SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Aerospace Manufacturing and Rework Facilities 

(40 CFR Part 63, Subpart GG)

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

EPA ICR Number 1687.10 OMB Control Number 2060-0314. 

1(b) Short Characterization/Abstract

This supporting statement addresses information collection activities that will be imposed 

by amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for

Aerospace Manufacturing and Rework Facilities, 40 CFR part 63, subpart GG. Proposed on June 

6, 1994; promulgated on September 1, 1995; and last-amended on April 20, 2006, the NESHAP 

applies to existing and new aerospace manufacturing and rework facilities where the total 

hazardous air pollutants (HAP) emitted are greater than or equal to 10 tons per year of any single

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

combination of HAP. New facilities include those that commenced construction or 

reconstruction after the date of proposal. Operations covered include: cleaning, primer and 

topcoat application, depainting, chemical milling maskant application, and handling and storage 

of waste.

As part of the residual risk and technology reviews for the NESHAP, the final rule adds 

requirements for specialty coating application operations and removes the exemptions from the 

emissions limitations for periods of startup, shutdown and malfunction (SSM) so that affected 

units would be subject to the emission standards at all times. The final rule also makes 

clarifications to the compliance provisions, the application equipment requirements and 

inorganic HAP control requirements, and the requirements for waste storage and handling. This 

information collection request documents the additional recordkeeping and reporting 

requirements and burden imposed by the final rule for specialty coatings. The other changes 

being made in the final rule do not have any estimated additional recordkeeping and reporting 

requirement burden.

In general, all NESHAP standards require initial notifications, performance tests, and

periodic reports by the owners/operators of the affected facilities. These notifications, reports, 

and records are essential in determining compliance, and are required of all affected facilities 

subject to NESHAP. This ICR includes the burden for activities that will be conducted in the 

first three years following promulgation of the final amendments to the NESHAP for Aerospace 

Manufacturing and Rework Facilities. The final rule adds recordkeeping and reporting provisions 

for specialty coating operations, but does not change the compliance costs for operations already 
being regulated by the existing emission standards. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

notifications, reports, and records, and retain the file for at least five years following the date of 

such notifications, reports, and records. All reports are sent to the delegated state or local 

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

United States Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an average of one

affected specialty coating operation (which is the total of all specialty coating applications) at 

each plant site and that each plant site has only one respondent (i.e., the owner/operator of the 

plant site).

Over the next three years, an average of 144 facilities per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. However, 

36 of these facilities are owned and operated by the Federal government, and are not considered 

respondents of this ICR. Therefore, the Affected Public only includes the 108 facilities that are 

privately-owned, for-profit businesses. Each respondent may have one or more operations (e.g., 

cleaning, coating, depainting, or specialty coating operations) subject to these standards. Of the 

144 existing sources currently covered by this standard, 109 facilities have specialty coating 

operations. The EPA estimates that the total number of potentially affected facilities with 

specialty coating operations is approximately 27 Federal government-operated facilities and 82 

privately-operated facilities.

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

without any “Terms of Clearance.”

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

and operated by the aerospace manufacturing and rework industry. Thirty-six of the facilities in 

the United States are owned by the Federal government and 108 facilities are privately-owned, 

for-profit businesses (hereafter, the latter are referred to as the “Affected Public”). The “burden” 

to the Affected Public may be found below in Tables A1 to A3 of Attachment A. The cost of this 

ICR to privately-operated aerospace manufacturing and rework facilities is $435,176 in labor 

costs, averaged over the first 3 years after the amendments are final.

The total average annual Agency cost during the three years of the ICR is estimated to be 

$207,135. The “burden” to the Agency may be found below in Tables B1 through C3 of 

attachment A. The burden includes the cost to Federal government-operated aerospace 

manufacturing and rework facilities to comply with the final amendments, and to the Federal 

EPA and state agencies to implement the final amendments.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection
The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, HAP emissions from aerospace manufacturing and 

rework facilities cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NESHAP were promulgated for this source 

category at 40 CFR part 63, subpart GG.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) ensure compliance with 

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

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard(s). Continuous emission monitors are used to 

ensure compliance with the standard(s) 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 properly 

installed and operated, leaks are being detected and repaired, and 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. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under (40 CFR part 63, subpart

GG).

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 its own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

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

An announcement of a public comment period for this collection was provided in the 

Federal Register notice of proposed rulemaking published for the Aerospace Manufacturing and 

Rework Facilities NESHAP RTR (80 FR 8392) on February 17, 2015. The EPA received several 

comments that referenced the burden estimate, and a summary of these comments and the EPA's 

full response is provided in the Summary of Public Comments and Responses for Aerospace 

Manufacturing and Rework Facilities Risk and Technology Review, which is found in the docket 

for the final rulemaking (EPA-HQ-OAR-2014-0830). A summary of the comments and 

responses is also provided in the following paragraphs.

