**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH)**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) ( Renewal), EPA ICR Number 2268.04, OMB Control Number 2060

- 0607

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the regulations published at 40 CFR P art 63, S ubpart HHHHHH were proposed on September, 9, 2007, and promulgated on January 9, 2008

. These regulations are part of the EPA Integrated Urban Strategy

to reduce cancer risk from area sources under S ection 112(k)(3)(C) of the Clean Air Act (CAA). The standard applies to existing and new sources that conduct paint stripping operations using methyl ene chloride (MeCl)

- containing paint strippers, motor vehicle and mobile equipment surface coating operations, and miscellaneous surface coating operations located at area sources. This information is being collected to assure compliance with 40 CFR Part 6 3 , S ubpart HHHHHH. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All repor ts 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. Over the next three ye ars, an average o f 39,812 respondents per ye ar will be subject to the standard. It is estimated that an average of 1,593 new commercially

- owned motor vehicle and mobile equipment refinishing sources and 25 new miscellaneous surface coating sources will startup each ye ar over the next three years to replace existing sources that terminate operations. The Office of Management and Budget ( OMB ) approved the currentl y active ICR without any “ Terms of Clearance. ”2

The “Affected Public” are owners or operators of paint stripping and miscellaneous surface coating operations at area sources
. The burden to the “Affected Public” may be found in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)

. The burden to the “Federal Government” is attributed entirel y to work performed b y federal emplo ye es or government contractors , and may be found in Table 2: Average Annual EPA Burden and Cos t

– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)

. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall re quire the maximum degree of emission reduction. Inaddition, S ection 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y require. In the Administrator's judgment , hazardous air pollutants (HAPs) from paint stripping and miscellaneous surface coating operations at area sources 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 P art 63 , S ubpart HHHHHH. **2(b) Practical Utility/Users of the Data**
In order to minimize HAP emissions from paint stripping, motor vehicle and mobile equipment refinishing operations, and miscellaneous surface coating, facilities must comply with certain equipment requirements and management practices. The information generated by the recordkeeping and reporting requirements described in this ICR will be used by EPA to ensure that personnel who spray coatings are certified in the proper selection, mixing, and application of coatings. Additionally, the information will ensure that filters and spray guns at spray

booths of3

affected facilities meet the minimum efficiency requirements. Further, this information will help EPA to maintain an updated inventory of all sources with paint stripping or surface coating operations. Adequate recordkeeping and reporting are necessary to ensure compliance with the standards, as required b y the CAA. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court. To minimize the burden, much of the information which is kept on site could be reviewed b y enforcement personnel during an inspection and would not need to be routinel y reported to the agency

. **3. Nonduplication, Consul tations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR P art 6 3 , S ubpart HHHHHH

. **3(a) Nonduplication** If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists. During the deve lopment of S ubpart HHHHHH, three different source categories were combined to be regulated under a single S ubpart. Subpart HHHHHH now includes sources that perform surface coating on both motor vehicles/mobile equipment, metal or plastic parts, or paint s tripping. This consolidation removed any duplicate rule requirements

. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this ICR was published in the Federal Register ( 78 FR 35023) on June 11, 2013. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compli ance data.4

Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply . In developing this ICR, EPA contacted the American Coatings Association at (202) 462

- 6272, the American Composites Manufacturers Association (ACMA) at (703) 525

- 0511, and the Society for Protective Coatings (877) 281

- 7772 . EPA did not receive comments. It i s our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. **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 b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
These rep orting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, S ection 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 ye ar records retention re quirement is consistent the Part 70 permit program and the five ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allow s EPA to establish the compliance history of a source , any pattern of non - compli ance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonex istence 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, c hapter 1, p art 2, subpart B

- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

**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 owners or op erators of paint stripping and miscellaneous surface coating operations at area sources

. The United States Standard Industrial Classification (SIC ) codes and corresponding North American Industry Classification System (NAICS ) codes are presented in the fo llowing table.
**Standard ( 40 CFR Part 63,**  **Subpart HHHHHH )**  **SIC Codes NAICS Codes** 
Paint Stripping Natural Gas Liquid Extraction 1321 211112 Spices and Extracts 2082 311942 Mobile Homes 2451 321991 Basic Chemical Manufacturing 2813 2816 2819 2865 2869 325110

325120 325131 325188 325192 325193 325199 Plastics Material Sy

nthetic Resins, and Nonvulcanizable Elastomers 2821 325211 Paint and Coating Manufacturing 2851 325510 Miscellaneous Chemical Production and Preparation 2819 325998
Alumina Refining 2819 331311 All Other Plastics Products 3089 326199 All Other Miscellaneous Manufacturing 2499 3399996

