a single source category for the purposes of this 

rulemaking. For purposes of the preamble and final rule, the 

term paint stripping and miscellaneous surface coating is used to

indicate that the three source categories of plastic parts and 

products (surface coating), autobody refinishing, and paint 

stripping have been treated as a single source category. 

Certain notifications and reports, as described in this 

information collection request, are necessary to enable the 

Administrator to identify existing sources subject to the NESHAP 

and to determine if the standards are being achieved.

2(b) Practical Utility/Users of the Data.

In order to minimize HAP emissions from paint stripping, 

motor vehicle and mobile equipment refinishing operations, and 

miscellaneous surface coating, facilities must comply with 

certain equipment requirements and management practices. The 

information generated by the recordkeeping and reporting 

requirements described in this ICR will be used by EPA to ensure 

that personnel who spray coatings are certified in the proper 

selection, mixing, and application of coatings. Additionally, the
5

information will ensure that filters and spray guns at spray 

booths of affected facilities meet the minimum efficiency 

requirements. Further, this information will help EPA to maintain

an updated inventory of all sources with paint stripping or 

surface coating operations.

Adequate recordkeeping and reporting are necessary to ensure 

compliance with the standards, as required by the CAA. The 

information collected from recordkeeping and reporting 

requirements is also used for targeting inspections, and is of 

sufficient quality to be used as evidence in court. To minimize 

the burden, much of the information, which is kept on site, could

be reviewed by enforcement personnel during an inspection and 

would not need to be routinely reported to the agency. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication.

If the subject standards have not been delegated, the 

information is sent directly to the appropriate EPA Regional 

Office. Otherwise, the information is sent directly to the 

delegated State or local agency. If a State or local agency has 

adopted their own similar standards to implement the Federal 

standards, a copy of the notice or report submitted to the State 

or local agency can be sent to the Administrator in lieu of the 

notice or report required by the Federal standards. 

During the development of subpart HHHHHH, three different 

source categories were combined to be regulated under a single 

subpart. Subpart HHHHHH now includes sources that perform 

surface coating on both motor vehicles/mobile equipment, metal or

plastic parts, or paint stripping, and this consolidation removed

any duplicate rule requirements. Therefore, no duplication 

exists. 

3(b) Public Notice Required Prior to ICR Submission to OMB.
6

An announcement of a public comment period for the renewal 

of this ICR was published in the Federal Register on September 

17, 2007 (72 FR 52958) as part of the proposed rulemaking. No 

comments were received on the burden published in the Federal 

Register that resulted in a change in the burden estimate.

3(c) Consultations.

During the development of this rule, EPA met with industry 

in order to obtain data and input on the training, recordkeeping 

and reporting requirements from the facilities potentially 

affected by this rule. 

For motor vehicle or mobile equipment finishing or 

refinishing, EPA met with the Alabama Collision Repair Industries

Association, Automotive Aftermarket Industry Association, 

Automotive Service Association, California Autobody Association, 

Cedar Rapids (Iowa) Autobody Association, Coordinating Committee 

For Automotive Repair (C-CAR), Collision Industry Council, InterIndustry Conference on Auto Collision Repair (I-CAR), I-CAR 

Education Foundation, National Association of Fleet 

Administrators, National Automobile Dealers Association, National

Paint and Coatings Association, and the National Institute for 

Automotive Service Excellence (ASE).

For miscellaneous parts and products surface coating, EPA 

contacted the Composite Manufacturers Association in order to 

obtain data and input from the facilities potentially affected by

this rule. The EPA also set up a web-based pilot-project for 

sources to visit and submit data on miscellaneous surface coating

operations. Neither of these sources provided data or input on 

the proposed rulemaking or associated burdens.

For paint stripping, the EPA will alert industry groups such 

as the Halogenated Solvents Industry Alliance (HSIA), and State 

and Local governments of its pending publication. The EPA will 

also involve the Small Business Administration (SBA) to assist in
7

outreach to small business entities that may not otherwise be 

aware of the final rule. 

The public also had the opportunity to review and comment on

the proposed rule and the ICR during the specified comment 

period. 

3(d) Effects of Less Frequent Collection.

The final rule includes the minimum requirements needed to 

demonstrate continuous compliance with the rule. Less frequent 

information collection would decrease the margin of assurance 

that facilities are continuing to meet the final standards. 

