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 Part 63, Subpart 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 Section 112(k)(3)(C) of the Clean 

Air Act (CAA). The standard applies to existing and new sources that conduct paint stripping 

operations using methylene 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 63, 

Subpart 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 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.

Over the next three years, an average of 39,812 respondents per year 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 year over the next three years to replace existing sources that terminate operations.

The Office of Management and Budget (OMB) approved the currently 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 entirely to work performed by federal employees or 

government contractors, and may be found 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). 

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, 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 Part 63, Subpart 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 of 
3

affected facilities meet the minimum efficiency requirements. Further, this information will help 

EPA to maintain an updated inventory of all sources with paint stripping or surface coating 

operations. 

Adequate recordkeeping and reporting are necessary to ensure compliance with the 

standards, as required by the CAA. The information collected from recordkeeping and reporting 

requirements is also used for targeting inspections, and is of sufficient quality to be used as 

evidence in court. To minimize the burden, much of the information which is kept on site could 

be reviewed by enforcement personnel during an inspection and would not need to be routinely 

reported to the agency.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart 

HHHHHH.

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.

During the development of Subpart HHHHHH, three different source categories were 

combined to be regulated under a single Subpart. Subpart HHHHHH now includes sources that 

perform surface coating on both motor vehicles/mobile equipment, metal or plastic parts, or paint 

stripping. 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 by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. 
4

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is 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 is 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 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 the 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).
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 operators 

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 following 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 Synthetic 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 339999
6

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

333611
7

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

336991
8

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

713930
9

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 Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Paint 

Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63, Subpart 

HHHHHH).

A source must make the following reports:

Notifications

Initial notification letter 63.11175(a)

Notification of compliance status 63.11175(b)

Annual notification of changes reports a63.11176(a)

a This notification is 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 a63.11177(b)

Spray gun efficiency b63.11177(c)

Notifications and annual reports c63.11177(d)

Annual usage of methylene chloride in paint strippers d63.11177(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 

manufacturer).

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 transfer 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 ton 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 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.

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 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 initial notification letters, notifications of compliance status, and annual compliance 

reports.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

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.

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

maintained by EPA's Office 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 OTIS 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.
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 likely to be affected by this rule, the reporting 

requirements for the individual facilities are minimal. There are no quarterly or semiannual 

requirements as there are with most regulated large industries. The burden is further minimized 

since costly monitoring equipment or performance tests are not required. For this ICR, it is 

estimated that of the existing sources, 93.5 percent (37,224 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 Miscellaneous 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 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 industry over the next three years from these recordkeeping 

and reporting requirements 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 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 $127.43 ($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 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 type 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 photocopying and mailing notifications and reports. 

The burden estimate for this ICR includes a one-time cost of one dollar for mailing and 

photocopying each initial notification and notification of compliance and three dollars for 

mailing and photocopying 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 

Compliance 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 

Compliance Status

$0 1,593 $0 $1 1,593 $1,593
14

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 $116,822

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 years of the ICR 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 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 during the three years of the ICR is estimated to be 

$1,064,942.
15

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (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 years, 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 year 

will startup each year over the next three years 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 respondents, 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 

years covered by this ICR. 

Number of Respondents1

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

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 25 831
16

Number of Respondents1

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

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 37,862 1,950 1,618 39,812

1

This ICR assumes a total of 39,812 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 sources subject to this rule (i.e., 39,812 sources) will not 

change in any given year.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 39,812. 
17

The total number of annual responses per year 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.

The 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), respectively, 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 estimated 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 calculations, 

which omitted technical and managerial labor burdens associated with painter certification 

recordkeeping activities conducted by commercial miscellaneous surface coating operations at 

area sources, as presented in Table 1a. This omission was inconsistent with the approach used 

throughout the remainder of the previous renewal and is inconsistent with the approach typically 

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 Statistics 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 revises the calculations 
19

which resulted in the observed decrease in the total O&M cost.

6(g) Burden Statement

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 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-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 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-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 used 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)

Management 

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 compliance 

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/A
21

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)

Management 

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

Assumptions:

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 constructed. 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 down at a rate equal to that replaced by new sources. Therefore, the total number of affected 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 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 employed by private industry.
22

Table 1b: 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)

Management 

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 1,382.74
23

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

Assumptions:

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 employed by private industry.
24

Table 1c: 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)

Management 

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. Process/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

Assumptions:

a. This ICR assumes a total of 3,000 paint stripping facilities exist in any given year. EPA estimates 1,050 of these facilities will use more than 150 gallons per 
25

year of paint strippers containing methylene chloride. These facilities are required to develop a written 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 employed 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)

Management 

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

Assumptions:

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.