**Standard ( 40 CFR Part 63,**  **Subpart HHHHHH )**  **SIC Codes NAICS Codes** 
Waste Treatment and Disposal 4953 562211 562212 562213 562219 Materials Recovery 4953 562920 Reupholstery

and Furniture Repair 4581 811420 Miscellaneous Surface Coating Aerospace Equipment 3728 3761 3764 336413

336414 336415 54171 Automobile Parts 3292 3429 3465 3621 3711 3714 335312

336111 336211 336312 336320 336330 336340 336370 336399 Extruded Aluminum 3354 3365 3442 3446 331316

331524 332321 332323 Heavy Equipment 3511 3531 333120

3336117

**Standard ( 40 CFR Part 63,**  **Subpart HHHHHH )**  **SIC Codes NAICS Codes** 
Job Shops 2499 3399 3429 3562 3577 3728 332722

332813 332991 334119 336413 339999 Large Trucks and Buses 3711 336120 336211 Metal Buildings 3448 332311 Metal Containers 2655 3325 3443 322214

331513 332420 811310 Metal Pipe and Foundry 3312 3317 3321 3325 331111

331210 331221 331511 331513 Rail Transportation 3531 3731 4011 336510

336611 482111 Recreational Vehicles 3354 3429 3711 3716 3751 3792 331316

336112 336211 336213 336214 336399 3369 3369918

**Standard ( 40 CFR Part 63,**  **Subpart HHHHHH )**  **SIC Codes NAICS Codes** 

Rubber

- to

- Metal Products 3061 3069 326291

326299 Structural Steel 3441 3448 332311

332312 Other 3715 336212 Transportation Equipment 3292 3716 3792 3799 336213

336214 336350 336999 56121 56211 8111 Other industrial and commercial 2522 337214 Miscellaneous Plastic Parts 3086 3089 326140

326150 326199 Office Equipment 3578 333313 Electronics 3663 334220 Medical Equipment 2599 3829 339111

339112 Sporting Equipment 3069 339920 Signs 3993 339950 Marine Equipment 3732 4493 336612

7139309

**Standard ( 40 CFR Part 63,**  **Subpart HHHHHH )**  **SIC Codes NAICS Codes** 
Motor Vehicle and Mobile Equipment Refinishing Commercial 5511 5521 7532 441110

441120 811121 Government Not applicable Not applicable **4(b) Information Requeste d**  **(i) Data Items**
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Paint Stripping and Miscellaneous Surface C oating at Area Sources (40 CFR P art 63, S ubpart HHHHHH)

. A source must make the following reports:

**Notification s**  Initial notification letter 63.11175(a) Notification of compliance status 63.11175(b) Annual notification of changes reports a 63.11176(a)

a This notification i s not required of paint stripping facilities using one ton or less of methylene chloride per year. A source must keep the following records:
**Recordkeeping** Painter certification 63.11177(a) Filter efficiency a 63.11177(b) Spray gun efficiency b 63.11177(c) Notifications and annual reports c 63.11177(d) Annual usage of methylene chloride in paint strippers d 63.11177(e)10 **Recordkeeping** Current methylene chloride minimization 63.11177(f) Deviations from compliance 63.11177(g) Source compliance assessments performed in support of the initial notification, notification of compliance status, or annual notification of changes report 63.11177(h)

a These records are required only 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 recordkeeping (i.e., maintaining a file of the filter efficiency, as reported by the manuf acturer). b These records only are required of sources that do not use high

- volume, low

-pressure (HVLP) spray guns, electrostatic applications, airless spray guns, or air assisted airless spray guns, and that instead opt to conduct testing to verify a tran sfer efficiency equivalency to that of an HVLP spray gun

. c Records of notifications of changes to reports are not required of paint stripping facilities using one ton or less of methylene chloride per year. d These records only are required of sources with paint stripping operations that have an annual usage of more than one to n of methylene chloride. 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 recordke eping at a plant site. Also, regulatory

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

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

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Plan and implement required activities. Create initial notification letter, notification of compliance status, and annual compliance report. Enter information required to be recorded above , including painter certification, filter efficiency, spray

gun, and deviation from the rule requirements and corrective actions taken

.11 **Respondent Activities** Train personnel to be able to respond to a collection of information. Audit the information. Transmit or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this 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 initial notification letters, notifications of compliance status, and annual compliance reports