Requirements for information gathering and recordkeeping are 

useful techniques to ensure that equipment requirements and work 

practices are applied. If the information required by the 

standards were collected less frequently, the likelihood of 

detecting inadequate equipment or operating practices would 

decrease and emissions would increase. 

3(e) General Guidelines.

The standards require affected facilities to maintain all 

records, including reports and notifications for at least 5 

years. This is consistent with the General Provisions as applied 

to the standards. Also, the retention of records for 5 years 

would allow EPA to establish the compliance history of a source 

and any pattern of compliance for purposes of determining the 

appropriate level of enforcement action. Historically, EPA has 

found that the most flagrant violators frequently have violations

extending beyond the 5 years. The EPA would be prevented from 

pursuing the worst violators due to the destruction or 

nonexistence of records if records were retained for less than 5 

years. 

Additionally, no reports or compliance notifications from 

existing sources are submitted in the first 3 years after 
8

promulgation of the rule. The only burden for owners and 

operators of existing sources in the first 3 years is to read and

understand the rule requirements and submit an initial 

notification letter, and maintain records indicating that all 

spray painters have received appropriate training. The other 

activities take place after the compliance date. The compliance 

date is 3 years after the promulgation date, so compliance 

reporting does not begin until the fourth year after 

promulgation. 

3(f) Confidentiality.

All information submitted to EPA for which a claim of 

confidentiality is made will be safeguarded according to EPA 

policies set forth in title 40, chapter 1, part 2, subpart B --

Confidentiality of Business Information (see 40 CFR 2; 

41 FR 36902, September 1, 1976, amended by 43 FR 39999, 

September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674,

March 23, 1979).

3(g) Sensitive Questions.

None of the reporting or recordkeeping requirements contain 

sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes.

Subpart HHHHHH has affected sources from three different 

source categories, which include: paint stripping, miscellaneous 

surface coating, and motor vehicle and mobile equipment surface 

coating. The following are the industrial classification of 

entities potentially regulated by the final rule. This list is 

not meant to be exhaustive, but it serves as a guide for entities

required to submit information discussed in this ICR. 
9

Table 1: NAICS Categories for Various Affected Sources

Category NAICS Examples of Potentially 

Regulated Entities

Paint Stripping

Natural Gas 

Liquid 

Extraction

211112

Natural Gas Liquid 

Extraction.

Spices and 

Extracts

311942

Spices and Extracts.

Mobile Homes 321991

Mobile Homes.

Basic Chemical 

Manufacturing 325110

325120

325131

325188

325192

325193

325199

Petrochemicals, Industrial 

Gases, Inorganic Dyes and 

Pigments, Basic Inorganic 

and Organic Chemicals,

Cyclic Crude and 

Intermediates, Ethyl 

Alcohol.

Plastics 

Material 

Synthetic 

Resins, and 

Nonvulcanizable 

Elastomers

325211

Plastics Material Synthetic 

Resins, and Nonvulcanizable 

Elastomers.

Paint and 

Coating 

Manufacturing

325510

Paint and Coating 

Manufacturing.

Miscellaneous 

Chemical 

Production and 

Preparation

325998

Miscellaneous Chemical 

Production and Preparation.

Alumina 

Refining 331311

Alumina Refining.

All Other 

Plastics 

Products

326199 All Other Plastics Products.
10

All Other 

Miscellaneous 

Manufacturing 

339999 All Other Miscellaneous 

Manufacturing. 

Waste Treatment 

and Disposal 562211

562212

562213

562219

Hazardous Waste Treatment 

and Disposal, Solid Waste 

Landfill, Solid Waste 

Combustors and Incinerators, 

Other Nonhazardous Waste 

Treatment and Disposal.

Materials 

Recovery 562920

Materials Recovery.

Reupholstery 

and Furniture 

Repair 

811420

Reupholstery and Furniture 

Repair.

Miscellaneous Surface Coating

Aerospace 

Equipment

336413 

336414 

336415 

54171

Aircraft engines, aircraft 

parts, aerospace ground 

equipment.

Automobile 

Parts

335312 

336111 

336211 

336312

33632

33633 

33634 

33637 

336399

Engine parts, vehicle parts 

and accessories, brakes, 

axles, etc.