One commenter, the Airlines Industry Association, argued that EPA needs to provide a 

safe harbor for companies that reasonably rely on the VOC or HAP content data supplied by the 

manufacturer in order to support the EPA’s recordkeeping and reporting burden estimate based 

on the use of manufacturer supplied data. The commenter argued that the rule must clarify that 

facilities will not be subject to enforcement action if laboratory testing reveals a specialty coating 

VOC or HAP content value over the limit when the manufacturer's supplied VOC or HAP 

content data show values that are compliant and no additional solvents were added by the 

facility. The EPA responded that we disagree with the commenter. If the EPA adopted the 

commenter’s recommendation, then the EPA would have no method to enforce the VOC and 

HAP content standards in cases where a coating applicator adds HAP containing solvent to the 

coating. Laboratory testing of the VOC and HAP content of coating samples collected in an “as 

applied” condition using EPA Methods 24 (for VOC) and 311 (for HAP) is needed to ensure 

compliance with the requirements of surface coating NESHAP and to ensure that coatings are 

not in violation due to excessive HAP containing solvent added by the coating applicator. The 

EPA did not change the rule or the burden estimate as a result of this comment because 

manufacturers already provide VOC or HAP content data for many of the specialty coatings and 

the data tend to overstate the VOC and HAP content of the coatings, making them a reliable 

method for regulated facilities to demonstrate compliance.

The same commenter argued that the EPA had under-estimated the burden because the 

EPA had assumed that all facilities would be able to use specialty coating manufacturers' VOC 
or HAP content data to demonstrate compliance, and no facilities would have to perform 

additional compliance calculations or VOC or HAP content analyses to demonstrate compliance. 

The EPA responded that we did not estimate the compliance costs based on the other compliance 

calculations and analytical methods in the rule because the most likely compliance option for the 

vast majority of coatings used by facilities is to use the manufacturer’s documentation of VOC or 

HAP content for each coating. This approach was supported as a reasonable alternative to the 

compliance calculations in public comments submitted by the American Coatings Association. 

The EPA did not change the rule or the burden estimate as a result of this comment.

The same commenter also argued that the EPA had underestimated the burden of tracking 

specialty coating usage for demonstrating compliance, and cited examples of costs that were 

incurred demonstrating compliance with state rules for specialty coatings. The EPA responded 

that these costs were not comparable and representative of the costs that would be needed to 

demonstrate compliance with the specialty coating limits in the NESHAP because the state rules 

required daily tracking of consumption of each specialty coating. In contrast, the NESHAP will 

require only annual tracking of each specialty coating and this can be done through the use of 

purchase records. The EPA did not change the rule or the burden estimate as a result of this 

comment.

3(c) Consultations

The public was provided the opportunity to review and comment on the burden estimated 

in this Information Collection Request during the comment period for the proposed rulemaking. 

In addition, industry representatives including the Aerospace Industries Association, and several 

member companies, provided information concerning the proposed amendments to the NESHAP 

for Aerospace Manufacturing and Rework Facilities at meetings with the EPA prior to rule 

proposal, and during the public comment period. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with the 

40 CFR Part 70 permit program and the five year statute of limitations on which the permit 
program is based. The retention of records for five years allows EPA to establish the compliance 

history of a source, any pattern of non-compliance and to determine the appropriate level of

enforcement action. EPA has found that the most flagrant violators have violations extending 

beyond five years. In addition, EPA would be prevented from pursuing the violators due to the 

destruction or nonexistence of essential records.

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 (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are aerospace 

manufacturing and rework facilities. The United States Standard Industrial Classification (SIC)

code for the respondents affected by the standards and the corresponding North American 

Industry Classification System for aerospace manufacturing and rework facilities are listed 

below. 

 

40 CFR Part 63, Subpart GG SIC Codes NAICS Codes

Aircraft Manufacturing 3721 336411

Aircraft Engine and Engine Parts Manufacturing 3724 336412

Other Aircraft Part and Auxiliary Equipment 

Manufacturing

3728 336413

Guided Missiles and Space Vehicles Manufacturing 3761 336414

Guided Missile and Space Vehicle Propulsion Unit and 

Propulsion Unit Parts Manufacturing

3764 336415

Other Guided Missile and Space Vehicle Parts and 

Auxiliary Equipment Manufacturing

3769 336419

Scheduled Passenger Air Transportation 4512 481111

Scheduled Freight Air Transportation 4512 481112
Nonscheduled Chartered Passenger Air Transportation 4522 481211

Nonscheduled Chartered Freight Air Transportation 4522 481212

Other Nonscheduled Air Transportation 4522 481219

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported are required by the final

amendments to the NESHAP for Aerospace Manufacturing and Rework Facilities (40 CFR Part 

63, Subpart GG). 