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information System (OTI S). **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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Of

fice of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars.12

**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 likel y to be affected b y this rule, the reporting requirements for the individual facilities are minimal. There are no quarterly or semiannual requirements as there are with most regulated large industries. The burden is further minimized since costly

monitoring equipment or performance tests are not required . For this ICR, it is estimated that of the existing sources, 93.5 percent (37,22 4 sources ) are estimated to be small businesses. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown in below Table 1 : Annual Respondent Burden and Cost

– NESHAP for Paint Stripping and Miscellane ous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consi stent 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 industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 125,171 ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with th e 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 $127.43 ( $60.68 + 110%) Technical $99.16 ( $47.22 + 110%)13 Clerical $50.88 ( $24.23 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 11 0 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs , which are addressed elsewhere in this ICR , and annual operation and maintenance (O&M) costs associated with photocopying and postage. There are no capital/startup costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**  Sources will incur O&M costs for photocop ying and mailing notifications and reports. The burden estimate for this IC R includes a one - time cos t of one dollar for mailing and photocopying each initial notification and notification o f compliance and three dollars for mailing and photocop ying each annual report.

**Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Burden Item (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) Miscellaneous Surface Coating Initial Notification Letter $0 25 $0 $1 25 $ 25

Notification of Com pliance Status $0 25 $0 $1 25 $ 25
Annual Compliance Report $0 25 $0 $3 831 $ 2,493

Subtotal $ 2,543 Commercial Motor Vehicle and Mobile Equipment Refinishing Initial Notification Letter $0 1,593 $0 $1 1,593 $1,593

Notification of Com pliance Status $0 1,593 $0 $1 1,593 $1,59314 **Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Burden Item (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) Annual Compliance Report $0 1,593 $0 $3 35,731 $107,193

Subtotal $110,379 Government Motor Vehicle and Mobile Equipment Refinishing Annual Compliance Report $0 0 $0 $3 250 $750

Subtotal $750 Paint Stripping Annual Compliance Report $0 0 $0 $3 1,050 $3,150

Subtotal $3,150
**TOTAL $11**  **6,822**
There are no capital/startup costs associated with this ICR

. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this ICR are $116,822

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the IC R is estimated to be $116,822

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall 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 during the three years of the ICR is estimated to be $ 1,064,942

.15

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

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

. 21 (GS

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

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 2013 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
. Details upon which this estimate is based appear below in Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal ). **6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this ICR, on average over the next three ye ars, approximately 39,812 existing respondents will be subject to the standard. This number is expected to remain constant over the period of this ICR. It is estimated that an additional 1,618 respondents per ye ar will startup each ye ar over the next three ye ars to replace existing sources which may terminate operations

. No new state or local government

- owned mobile equipment refinishing shops are expected to startup during this ICR period. The overall average number of respondent s, as shown in the table below, is 39,812 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents 1** 

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

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

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are No Longer Subject (E)

Number of Respondents (E=A+B+C

- D)

Miscellaneous Surface Coating
1 25 831 0 25 831
2 25 831 0 25 831
3 25 831 0 25 83116 **Number of Respondents 1**  Respondents That Submit Reports Respondents That Do Not Submit Any Reports

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

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are No Longer Subject (E)

Number of Respondents (E=A+B+C

- D)

Commercial Motor Vehicle and Mobile Equipment Refinishing
1 1,593 35,731 0 1,593 35,731
2 1,593 35,731 0 1,593 35,731
3 1,593 35,731 0 1,593 35,731 Government Motor Vehicle and Mobile Equipment Refinishing
1 0 250 0 0 250
2 0 250 0 0 250
3 0 250 0 0 250 Paint Stripping
1 0 1,050 1,950 0 3,000
2 0 1,050 1,950 0 3,000
3 0 1,050 1,950 0 3,000 **Average 1,618**  **3 7,862**  **1,95 0**  **1,618 39,812**  1 This ICR assumes a total of 3 9,812 commercial facilities exist in any given year, and that 1,618 new sources per year will be constructed. This ICR also assumes that existing sources will shut down at a rate equal to that replaced by new sources. Therefore, the total number of affected s ources subject to this rule (i.e., 39,812 sources) will not change in any given year