Motor vehicle body 

manufacturing and automobile 

assembly plants.

Extruded 

Aluminum

331316 

331524 

332321 

332323

Extruded aluminum, 

architectural components, 

coils, rod, and tubes.

Heavy Equipment 33312 

333611 

Tractors, earth moving 

machinery.
11

Job Shops 332722 

332813 

332991 

334119 

336413 

339999

Any of the products from the 

miscellaneous metal parts 

and products segments.

Manufacturing industries not 

elsewhere classified (e.g., 

bezels, consoles, panels, 

lenses).

Large Trucks 

and Buses

33612 

336211

Large trucks and buses.

Metal Buildings 332311 Prefabricated metal: 

buildings, carports, docks, 

dwellings, greenhouses, 

panels for buildings.

Metal 

Containers

33242 

81131 

322214 

331513 

Drums, kegs, pails, shipping 

containers.

Metal Pipe and 

Foundry

331111 

331513 

33121 

331221 

331511

Plate, tube, rods, nails, 

etc.

Rail Transportation33651 336611 

482111

Brakes, engines, freight 

cars, locomotives.

Recreational 

Vehicles

3369 

331316 

336991 

336211 

336112 

336213 

336214 

336399

Motorcycles, motor homes, 

semi trailers, truck 

trailers.

Rubber-toMetal Products326291 

326299

Engine mounts, rubberized 

tank tread, harmonic 

balancers.

Structural 

Steel

332311 

332312

Joists, railway bridge 

sections, highway bridge 

sections.
12

Other 

Transportation 

Equipment

336212 

336213 

336214 

336999 

33635 

56121 

8111 

56211

Miscellaneous transportation 

related equipment and parts. 

Truck trailer manufacturing. 

Motor home manufacturing. 

Travel trailer and camper 

manufacturing.

Other 

industrial and 

commercial

337214 Office furniture, except 

wood.

Miscellaneous 

Plastic Parts

32614

32615

326199

Plastic foam products (e.g., 

pool floats, wrestling mats, 

life jackets).

Plastic products not 

elsewhere classified (e.g., 

name plates, coin holders, 

storage boxes, license plate 

housings, cosmetic caps, cup 

holders).

Office 

Equipment

333313 Office machines.

Electronics 33422 Radio and television 

broadcasting and 

communications equipment 

(e.g., cellular telephones).

Medical 

Equipment

339111, 

339112

Medical equipment and 

supplies.

Sporting 

Equipment

33992 Sporting and athletic goods.

Signs 33995 Signs and advertising 

specialties.

Marine 

Equipment

336612

713930

Boat building

Marinas, including boat 

repair yards

Motor Vehicle and Mobile Equipment Refinishing
13

Commercial 441110

441120

811121

New Car Dealers; Used Car 

Dealers; Automotive Body, 

Paint, and Interior Repair 

and Maintenance.

Government Not 

Applicable

Government entities, besides 

Department of Defense, that 

maintain vehicles, such as 

school buses, police and 

emergency vehicles, transit 

buses, or highway 

maintenance vehicles.

4(b) Information Requested. 

(i) Data items. The recordkeeping and reporting requirements of 

the final rule include the following:

•Initial notification letter §63.11175(a) 

•Notification of compliance status §63.11175(b)1

•Annual notification of changes reports §63.11176(a)1

•Records of painter certification §63.11177(a)

•Records of filter efficiency §63.11177(b)2

•Records of spray gun efficiency §63.1177(c)3

•Records of notifications and annual reports §63.11177(d)1

•Records of annual usage of methylene chloride (MeCl) in 

paint strippers §63.11177(e)4

•Records of current methylene chloride minimization

§63.11177(f)3

•Records of deviations from compliance §63.11177(g)1

(ii) Respondent Activities. Both new and existing sources 

 

1 These notifications/reports/records are not required of paint stripping 

facilities using one ton or less of methylene chloride (MeCl) for paint 

stripping per year.

2 These records are only required if a source does not have a polyester fiber 

or fiberglass filter. If a source has another type of filter, it is assumed 

that the manufacturer of the alternative filter would perform the test. The 

only burden on the source would be the burden associated with recording and 

maintaining a file of this filter efficiency as reported by the manufacturer.

