SUPPORTING STATEMENT FOR

NATIONAL EMISSION STANDARDS FOR HAZARDOU S AIR POLLUTANTS (NESHAP) FOR PAINT STRIPPING AND MISCELLANEOUS SURFAC E COATING OPERATIONS

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

U.S. Environmental Prote ction Agency Office of Air Quality Planning and Standards Research Triangle Park, NC 27711

December 20071 PART A OF THE SUPPORTING STATEMENT

1. IDENTIFICATION OF THE INFORMATION COLLECTION 1(a) Title of the Information Collection. Thi s Information Collection Request (ICR) is entitled

“ NESHAP for Paint Stripping a nd Miscellaneous Surface Coating Operations a t Area Sources (40 CFR PART 63, SUBPART HHHHHH) ”. The ICR number for this is 2268.02.
1(b) Short Characterization/Abstract. The Na tional 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 r educe 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 fir st 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 c ompliance 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 followin g 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 i s 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 an y 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 threshold s. 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 number3

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 3 0 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 initi al 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 7042 7), 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 refi nishing 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 very4

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 st andards. 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 fa ctors, 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 info rmation 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 repo rting 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, the5

information will ensure that filters and spray guns at sp ray 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 ar e 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 mi nimize 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 h as 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 pa int 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 publi shed 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 t he 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 refini shing, 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, Inter

Industry Conference on Auto Collision Repair (I

- CAR), I

- CAR Education Foundation, National Association of Fleet Administrators, National Automobile Dealers Association, National Paint and Coatings As sociation, 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 af fected 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 pa int 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 in7

outreach to small business entities that may not otherwise be aware of the final rule
. Th e public also ha d 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 fo r 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 Gene ral 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. Hi storically, 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, n o reports or compliance notifications from existing sources are submitted in the first 3 years after8

promulgation of the rule. The only burden for owners and operators of existing sources in the firs t 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 regulat ed 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 Exam ples of Potentially Regulated Entities Paint Stripping Natural Gas Liquid Extraction 211112 Natural Gas Liquid Extraction
. Spice s and Extract s 311942 Spice s and Extract s.

Mobile Homes 321991 Mobile Homes
. Basic Chemical Manufacturing 325110 325120 325 131 325188 325192 325193 325199 Petrochemical s , Industrial

Gas es , Inorganic Dye s and Pigment s, Basic Inorganic and Organic Chemical s, Cyclic Crude and Intermediate s , 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 Product ion and Preparation 325998 Miscellaneous Chemical Product ion and Preparation
.

Alumi na Refining 331311 Alumina Refining
.
All Other Plastics Product s 326199 All Other Plastics Product s.10

All Other Miscellaneous Manufacturing 339999 All Ot her 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 Recover y. Reupholstery and Furniture Repair 811420 Reupholstery and Fu rniture 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 33 3611 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, le nses). 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 Trans

portation 33651 336611 482111 Brakes, engines, freight

cars, locomotives. Recreational Vehicles 3369 331316 336991 336211 336112 3 36213 336214 336399 Motorcycles, motor homes,

semi trailers, truck trailers.

Rubber

- to
Metal Products 326291 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.

O ther 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, co in 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 3391 11, 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 E quipment Refinishing13

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, suc h 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:

• In itial 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 §63.1117 7 (a)

•Records of filter efficiency §63.11177(b) 2

•Records of spray gun effic iency §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 c ompliance §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 requi red 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 associat ed 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. Eac h 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 D 1 to D 3.
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 requireme nts 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 (3 7 , 224 sources) ar e 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 of15

compl iance 5 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 promulgate d 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 report 5 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 a dditional 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 annua l MeCl usage in paint stripping operations
. Owners of affected paint stripping operations that use more than one ton of MeCl in paint stripper s , 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 b reakdown 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 Redu ction 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 informati on 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, Pain t, 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 re lated 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 rat es from May 2005 have been multiplied by a factor of 1.6 so17

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 cler ical 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 carr ying 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 an d 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 cost s 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 Sour ces rule. The l abor 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 G overnment”. 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, and18

executive for c lerical 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 pers onnel, $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 3 9 , 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 coat ing 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 sho wing 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

S ources 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

Total s 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 YearCategory(A)AnnualNumber of NewRespondents (AverageYear 1,2, and 3)(B)Number of Reportsfor New Respondents(C)Number of ExistingRespondents(D)*Number of Reportsfor ExistingRespondents(F)Number of ExistingRespondents ThatKeep Records but DoNot Submit Reports(E)Total Annual ResponsesE=(AxB)+(CxD)+F

Miscellaneous Surface 33 3 781 1 0 108120

Coating Commercial Motor Vehicle and Mobile Equipment Refinishing 2,124 3 32, 5 45 1 0 38,917

Government Motor Vehicle and Mobile Equipment Refinishing 0 3 250 1 0 250

Paint Stripping 0 3 1 , 05 0 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 notificatio ns, 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 constan t 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 record keeping 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 coating21

facilities, Attachment B pr esents 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 t his 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 respon dent burden for the 3

- year period is 24 6 , 703 hours, $10, 1 54 , 7 22 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 S ource 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 $ 2,1 57 ,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 $10,1 54 ,723 O&M cost $ 23,236 $ 83 $ 1,350 $ 24,66922

(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 co lumn. The average annual Agency burden over the first 3 years is 1 2 , 004 hours and $69 8 , 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 ; $2,0 49 , 798 ; and $2, 1 57 , 6 57 , respectively. The total O&M costs are $4 2 , 217 ; $1 2 , 944 ; and $ 18 , 848 , respectively. The corresponding total number of respondent hours during this period is 6 25 , 771 hours, 5 1 ,46 1 hours, and 6 2 , 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 col lection activities required, based on the initial collection23

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 revi ewing 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 2 7 , 035 ; 3, 721 ; and 5 , 256 total hours in labor, respectively. The corr esponding costs for each year are $1, 790 , 172 ; $1 26 , 528 ; and $1 78 , 687
. 6(f) Reasons for Change in Burden. Th ere 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 mea ns 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 a24

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 fo r 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

- 20 05

- 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 Readi ng 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 o f 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 electroni cally. 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, Atte ntion: 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 surfac e 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 Rec ordkeeping 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 Opera tions 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 C oating 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 327 o Table B4. Annual Respondent Burden and Cos t 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 Requiremen ts 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 Record keeping 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 t he 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 Operati ons At Area Sources

- Year 4 (all existing sources comply)