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 39,812

.17

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

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Miscellaneous Surface Coating Initial notification letter 25 1 0 25 Notification of compliance status 25 1 0 25 Annual compliance report 831 1 0 831 Subtotal 881 Commercial Motor Vehicle and Mobile Equipment Refinishing Initial notification letter 1,593 1 0 1,593 Notification of compliance status 1,593 1 0 1,593 Annual compliance report 35,731 1 0 35,731 Subtotal 38,917 Government Motor Vehicle and Mobile Equipment Refinishing Initial notification letter 0 1 0 0 Notification of compliance status 0 1 0 0 Annual compliance report 250 1 0 250 Subtotal 250 Paint Stripping Initial notification letter 0 1 0 0 Notification of compliance status 0 1 0 0 Annual compliance report 1,050 1 1,950 3,000 Subtotal 3,000 **TOTAL 43,048**  The number of Total Annual Responses is 43,048. Th e total annual labor costs are $12,040,308

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

– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)

.18

**6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 (below) , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 125,171

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

– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is e stimated to average 3 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $116,822

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally**  The average annual Agency burden and cost over next three years is estimated to be 23,631 labor hours at a cost of $ 1,064,942 . See Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)

. **6(f) Reasons for Change in Burden** There is an apparent increase in the total estimated respondent cost burden as currently identified in the OMB Inventory of Approved Burdens. The increase is not due to any program changes. It primarily

is attributed to corrections to the previous renewal’s burden calculation s, which omitted technical and managerial labor burdens associated with painter certification recordkeeping activities conducted by commerci al miscellaneous surface coating operations at area sources , as presented in Table 1 a
. This omission was inconsistent with the approach used throughout the remainder of the previous renewal and is inconsistent with the approach typicall y used by the Agency to calculate the respondent labor burden. Also, this renewal uses updated labor rates, which further contributed to the apparent increase in the respondent burden cost. This ICR references labor rates from the Bureau of Labor Statistic s to calculate the respondent cost burden. There is a decrease in the total O&M cost as compared to the previous renewal

. This change also is not due to any program changes , and is attributed directly to corrections made to the previous renewal’s calculations . The previous renewal overestimated the number of initial report and notification that are required for new sources

. This renewal revise s the calculations19

which resulted in the observed decrease in the total O&M cost. **6(g) Burden Statemen t**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 3 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

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

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR P art 9 and 48 CFR C hapter 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

- 2013

- 0354. An electronic version of the public docket is available at http://www.regulations.gov , which may be used to obtain a copy

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

. When in the 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 i s (202) 566

- 1927

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

- HQ

- OECA

- 2013

- 0354 and OMB Control Number 2060

- 0607 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were us ed in collecting this information.20

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

**– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area**  **Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)**

**Sector Commercial**  **Misc. Surface Coating**  **Government**

**Misc. Surface Coating**  **Paint Stripping Total**  Burden Hours 120,959 589 3,623 125,171 Labor Cost $11,635,164 $56,692 $348,451 $12,040,308

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

**– Commercial Miscellaneous Surface Coating Operations at Area Sources** 

**Burden Item A**  **B C**  **D E**  **F G**  **H**

**Technical person**  **- hours**  **per occurrence No. of** 

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

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

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

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

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

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

**per year ($)**  **b** 1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions 5 1 5 1,618 8,090 404.5 809 894,911.76 B. Required activities N/A C. Create information 1. Initial notification letter 1 1 1 1,618 1,618 80.9 161.8 178,982.35 2. Notification of c om

pliance status 2 1 2 1,618 3,236 161.8 323.6 357,964.7 3. Annual compliance report 2 1 2 36,562 73,124 3,656.2 7,312.4 8,088,940.32 **Subtotal for Reporting**  **Requirements 98,978**  **9,520,799** 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities N/A C. Implement activities N/A21

**Burden Item A**  **B C**  **D E**  **F G**  **H**

**Technical person**  **- hours**  **per occurrence No. of** 

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

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

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

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

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

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

**per year ($)**  **b** D. Develop record system 8 1 8 1,618 12,944 647.2 1,294.4 1,431,858.81 E. Time to record information 1. Records of painter certification 0.25 2.4 0.6 7,156 4,293.6 214.68 429.36 474,955.89 2. Records of filter efficiency 0.25 1 0.25 357 89.25 4.46 8.93 9,872.79 3. Records of spray gun 1.5 1 1.5 0 0 0 0 0 4. Records of deviation from rule requirements and corrective actions taken 1 1 1 1,787 1,787 89.35 178.7 197,677.05 F. Time to train personnel N/A G. Time for audits N/A **Subtotal for Recordkeeping**  **Requirements 21,981**  **2,114,365 TOTAL ANNUAL**  **BURDEN AND COST (ROUNDED) 120,959**  **11,635,164**
**Assu mptions:**  a. This ICR assumes a total of 36,562 commercial facilities exist in any given year, and that 1,618 new sources per year will be cons tructed. These commercial facilities comprise both the miscellaneous surface coating and commercial motor vehicle and mobile equipment refinishing categories. This ICR also assumes that existing sources will shut dow n at a rate equal to that replaced by new sources. Therefore, the total number of affecte d sources subject to this rule (i.e., 41,430 sources) will not change in any given year. b. This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013, “Table 2. Civilian wo rkers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those em ployed by private industry.22