3 These records are only required for sources without an HVLP that opt to test 

non-HVLP type spray guns. 

4 These records are only required of sources with paint stripping operations 

that have an annual usage of more than one ton of MeCl.
14

must read the rule and understand the rule requirements. 

Respondents must also submit notifications and annual reports

according to the timelines specified in the rule. Each source 

must maintain all applicable records for 5 years.

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities.

A list of Agency Activities is provided in Attachments D1 to 

D3.

5(b) Collection Methodology and Management.

Reports submitted to the Agency and records maintained by 

the respondents may be tabulated and published for use in 

compliance and enforcement programs.

5(c) Small Entity Flexibility.

Affected facilities are primarily small entities (e.g., 

small businesses). Because of the large number of small 

businesses that are likely to be affected by this rule, the 

reporting requirements for the individual facilities are minimal.

There are no quarterly or semiannual requirements as there are 

with most regulated large industries. The burden is further 

minimized since costly monitoring equipment, or performance tests

are not required. For this ICR, it is estimated that out of the 

existing sources 93.5 percent (37,224 sources) are estimated to 

be small businesses.

5(d) Collection Schedule.

The information collection schedule is different for new and 

existing sources subject to the final rule. New sources are 

required to submit their initial notification and notification of
15

compliance5 within 180 days after their initial start-up or 180 

days after this rule is promulgated. Existing sources have two 

year from the date the rule is promulgated to submit the initial 

notification and three years and 60 days after the rule is 

promulgated to submit the notification of compliance, if 

required. These two notifications are one-time-only burdens.

New and existing sources must also submit an annual report5

for each calendar year by March 1 of the following year if there 

are any changes in the information contained in the initial 

notification since the initial notification or a previous report 

of changes, starting with the year of the initial compliance date

for the source. This corresponds to the first annual report being

submitted in years 2 and 4 of this ICR for new and existing 

sources, respectively.

Records of each notification, annual report and deviations 

from compliance, if required, must be kept at the source for five

years. Owners of affected surface coating operations must 

maintain additional records of painter certification dates and 

refresher training dates, spray booth filter efficiency, and 

spray gun efficiency provided by the manufacturers. Owners of an

affected paint stripping operation must maintain additional 

records of annual MeCl usage in paint stripping operations.

Owners of affected paint stripping operations that use more than 

one ton of MeCl in paint strippers, per year, must maintain a 

record of their MeCl minimization plan on-site for the duration 

of their facility’s operations. The data items and respondent 

activities for surface coating operations are summarized in 

Attachments A1 to A3 (commercial entities), Attachments B1 to B3 

(government-owned entities). Since the respondent activities are 

slightly different, the requirements for affected paint stripping

operations are summarized in Attachments C1 to C3.

 

5 Notifications of compliance and annual compliance reports are not required 

from paint stripping facilities with annual usage of 1 ton or less of MeCl in 

paint stripping operations.
16

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden.

Tables A1-A3, B1-B3, and C1-C3 in Attachments A to C present 

an itemized breakdown of the reporting and recordkeeping 

requirements in the first 3 years for the respondents subject to 

the final NESHAP. 

The individual burdens are expressed under standardized 

headings consistent with the concept of burden under the 

Paperwork Reduction Act. Where appropriate, the specific tasks 

and major assumptions have been identified. Responses to this 

information collection are mandatory. An 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(b) Estimating Respondent Costs.

(i) Labor Costs. 

Labor rates, on a per-hour basis, are from the United States 

Department of Labor, Bureau of Labor Statistics, Occupational 

Employment Statistics, May 2005. The occupational category that 

is the most similar to personnel at affected facilities with 

miscellaneous surface coating operations or paint stripping 

operations is assumed to be an average (mean) of “Automotive 

Body, Paint, Interior, and Glass Repair,” “Plastics Product 

Manufacturing,” and “Fabricated metal product manufacturing.” 

This ICR uses the labor rates for the following occupations 

within these categories: for technical labor, an average of 

automotive body and related repairers, and environmental 

engineers; for managerial labor, first-line supervisors/managers 

of mechanics/installers/repairers, and engineering managers; for 

clerical labor, file clerks and secretaries. The hourly mean wage 

rates from May 2005 have been multiplied by a factor of 1.6 so 
17

that overhead and benefits are included in the per-hour labor 

rates used to estimate respondent costs. The resulting rates used

are $45 for technical personnel, $58 for management and $19 for 

clerical personnel.