A source must make the following reports:

Notifications/Reports

Notification of construction and modification

63.743(a)(2-3), 

63.753(a), 63.5(d), 

63.10(d)(5)

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

63.753(a)(2)

Notification of performance test and results

63.7(b), 63.7(g)(1), 

63.9(e), 63.10(d)(2), 

63.753(a)

Notification and report of physical and operational changes

63.5(b)(6), 

63.743(a)(2), 

63.753(a)

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

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

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

Semiannual report

63.10(e)(3), 

63.753(c)(1), 

63.753(d)(1) and 

(d)(3), 63.753(e)

Annual report 63.753(c)(2), 

63.753(d)(2)
A source must keep the following records:

Recordkeeping

Records of daily and monthly inspections

63.10(b)(2), 

63.743(a)(3), 

63.752(a)

Emission testing 63.10(b)(2), 

63.752(a)

Facility operation and maintenance including construction and 

modification

63.5(b), 

63.743(a)(2-3), 

63.752(a)

Primers/topcoats/maskants/specialty coatings: Records using compliant 

coatings without averaging

63.752(c)(1-3), 

63.752(f)(1)

Primers/topcoats/maskants/specialty coatings: Records using averaging

63.752(c)(1), 

63.752(c)(4), 

63.752(f)(2)

Primers/topcoats/maskants/specialty coatings: Records using control 

devices

63.752(c)(1), 

63.752(c)(5-6), 

63.752(d), 

63.752(f)(3), 

63.752(f)(4) 

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

63.752(a)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not widely 

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

reporting.
(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for pressure drop and liquid supply pressure for 

spray booths.

Perform initial performance test, Reference Methods 1, 1A, 2, 2A, 2C, 2D, 3, 4,18, 24, 25A, 

40, 301, or 319 tests, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 
Agency Activities

and the Integrated Compliance Information System (ICIS). 

5(b) Collection Methodology and Management

Facilities are expected to use purchase records and manufacturer’s documentation of 

HAP and VOC content, based on coating formulation, to establish compliance with the final

HAP and VOC content limit standards in the Aerospace NESHAP for specialty coatings. 

Facilities are not expected to measure the HAP or VOC content of the coatings. If a facility is 

using add-on controls to comply, performance test reports are used by the Agency to discern a 

source’s initial capability to comply with the emission standard. Data and records maintained by 

the respondents used in compliance and enforcement programs. The semiannual reports 

submitted by respondents are used for problem identification, as a check on source operation and 

maintenance, and for compliance determinations.

Information contained in the reports is entered into ICIS which is operated and 

maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this regulation.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Tables A1 to B3 of Attachment A.

6. Estimating the Burden and Cost of the Collection

Tables A1 to A3 in Attachment A present an itemized breakdown of the reporting and 

recordkeeping requirements in the first 3 years for the industry respondents subject to the final

NESHAP. Tables B1to B3 present the burden on Federal government-operated aerospace 

manufacturing and rework facilities and is included in the Agency burden discussed below. 

The individual burdens are expressed under standardized headings believed to be 

consistent with the concept of burden under the Paperwork Reduction Act. Where 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 is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to respondents in the private sector over the next three years 

from these recordkeeping and reporting requirements is estimated to be 4,475 hours (Total Labor 

Hours from Tables A1 to A3 of Attachment A). These hours are based on Agency studies and 

background documents from the development of the regulation, Agency knowledge and 

experience with the NESHAP program, the previously approved ICR, and any comments 

received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $127.72 ($60.82 + 110%) 

Technical $101.60 ($48.38 + 110%)

Clerical $38.58 ($18.37 + 110%)

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

2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace 

Product and Parts Manufacturing (NAICS code 336400). The rates have been increased by 110 

percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard(s) are labor costs. There are no capital/startup or operation and 

maintenance costs associated with the recordkeeping and reporting requirements. EPA assumed 

that the recordkeeping associated with the specialty coating operations will be accomplished with 

the existing equipment (e.g., computer systems) used for compliance for existing coating 

operations.

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

The only type of industry costs associated with the information collection activity in the 

regulations are labor costs. There are no capital/startup or operation and maintenance costs.
6(c) Estimating Agency Burden and Cost

Costs to the Agency include the costs for Federal government-owned aerospace 

manufacturing and rework facilities associated with complying with the final amendments. 

Tables B1 to B3 in Attachment A present an itemized breakdown of the reporting and 

recordkeeping requirements in the first 3 years for the Federal government-owned sources 

subject to the final NESHAP. The average annual burden to these respondents over the next three 

years from these recordkeeping and reporting requirements is estimated to be 2,439 hours and 

$198,395 (Total Labor Burden and Cost from Tables B1 to B3). 

The costs to the Agency also include those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. The average annual 

Agency cost for these activities during the three years of the ICR is estimated to be $8,740. 

Details upon which this estimate is based appear below in Tables C1 to C3 of Attachment A.

The total average annual Agency cost during the three years of the ICR is estimated to be 

$207,135. 