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

**– Government** 
**- owned Miscellaneous Surface Coating Operations at Area**  **Sources**

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

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

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

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

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

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

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

**per year ($)**  **b** 1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions 5 1 5 0 0 0 0 0 B. Required activities N/A C. Create information 1. Initial notification letter 1 1 1 0 0 0 0 0 2. Notification of compliance status 2 1 2 0 0 0 0 0 3. Annual compliance report 2 1 2 250 500 25 50 55,309.75 **Subtotal for Reporting**  **Requirements 575**  **55,310** 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities N/A C. Implement activities N/A D. Develop record system 8 1 8 0 0 0 0 0 E. Time to record information 1. Records of painter certification 0.25 2.4 0.6 0 0 0 0 0 2. Records of filter efficiency 0.25 1 0.25 0 0 0 0 0 3. Records of spray gun 1.5 1 1.5 0 0 0 0 0 4. Records of deviation from rule requirements and corrective actions taken 1 1 1 12.5 12.5 0.63 1.25 1,382.7423

F. Time to train personnel N/A G. Time for audits N/A **Subtotal for Recordkeeping**  **Requirements 14**  **1,383 TOTAL ANNUAL BURDEN AND COST (ROUNDED)**  **589 56,692** 
**Assu mptions:**  a. EPA estimates a total of 250 existing, government

- owned paint shops by assuming one shop per county for counties with a population greater than 240,000. This ICR assumes no new, government

- owned paint shops will open over the three

- year ICR period. b. This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those em ployed by private industry.24 **Table 1 c**  **: Annual Respondent Burden and Cost**

**– Paint Stripping Operations at Area Sources** 

**Burden Item A**  **B C**  **D E**  **F G**  **H**

**Technical person**  **- hours**  **per occurrence No. of** 

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

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

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

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

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

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

**per year ($)**  **b** 1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions 2 0 0 0 0 0 0 0 B. P rocess/Review information 2 0 0 0 0 0 0 0 C. Create information 1. Initial notification letter 1 0 0 0 0 0 0 0 2. Notification of compliance status 1 0 0 0 0 0 0 0 3. Annual compliance report 1 1 1 1,050 1,050 52.5 105 116,150.48 **Subtotal for Reporting**  **Requirements 1,208**  **116,150** 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities 8 0 0 0 0 0 0 0 C. Implement activities 1. Train personnel 8 0 0 0 0 0 0 0 2. Update plan 2 1 2 1,050 2,100 105 210 232,300.95 D. Time to record information 1 0 0 1,050 0 0 0 0 **Subtotal for Recordkeeping**  **Requirements 2,415**  **232,301 TOTAL ANNUAL BURDEN AND COST (ROUNDED)**  **3,623 348,451** 
**Assu mptions:**  a. This ICR assumes a total of 3,000 paint stripping facilities exist in any given year. EPA estimates 1,050 of these facilitie s will use more than 150 gallons per25

year of paint strippers containing methylene chloride. These facilities are required to develop a w ritten plan and to submit notification of compliance status and annual compliance reports. b. This ICR uses the following labor rates: $99.16 for technical, $127.43 for managerial, and $50.88 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2013, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those em ployed by private industry.26

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

**– NESHAP for Paint Stripping and Miscellaneous Surface Coating at Area**  **Sources (40 CFR Part 63, Subpart HHHHHH) (Renewal)**

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

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

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

**per year Technical** 

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

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

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

**per year ($)**  **a** Applications N/A Required activities N/A Create information N/A Gather information N/A Report reviews N/A Initial notification letter 0.5 1 0.5 1,618 809 40.45 80.9 41,926.02 Notification of compliance status 0.5 1 0.5 1,618 809 40.45 80.9 41,926.02 Annual compliance report 0.5 1 0.5 37,862 18,931 946.55 1,893.1 981,089.61 **TOTAL ANNUAL BURDEN AND COST (ROUNDED) 23,631**  **1,064,942**
**Assu mptions:**  a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2013 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.