(ii) Capital Costs. 

Capital costs usually include any produced physical good 

needed to provide the information, such as machinery, computers, 

and other equipment. EPA does not anticipate that respondents 

will incur capital costs in carrying out the information 

collection requirements covered in this ICR.

(iii) Operations and Maintenance Costs. 

Sources will incur costs for photocopying and mailing 

notifications and reports. For this ICR, a one-time operations 

cost of $1 for mailing and making a photocopy of each initial 

notification and notification of compliance, and a $3 operations 

cost for mailing and making a photocopy of each annual report is 

included in the burden estimate. 

6(c) Estimating Agency Burden and Cost.

The only costs to Agency are those costs associated with EPA 

Regions and States reviewing the rule, and reviewing 

notifications and reports submitted by the respondents and 

maintaining a list of units subject to the Miscellaneous Surface 

Coating Operations at Area Sources rule. The labor rates for 

Agency employees are based on the estimated labor rates from the 

United States Department of Labor, Bureau of Labor Statistics, 

Occupational Employment Statistics, May 2005 for “Federal, State 

and Local Government”. This ICR uses the labor rates for the 

following occupations within this category: engineering managers

for managerial labor; environmental engineering technicians for 

technical labor; and secretaries, except legal, medical, and 
18

executive for clerical labor. The hourly mean wage rates from May

2005 have been multiplied by a factor of 1.6 so that overhead and

benefits are included in the per-hour labor rates used to 

estimate respondent costs. The resulting rates used are $32.75 

for technical personnel, $72.45 for management and $25.06 for 

clerical personnel. 

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

Costs.

The EPA estimates that the total number of potentially 

affected facilities is approximately 39,812 sources. This number 

of sources is expected to remain constant over the period of this

ICR. However, it is expected that an average of 1,593 new 

commercially-owned motor vehicle and mobile equipment refinishing

sources and 25 new miscellaneous surface coating sources will 

start-up each year over the next three years to replace existing 

sources which may go out of business.6 No new state or local 

government-owned mobile equipment refinishing shops are expected 

to start-up during this ICR period. A table showing the 

estimated number of sources for each category is shown in Table 2

below.

 

6 See the Memorandum in Docket #EPA-OAR-2005-0526 entitled “Estimating 

The Number Of Automotive Refinishing Shops And The Projected Number Of 

New Shops”.
19

Table 2 Summary of Respondent Universe

Category

Number of 

Existing 

Sources 

in Year 1

New 

Sources 

in Year 1 

of ICR*

New 

Sources 

in Year 2 

of ICR

New 

Sources 

in Year 3 

of ICR

Miscellaneous

Surface 

Coating

781 50 25 25

Commercial 

Motor Vehicle

and Mobile 

Equipment 

Refinishing

32,545 3,186 1,593 1,593

Government 

Motor Vehicle

and Mobile 

Equipment 

Refinishing

250 0 0 0

Paint 

Stripping 3,000 0 0 0

Totals 36,576 3,236 1,618 1,618

* See Table A1, note (d). The total number of sources in 

Year 1 is 39,812.

The total number of annual responses per year is calculated 

using the following table:

Table 3 Number of Responses per Respondent per Year Category (A) Annual Number of New Respondents (Average Year 1,2, and 3) (B) Number of Reports for New Respondents (C) Number of Existing Respondents (D)* Number of Reports for Existing Respondents (F) Number of Existing 

Respondents That Keep Records but Do Not Submit Reports

(E)Total Annual Responses E=(AxB)+(CxD)+F

Miscellaneous 

Surface 

33 3 781 1 0 1081
20

Coating

Commercial 

Motor Vehicle 

and Mobile 

Equipment 

Refinishing

2,124 3 32,545 1 0 38,917

Government 

Motor Vehicle 

and Mobile 

Equipment 

Refinishing

0 3 250 1 0 250

Paint 

Stripping

0 3 1,050 1 1,950 1,050

Total 6,472 34,426 41,298

* Responses for existing sources are only the initial notification, which is a

one-time burden during this three year ICR period.