This ICR uses the following labor rates for the costs for Federal government-owned 

sources to comply with the final amendments: 

Managerial $89.49 ($55.93 + 60%)

Technical $86.16 ($53.85 + 60%)

Clerical $29.04 ($18.15 + 60%)

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

2013, “National Occupational Employment and Wage Estimates United States” in the Federal 

Executive Branch (NAICS code 999100).

The average hourly labor rate used for the EPA Region and States to review reports and 

compliance and enforcement is as follows:

Managerial $62.90 (GS-13, Step 5, $39.61 + 60%) 

Technical $46.67 (GS-12, Step 1, $28.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. 

Both sets of the above rates have been increased by 60 percent to account for the benefit 

packages available to government employees. 
6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately 

144 existing facilities will be subject to the standard. Thirty-six of the facilities in the United 

States are operated by the Federal government and 108 facilities are privately-owned, for-profit 

businesses. Thus, only the 108 privately-owned businesses are considered respondents to this 

ICR. Of the 144 existing sources currently covered by this standard, 109 facilities have specialty 

coating operations. The EPA estimates that the total number of potentially affected facilities with 

specialty coating operations is approximately 27 Federal government-operated facilities and 82

privately-operated facilities. This number of sources is expected to remain constant over the 

period of this ICR as no sources are expected to start-up over the next three years. This is based 

on a comprehensive ICR that was sent to all known aerospace facilities in February 2011.

While there are no additional reports that are required to be submitted by the respondents 

due to the final Amendments, additional time is need to complete the annual reports and are 

therefore considered as one additional annual response for the 82 privately-operated facilities.

The number of Total Annual Responses is 82.

The total annual labor costs are $435,176.

Details regarding these estimates may be found in Attachment Tables A1 to A3.

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 A1 to A3, B1 to B3, and C1 to C3 respectively, and summarized 

below. 

(i) Respondent Tally

The total annual labor hours for privately-owned facilities are 4,475 hours at a cost of 

$435,176. Details regarding these estimates may be found in Tables A1 to A3 of Attachment A. 

Attachment A also presents the burden on Federal government-operated facilities and is 

discussed below in section (ii). 

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

information is estimated to average 54.6 hours per response.

There are no total annual capital/startup and O&M costs to the regulated entity. The cost 

calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally
The total average annual Agency cost during the three years of the ICR is estimated to be 

$207,135. This includes the average annual Agency burden and cost over next three years for 

Federal government-operated facilities (2,439 labor hours at a cost of $198,395) and EPA 

Regions and States (148 labor hours at a cost of $8,740). See Tables B1 to B3 and C1 to C3 for 

details.

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR as it is for the final Aerospace 

Manufacturing and Rework Facilities NESHAP amendments and is considered a new burden.

6(g) Burden Statement

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

is estimated to average approximately 54.6 hours per response. This burden is estimated by 

dividing the average annual burden hours for privately-owned facilities over the three-year 

period (4,475) hours by the total number of responses during the three-year period (82). Burden 

means the total time, effort, or financial resources expended by persons to generate, maintain, 

retain, or disclose or provide information to or for a Federal agency. This includes the time 

needed to review instructions; develop, acquire, install, and utilize technology and systems for 

the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with 

any previously applicable instructions and requirements; train personnel to be able to respond to 

a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2014-0830. 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 and 

final collection of information, view public comments, access the index listing of the contents of 

the docket, and to access those documents in the public docket that are available electronically. 

When in the system, select “search,” then key in the docket ID number identified in this 

document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 
Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0830 and OMB Control Number 2060-0314 in any 

correspondence. 
Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
ATTACHMENT A

TABLES A, B, and C

Tables A1 - A3: Annual Respondent Burden and Cost of Recordkeeping and Reporting 

Requirements for Specialty Coating Operations at Privately-Operated Aerospace 

Manufacturing and Rework Facilities – Years 1-3 

Tables B1 - B3: Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements 

for Specialty Coating Operations at Federal Government-Operated Aerospace 

Manufacturing and Rework Facilities – Years 1-3 

Tables C1 - C3: Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting 

Requirements of Aerospace Specialty Coating Operations – Years 1-3 
(A) (B) (C) (D) (E) (F) (G) (H) 

Person hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Person hours per 

respondent per 

year 

Respondents 

per year a

Technical personhours per year Management 

person hours per 

year

Clerical person 

hours per year 

Total Cost Per 

Year b

(A x B) (C x D) (E x 0.05) (E x 0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d 1 1 1 82 82 4.1 8.2 $ 9,171.03

 B. Required activities 

 Initial performance tests N/A

 Repeat performance test N/A

 C. Create information See 4C

 D. Gather existing information See 4C

 E. Write report

 Notification of construction/reconstruction N/A e

 Notification of physical and operational changes N/A e

 Notification of actual startup N/A e

 Notification of change in production capacity N/A e

 Compliance status information report N/A e

 Waiver application N/A e

 Startup, shutdown, malfunction plan N/A e

 Preparation of site-specific test plan N/A e

 Notification of initial performance test N/A e

 Report of initial test N/A e

 Startup, shutdown, malfunction report N/A e

 Semiannual report – including report of periods of noncompliance N/A e

Subtotal for Reporting Requirements $ 9,171

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities d 4 1 4 82 328 16.4 32.8 $ 36,684.11

 C. Implement activities

 Compliance coating records 82 2497 124.85 249.7 $ 279,268.97

N/A e

 Control device maintenance log (inorganics) N/A e

 D. Develop record system d, f 10 1 10 82 820 41 82 $ 91,710.28

 E. Time to enter/maintain information

 Records of startup, shutdown, and malfunction N/A e

 Records of all measurements and information See 4C

 required by standard

 F. Time to train personneld, g 2 3 6 82 492 24.6 49.2 $ 55,026.17

 G. Time for auditsh 10 1 10 82 820 41 82 $ 91,710.28

Subtotal for Recordkeeping Requirements $ 554,400

TOTAL LABOR BURDEN AND COST (rounded) $ 563,571

Table A1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations 

at Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 1

5794.85

Burden item

 Control device maintenance or rolling material balance log (organics)

5700.55

94.3

See NOTE 1
a

 Assumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.

c

 We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

d

 One-time cost that is only incurred during the first year of compliance.

f

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

g

 We have assumed one person per shift will require training on recordkeeping requirements and system.

h

 We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

b

 Assumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses mean hourly wage for the following 

labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace Product and Parts Manufacturing (NAICS code 

336400): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 110 percent to account for the benefit packages available to 

those employed by private industry.

e

 We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating operations.

NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR survey responses.

(A) (B) (C) (D) (E) (F) (G) (H) 

Person hours 

per occurrence

No. of 

occurrences per 

respondent per 

year

Person hours per 

respondent per 

year 

Respondents 

per year a

Technical personhours per year Management 

person hours per 

year

Clerical 

person 

hours per 

year 

Total Cost Per 

Year b

(A x B) (C x D) (E x 0.05) (E x 0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d N/A $ -

 B. Required activities 

 Initial performance tests N/A e

 Repeat performance test N/A e

 C. Create information See 4C

 D. Gather existing information See 4C

 E. Write report

 Notification of construction/reconstruction N/A e

 Notification of physical and operational changes N/A e

 Notification of actual startup N/A e

 Notification of change in production capacity N/A e

 Compliance status information report N/A e

 Waiver application N/A e

 Startup, shutdown, malfunction plan N/A e

 Preparation of site-specific test plan N/A e

 Notification of initial performance test N/A e

 Report of initial test N/A e

 Startup, shutdown, malfunction report N/A e

 Semiannual report – including report of periods of noncompliance N/A e

Subtotal for Reporting Requirements $ -

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities d N/A $ -

 C. Implement activities

 Compliance coating records 82 2497 124.85 249.7 $ 279,268.97

N/A e

 Control device maintenance log (inorganics) N/A e

 D. Develop record system d, f N/A $ -

 E. Time to enter/maintain information

 Records of startup, shutdown, and malfunction N/A e

 Records of all measurements and information See 4C

Table A2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations 

at Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 2

Burden item

0

See NOTE 1

 Control device maintenance or rolling material balance log (organics)
 required by standard

 F. Time to train personnel d, g N/A $ -

 G. Time for auditsh 10 1 10 82 820 41 82 $ 91,710.28

Subtotal for Recordkeeping Requirements $ 370,979

TOTAL LABOR BURDEN AND COST (rounded) $ 370,979

a

 Assumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.

c

 We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

e

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

f

 We have assumed one person per shift will require training on recordkeeping requirements and system.

g

 We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

h

 One-time cost that is only incurred during the first year of compliance.

b

 Assumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses mean hourly wage 

for the following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace Product 

and Parts Manufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 110 

percent to account for the benefit packages available to those employed by private industry.

d

 We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating 

operations.

NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR 

survey responses.

3814.55

3814.55

(A) (B) (C) (D) (E) (F) (G) (H) 

Person hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Person hours per 

respondent per 

year 

Respondents 

per year a

Technical 

person- hours 

per year 

Management 

person hours per 

year

Clerical 

person 

hours per 

year 

Total Cost Per 

Year b

(A x B) (C x D) (E x 0.05) (E x 0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d N/A $ -