The number of Total Annual Responses is 41,298, these 

responses include initial notifications, notifications of 

compliance status, and annual compliance reports and it does not 

count recordkeeping activities as a response. Details regarding 

these estimates may be found in Attachment Tables A1 to C3.

Due to the schedule of information collected under this ICR, 

the number of sources subject to reporting and recordkeeping 

requirements will vary over the three-year period. Respondent 

burden is calculated based on the assumption that the total 

number of units will remain constant during years one through 

three even though some units will qualify as new units under this

final rule.

6(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent Tally. An annual breakdown for each of the 

reporting, and recordkeeping activities required by the final

rule is presented in Tables A1 through C3 in Attachments A, B, 

and C, which represent years 1 through 3 of this ICR. Attachment 

A presents the burden on commercially-owned surface coating 
21

facilities, Attachment B presents the burden on government-owned 

surface coating facilities, and Attachment C presents the burden 

on paint stripping sources. The estimate of total annual hours 

requested from the respondents was based on the assumptions 

outlined in section 6(d) of this ICR. The EPA estimated the 

respondent burden for the first 3 years after the promulgation of

the NESHAP by totaling the hours per year for technical, 

managerial, and clerical staff at the facility. Due to the 

absence of capital or start-up costs in the first 3 years, there 

are no annualized capital costs. There are minimal operating and 

maintenance costs incurred in the first 3 years for each 

notification and report that is mailed to the Agency and copied 

for a facility record. The average annual respondent burden for 

the 3-year period is 246,703 hours, $10,154,722 in labor costs 

and $24,670 in operating and maintenance costs. A summary of the 

total annual burden and costs are shown in Table 4 below.

Table 4 Summary of Burden and Costs for the Affected Source 

Categories

Sector

Commercial 

Surface Coating

Government 

Surface 

Coating Paint Stripping Total

Year 1

Burden Hours 604,346 4,175 17,250 625,771 

Labor Cost $ 25,332,136 $ 174,920 $ 749,655 $ 26,256,711 

O&M cost $ 38,967 $ 250 $ 3,000 $ 42,217 

Year 2

Burden Hours 41,801 - 9,660 51,461 

Labor Cost $ 1,629,992 $ - $ 419,807 $ 2,049,798 

O&M cost $ 12,944 $ - $ - $ 12,944 

Year 3

Burden Hours 45,620 - 17,258 62,878

Labor Cost $ 1,795,962 $ - $ 361,695 $ 2,157,657

O&M cost $17,798 $ - $ 1,050 $ 18,848 

Annual 

Average

Burden Hours 230,589 1,392 14,723 246,704

Labor Cost $ 9,586,030 $ 58,307 $ 510,386 $10,154,723

O&M cost $ 23,236 $ 83 $ 1,350 $ 24,669
22

(ii) The Agency Tally. The bottom line Designated 

Administrator burden hours and costs, presented in Tables D1 

through D3 in Attachment D, were calculated by totaling the hours

per year for technical, managerial, and clerical staff, and by 

totaling the cost column. The average annual Agency burden over 

the first 3 years is 12,004 hours and $698,462 of labor costs. 

There are no capital, start-up or operating and maintenance costs

in the first 3 years. A summary of each year of Agency Burden is 

presented below in Table 5.

Table 5 Summary of Agency Burden for Years 1-3 of this ICR.

Agency

Year 1

Burden Hours 27,035 

Labor Cost $ 1,790,172 

O&M cost $ - 

Year 2

Burden Hours 3,721 

Labor Cost $ 126,528 

O&M cost $ - 

Year 3

Burden Hours 5,256 

Labor Cost $ 178,687 

O&M cost $ - 

3-year 

Average

Burden Hours 12,004 

Labor Cost $ 698,462 

O&M cost $ - 

(iii) Variation in the Annual Bottom Line. The total 

respondent labor costs for years 1, 2, and 3 are $26,256,711; 

$2,049,798; and $2,157,657, respectively. The total O&M costs are

$42,217; $12,944; and $18,848, respectively. The corresponding 

total number of respondent hours during this period is 625,771

hours, 51,461 hours, and 62,877 hours, which are shown in Table 4

above and Attachments A1 to C3. The variation in the burden for 

each of the three years is a result of the number of information 

collection activities required, based on the initial collection 
23

schedule and the fact that some burdens are one-time-only 

information collection activities. Starting in year four, which 

is shown in Attachments A4, B4, and C4, both existing and new 

sources are required to meet all the reporting and recordkeeping 

requirements and the annual burden is expected to stay relatively

constant from that point forward.