 B. Required activities 

 Initial performance tests N/A e

 Repeat performance test N/A e

 C. Create information See 4C

 D. Gather existing information See 4C

 E. Write report

 Notification of construction/reconstruction N/A e

 Notification of physical and operational changes N/A e

 Notification of actual startup N/A e

 Notification of change in production capacity N/A e

 Compliance status information report N/A e

 Waiver application N/A e

 Startup, shutdown, malfunction plan N/A e

 Preparation of site-specific test plan N/A e

 Notification of initial performance test N/A e

 Report of initial test N/A e

 Startup, shutdown, malfunction report N/A e

 Semiannual report – including report of periods of noncompliance N/A e

Subtotal for Reporting Requirements $ -

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities d N/A $ -

 C. Implement activities

 Compliance coating records 82 2497 124.85 249.7 $ 279,268.97

N/A e

 Control device maintenance log (inorganics) N/A e

 D. Develop record system d, f N/A $ -

 E. Time to enter/maintain information

 Records of startup, shutdown, and malfunction N/A e

 Records of all measurements and information See 4C

 required by standard

 F. Time to train personnel d, g N/A $ -

 G. Time for auditsh 10 1 10 82 820 41 82 $ 91,710.28

Subtotal for Recordkeeping Requirements $ 370,979

TOTAL LABOR BURDEN AND COST (rounded) $ 370,979

Table A3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations 

at Privately-Operated Aerospace Manufacturing and Rework Facilities - Year 3

Burden item

0

See NOTE 1

 Control device maintenance or rolling material balance log (organics)

3814.55

3814.55
a

 Assumes 82 privately-owned facilities will be subject to specialty coating provisions of the rule, and these account for 60% of specialty coatings.

c

 We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

e

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

f

 We have assumed one person per shift will require training on recordkeeping requirements and system.

g

 We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

h

 One-time cost that is only incurred during the first year of compliance.

b

 Assumes the following labor rates: $127.72 per hour for Executive, Administrative, and Managerial labor; $101.60 per hour for Technical labor, and $38.58 per hour for Clerical labor. This ICR uses mean hourly wage for the 

following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Aerospace Product and Parts 

Manufacturing (NAICS code 336400): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

d

 We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating 

operations.

NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR 

survey responses.

(A) (B) (C) (D) (E) (F) (G) (H) 

Person hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Person hours per 

respondent per 

year 

Respondents 

per year a

Technical personhours per year Management 

person hours per 

year

Clerical person 

hours per year 

Total Cost Per 

Year b

(A x B) (C x D) (E x 0.05) (E x 0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d 1 1 1 27 27 1.35 2.7 $ 2,525.54

 B. Required activities 

 Initial performance tests N/A

 Repeat performance test N/A

 C. Create information See 4C

 D. Gather existing information See 4C

 E. Write report

 Notification of construction/reconstruction N/A e

 Notification of physical and operational changes N/A e

 Notification of actual startup N/A e

 Notification of change in production capacity N/A e

 Compliance status information report N/A e

 Waiver application N/A e

 Startup, shutdown, malfunction plan N/A e

 Preparation of site-specific test plan N/A e

 Notification of initial performance test N/A e

 Report of initial test N/A e

 Startup, shutdown, malfunction report N/A e

 Semiannual report – including report of periods of noncompliance N/A e

Subtotal for Reporting Requirements $ 2,526

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities d 4 1 4 27 108 5.4 10.8 $ 10,102.15

 C. Implement activities

 Compliance coating records 27 1662 83.1 166.2 $ 155,460.82

N/A e

 Control device maintenance log (inorganics) N/A e

 D. Develop record system d, f 10 1 10 27 270 13.5 27 $ 25,255.37

 E. Time to enter/maintain information

 Records of startup, shutdown, and malfunction N/A e

 Records of all measurements and information See 4C

 required by standard

 F. Time to train personnel d, g 2 3 6 27 162 8.1 16.2 $ 15,153.22

 G. Time for auditsh 10 1 10 27 270 13.5 27 $ 25,255.37

Subtotal for Recordkeeping Requirements $ 231,227

TOTAL LABOR BURDEN AND COST (rounded) $ 233,752

Table B1. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations 

at Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 1

Burden item

31.05

See NOTE 1

 Control device maintenance or rolling material balance log (organics)

2842.8

2873.85
a

 Assumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.

c

 We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

e

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

f

 We have assumed one person per shift will require training on recordkeeping requirements and system.

g

 We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

h

 One-time cost that is only incurred during the first year of compliance.

b

 Assumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04 per hour for Clerical labor. This ICR uses mean hourly wage for the following 

labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch (NAICS code 999100): 

Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 60 percent to account for the benefit packages available to government 

employees.

d

 We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating operations.

NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR survey responses.

(A) (B) (C) (D) (E) (F) (G) (H) 

Person hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Person hours per 

respondent per 

year 

Respondents 

per year a

Technical 

person- hours 

per year 

Management 

person hours per 

year

Clerical 

person 

hours per 

year 

Total Cost Per 

Year b

(A x B) (C x D) (E x 0.05) (E x 0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d N/A $ -

 B. Required activities 

 Initial performance tests N/A e

 Repeat performance test N/A e

 C. Create information See 4C

 D. Gather existing information See 4C

 E. Write report

 Notification of construction/reconstruction N/A e

 Notification of physical and operational changes N/A e

 Notification of actual startup N/A e

 Notification of change in production capacity N/A e

 Compliance status information report N/A e

 Waiver application N/A e

 Startup, shutdown, malfunction plan N/A e

 Preparation of site-specific test plan N/A e

 Notification of initial performance test N/A e

 Report of initial test N/A e

 Startup, shutdown, malfunction report N/A e

 Semiannual report – including report of periods of noncompliance N/A e

Subtotal for Reporting Requirements $ -

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities d N/A $ -

 C. Implement activities

 Compliance coating records 27 1662 83.1 166.2 $ 155,460.82

N/A e

 Control device maintenance log (inorganics) N/A e

 D. Develop record system d, f N/A $ -

 E. Time to enter/maintain information

 Records of startup, shutdown, and malfunction N/A e

 Records of all measurements and information See 4C

 required by standard

 F. Time to train personnel d, g N/A $ -

 G. Time for auditsh 10 1 10 27 270 13.5 27 $ 25,255.37

Subtotal for Recordkeeping Requirements $ 180,716

TOTAL LABOR BURDEN AND COST (rounded) $ 180,716

Table B2. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations 

at Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 2

Burden item

0

See NOTE 1

 Control device maintenance or rolling material balance log (organics)

2221.8

2221.8
a

 Assumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.

c

 We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

e

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

f

 We have assumed one person per shift will require training on recordkeeping requirements and system.

g

 We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

h

 One-time cost that is only incurred during the first year of compliance.

b

 Assumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04 per hour for Clerical labor. This ICR uses mean hourly wage for the 

following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch (NAICS 

code 999100): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 60 percent to account for the benefit packages 

available to government employees.

d

 We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating 

operations.

NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR 

survey responses.

(A) (B) (C) (D) (E) (F) (G) (H) 

Person hours 

per occurrence

No. of 

occurrences per 

respondent per 

year

Person hours per 

respondent per 

year 

Respondents 

per year a

Technical personhours per year Management 

person hours per 

year

Clerical 

person 

hours per 

year 

Total Cost Per 

Year b

(A x B) (C x D) (E x 0.05) (E x 0.1)

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 A. Read instructions c, d N/A $ -

 B. Required activities 

 Initial performance tests N/A e

 Repeat performance test N/A e

 C. Create information See 4C

 D. Gather existing information See 4C

 E. Write report

 Notification of construction/reconstruction N/A e

 Notification of physical and operational changes N/A e

 Notification of actual startup N/A e

 Notification of change in production capacity N/A e

 Compliance status information report N/A e

 Waiver application N/A e

 Startup, shutdown, malfunction plan N/A e

 Preparation of site-specific test plan N/A e

 Notification of initial performance test N/A e

 Report of initial test N/A e

 Startup, shutdown, malfunction report N/A e

 Semiannual report – including report of periods of noncompliance N/A e

Subtotal for Reporting Requirements $ -

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities d N/A $ -

 C. Implement activities

 Compliance coating records 27 1662 83.1 166.2 $ 155,460.82

N/A e

 Control device maintenance log (inorganics) N/A e

 D. Develop record system d, f N/A $ -

 E. Time to enter/maintain information

 Records of startup, shutdown, and malfunction N/A e

 Records of all measurements and information See 4C

 required by standard

 F. Time to train personnel d, g N/A $ -

 G. Time for auditsh 10 1 10 27 270 13.5 27 $ 25,255.37

Subtotal for Recordkeeping Requirements $ 180,716

TOTAL LABOR BURDEN AND COST (rounded) $ 180,716

Table B3. Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for Specialty Coating Operations 

at Federal Government-Operated Aerospace Manufacturing and Rework Facilities - Year 3

Burden item

0

See NOTE 1

 Control device maintenance or rolling material balance log (organics)

2221.8

2221.8
a

 Assumes 27 federally-owned facilities will be subject to specialty coating provisions of the rule, and these account for 40% of specialty coatings.

c

 We have assumed that there will be no net growth for the industry, only existing sources will read instructions.

e

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

f

 We have assumed one person per shift will require training on recordkeeping requirements and system.

g

 We have assumed auditing activities will coincide with similar activities for coating operations, so would entail about half the effort assumed for the same activity in coating operations.

h

 One-time cost that is only incurred during the first year of compliance.

b

 Assumes the following labor rates: $89.49 per hour for Executive, Administrative, and Managerial labor; $86.16 per hour for Technical labor, and $29.04 per hour for Clerical labor. This ICR uses mean hourly wage for the 

following labor categories from the United States Department of Labor, Bureau of Labor Statistics, May 2013, “National Occupational Employment and Wage Estimates United States” in the Federal Executive Branch (NAICS 

code 999100): Managers, All Other for Managerial labor; Aerospace Engineers for Technical labor, and Office Clerks, General for Clerical labor. The rates have been increased by 60 percent to account for the benefit packages 

available to government employees.

d

 We have assumed that specialty coatings operations will not require installation of additional booths and control devices, and that the costs associated with these devices is covered under the compliance costs for coating 

operations.