During the first 3 years, the Agency will be reviewing the 

regulation, and reviewing the initial notifications from all 

sources and the compliance notifications and initial annual 

compliance reports from the new sources. In years 1, 2, and 3, 

the Agency will expend 27,035; 3,721; and 5,256 total hours in 

labor, respectively. The corresponding costs for each year are 

$1,790,172; $126,528; and $178,687.

6(f) Reasons for Change in Burden.

 There was no comment on the ICR during the comment period

that resulted in a change in the burden estimate. Therefore, the 

burden for the final rule remains unchanged from the proposed 

rule. 

6(g) Burden Statement.

 The annual public reporting and recordkeeping burden for 

this collection of information is estimated to average 

approximately 6 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 
24

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 currently valid OMB control 

number. The OMB control numbers for EPA's regulations are listed 

in 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 docket for

this ICR under Docket ID No. EPA-HQ-OAR-2005-0526, which is 

available for online viewing at www.regulations.gov, or in person

viewing at the Air and Radiation Docket in the EPA Docket Center 

(EPA/DC), EPA West Building, Room 3334, 1301 Constitution Ave., 

NW, Washington, DC. The EPA/DC Public Reading Room is open from 8

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 Air and Radiation Docket 

Center is 202-566-1742.

An electronic version of the public docket is available at 

www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the 

public 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 above. 

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 Office for EPA.

Please include the EPA Docket ID No. EPA-HQ-OAR-2005-0526 and OMB

Control Number 2060-NEW in any correspondence.
25

Part B of the Supporting Statement

This part is not applicable because no statistical methods 

were used in collecting the information.
26

List of Attachments

Note: Where we use the term “Miscellaneous Surface Coating

Operations” in these table headings, we are referring to both the

plastic/metal surface coating operations and autobody refinishing

surface coating operations.

 Attachment A

o Table A1. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Commercial 

Miscellaneous Surface Coating Operations at Area 

Sources - Year 1

o Table A2. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Commercial 

Miscellaneous Surface Coating Operations at Area 

Sources - Year 2

o Table A3. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Commercial 

Miscellaneous Surface Coating Operations at Area 

Sources - Year 3

o Table A4. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Commercial 

Miscellaneous Surface Coating Operations at Area 

Sources - Year 4 (all existing sources comply)

 Attachment B

o Table B1. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Government 

Surface Coating Operations at Area Sources - Year 1

o Table B2. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Government 

Surface Coating Operations at Area Sources - Year 2 

o Table B3. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Government 

Miscellaneous Surface Coating Operations at Area 

Sources - Year 3
27

o Table B4. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Government 

Miscellaneous Surface Coating Operations at Area 

Sources - Year 4 (all existing sources comply)

 Attachment C

o Table C1. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Paint 

Stripping Operations at Area Sources - Year 1

o Table C2. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Paint 

Stripping Operations at Area Sources - Year 2

o Table C3. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Paint 

Stripping Operations at Area Sources - Year 3

o Table C4. Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements of Paint 

Stripping at Area Sources - Year 4 (all existing 

sources comply)

 Attachment D

o Table D1. Annual Designated Administrator Burden and 

Cost of Recordkeeping and Reporting Requirements of the

Paint Stripping and Miscellaneous Surface Coating 

Operations At Area Sources - Year 1 

o Table D2. Annual Designated Administrator Burden and 

Cost of Recordkeeping and Reporting Requirements of the

Paint Stripping and Miscellaneous Surface Coating 

Operations At Area Sources - Year 2

o Table D3. Annual Designated Administrator Burden and 

Cost of Recordkeeping and Reporting Requirements of the

Paint Stripping and Miscellaneous Surface Coating 

Operations At Area Sources - Year 3

o Table D4. Annual Designated Administrator Burden and 

Cost of Recordkeeping and Reporting Requirements of the

Paint Stripping and Miscellaneous Surface Coating 

Operations At Area Sources - Year 4 (all existing 

sources comply)