NOTE 1 - These costs vary by facility, and are calculated assuming one hour per year per specialty coating used. A separate worksheet breaks down the assumed number of specialty coatings by facility based on 2011 ICR 

survey responses.

ICR_Costs 10272015_ERG.xlsx

Agency Burden Year 1

19 of 21 11/2/2015

46.67 62.90 25.25

(B) (C) (D) (E) (F)

EPA Tech Management Clerical EPA

Hours Hours Hours Hours Cost

Per Per Year Per Year Per Year Per Year (a, b)

Occurrence @$46.67 @$62.90 @$25.25

Burden Item (Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)

1. Applications 0

2. Read and Understand Rule Requirements c, d 1 60 3 6 $4,065

3. Required Activities

A. Observe initial performance tests

B. Observe annual performance tests

C. Excess emissions -- Enforcement Activities

D. Create Information

E. Gather Information

F. Report Reviews

1) Initial Notification d 0.5 0 0 0 $0

2) Notification of Compliance Status d 0.5 0 0 0 $0

3) Review annual and semiannual compliance report 1 109 5 11 $7,385

4. Travel expenses: 

TOTAL: 169 8 17 $11,450

Total Hours Labor Non-Labor Total

194 $11,450 $0 $11,450

a

 We have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.

Per Year

N/A

Table C1. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements

of Aerospace Specialty Coating Operations - Year 1

(A)

Number of

Occurrences

c

 Assume that each State and EPA region reviews the rule and develops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10 Regions 

= 60 occurrences.

b

 Assumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government 

employees. These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.

60

N/A

N/A

N/A

N/A

N/A

0

0

109

N/A
ICR_Costs 10272015_ERG.xlsx

Agency Burden Year 1

20 of 21 11/2/2015

47 63 25

(B) (C) (D) (E) (F)

EPA Tech Management Clerical EPA

Hours Hours Hours Hours Cost

Per Per Year Per Year Per Year Per Year (a, b)

Occurrence @$46.67 @$62.90 @$25.25

Burden Item (Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)

1. Applications 0

2. Read and Understand Rule Requirements c, d 1 0 0 0 $0

3. Required Activities

A. Observe initial performance tests

B. Observe annual performance tests

C. Excess emissions -- Enforcement Activities

D. Create Information

E. Gather Information

F. Report Reviews

1) Initial Notification d 0.5 0 0 0 $0

2) Notification of Compliance Status d 0.5 0 0 0 $0

3) Review annual and semiannual compliance report 1 109 5 11 $7,385

4. Travel expenses: 

TOTAL: 109 5 11 $7,385

Total Hours Labor Non-Labor Total

125 $7,385 $0 $7,385

a

 We have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.

d

 One-time only costs.

b

 Assumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. 

These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.

c

 Assume that each State and EPA region reviews the rule and develops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10 Regions = 

60 occurrences.

N/A

N/A

N/A

N/A

N/A

Per Year 

N/A

Table C2. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements

of Aerospace Specialty Coating Operations - Year 2

(A)

Number of

Occurrences

N/A

0

0

0

109
ICR_Costs 10272015_ERG.xlsx

Agency Burden Year 1

21 of 21 11/2/2015

47 63 25

(B) (C) (D) (E) (F)

EPA Tech Management Clerical EPA

Hours Hours Hours Hours Cost

Per Per Year Per Year Per Year Per Year (a, b)

Occurrence @$46.67 @$62.90 @$25.25

Burden Item (Tech Hours) (C=AxB) (D=Cx0.05) (E=Cx0.1)

1. Applications 0

2. Read and Understand Rule Requirements c, d 1 0 0 0 $0

3. Required Activities

A. Observe initial performance tests

B. Observe annual performance tests

C. Excess emissions -- Enforcement Activities

D. Create Information

E. Gather Information

F. Report Reviews

1) Initial Notification d 0.5 0 0 0 $0

2) Notification of Compliance Status d 0.5 0 0 0 $0

3) Review annual and semiannual compliance report 1 109 5 11 $7,385

4. Travel expenses: 

TOTAL: 109 5 11 $7,385

Total Hours Labor Non-Labor Total

125 $7,385 $0 $7,385

a

 We have assumed that the average number of respondents that will be subject to this rule will be 109. There will be no new additional sources during the next three years of this ICR.

d

 One-time only costs.

b

 Assumes the following labor rates: $62.90 per hour for Management labor; $46.67 per hour for Technical labor, and $25.25 per hour for Clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. 

These rates can be obtained from the OPM web site, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2014/general-schedule/.

c

 Assume that each State and EPA region reviews the rule and develops a plan for reviewing notifications and reports. 1 occurrence per State * 50 States + 1 occurence per EPA Region * 10 Regions = 

60 occurrences.

0

N/A

N/A

N/A

N/A

Table C3. Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements

of Aerospace Specialty Coating Operations - Year 3

(A)

Number of

Occurrences

Per Year 

109

N/A

N/A

N/A

0

0