SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) 

(Renewal), EPA ICR Number 2115.04, OMB Control Number 2060-0535

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants for Miscellaneous 

Coating Manufacturing were proposed on April 4, 2002, and promulgated on December 11, 

2003. Following several proposed amendments, a final rule was promulgated on October 4, 

2006. These regulations apply to existing facilities and new facilities that manufacture a 

miscellaneous coating and are either located at, or are part of, major sources of hazardous air 

pollutant (HAP) emissions. An affected source that commenced construction or reconstruction 

after April 4, 2002, is considered to be an affected source. “Major source” means that the 

process equipment used to manufacture the miscellaneous coatings and any other operations or 

equipment at the facility emit, or have the potential to emit, 10 tons per year or more of a single 

HAP or 25 tons per year or more of any combination of HAPs. A facility is subject to the 

NESHAP if it meets the following criteria:

 Manufactures coatings, including inks, paints, or adhesives described by Standard 

Industrial Classification (SIC) codes 285, or 289, or North American Industrial 

Classification System (NAICS) codes 3255, or 3259;

 Processes, uses, or produces HAP;

 Not part of an affected source under another subpart of 40 CFR part 63.

New facilities include those that commenced construction or reconstruction after the date 

of proposal. This information is being collected to assure compliance with 40 CFR part 63, 

subpart HHHHH.

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, 
2

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 U. S.

Environmental Protection Agency (EPA) regional office.

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

affected facilities at each plant site, and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 135 respondents per year will be subject to the 

standard, and one additional respondent per year will become subject to the standard. 

The active (previous) ICR had the following Terms of Clearance (TOC):

When this ICR is renewed, EPA should review the respondent burden,

universe, labor rates, and capital costs and ensure these estimates 

have been updated.

EPA has addressed each item of concern in the TOC by consulting with 

industry representatives to review and update the respondent universe and burden 

estimates. Costs were updated as described in Section 6 of this supporting statement.

The respondents to this ICR (the “Affected Public) are publicly owned and operated 

miscellaneous coating manufacturing plants. None of the facilities are owned by either state, 

local and tribal agencies or the Federal government. The “burden” to respondents is calculated 

below in Table 1: Annual Respondent Burden and Cost − NESHAP for Miscellaneous Coating 

Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal). The burden to the “Federal 

Government” is attributed entirely to work performed by either Federal employees or 

government contractors. This burden is calculated below in Table 2: Average Annual EPA

Burden and Cost − NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, 

Subpart HHHHH) (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 
3

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 miscellaneous coating 

manufacturers cause, or contribute to air pollution that may reasonably be anticipated to 

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

source category at 40 CFR part 63, subpart HHHHH.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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 standards. Continuous emission monitors are used 

to ensure compliance with the standards at all times.

The notifications required in the standards are used to inform the Agency, or delegated 

authority when a source becomes subject to the requirements of the standard. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated and the standard is being met. The performance test also may 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. Non-duplication, Consultations, and Other Collection Criteria

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

HHHHH.

3(a) Non-duplication

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, 

duplication does not exist.
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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 (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. 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 EPA’s Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of all compliance data. We estimate that there are 135 existing 

respondents subject to the reporting requirements of this standard, and that one new source 

will become subject to the standard over the three-year period covered by this ICR.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standards as they were being developed and these

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, the Agency contacted: 1) the American Coatings 

Association (ACA), at (202) 462-8731; and 2) the Adhesive and Sealant Council (ASC), at (301) 

986-9700. EPA did not receive any comments from these consultations. 

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. In this 

case, no comments were received.

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 and 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 
5

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 (CBI) (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 and 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 miscellaneous 

coating manufacturing plants. The United States Standard Industrial Classification (SIC) codes 

for the respondents affected by the standards, and their corresponding North American Industry

Classification System (NAICS) codes, are listed below for the source category.

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

Paint, Coating, and Adhesive Manufacturing 285 3255

Other Chemical Product and Preparation Manufacturing 289 3259

4(b) Information Requested

(i) Data Items

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

Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH).

A source must make the following reports:

Notifications

Notification and application of construction or 

reconstruction

63.9(b)(1)-(3), 63.8070(a)
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Notifications

Notification of anticipated date of initial startup 63.9(b)(4), 63.8070(b)(2)

Notification to commence construction 63.5180(b)(2), 63.9(b)(4)

Notification of actual startup 63.5180(b)(2), 63.9(b)(4)

Notification of intent to construct/reconstruct 63.5180(b)(2), 63.9(b)(4)-(5)

Notification of opacity or visible emission observations 63.8070(a), 63.6(h)(4)

Notification of performance test, test plan, and emission 

profile

63.7(b)-(c), 63.9(e), 63.8070(a),(d)

Notification of CMS performance evaluation 63.8(e)(2), 63.9(g)

Notification of compliance status (including 

performance test results)

63.9(h), 63.10(d)(2), 63.8070(e)

Notification of process change 63.8070(f)

Emissions averaging plan 63.1250-63.1260, 63.8060

Reports

Pre-compliance report 63.8075(c)

Semiannual compliance report

$ Startup, shutdown, and malfunction reports

$ Deviations/no deviations/out-of-control CMS

$ No out-of-control CMS

$ Heat exchange system reports (delay of repair)

$ Maintenance and inspection reports for storage tank 

control devices

$ Operating scenario reports

$ Equipment leak reports

$ Emissions averaging reports

63.10(e)(3) and 63.8075(b),(d)

63.10(d)(5) and 63.8075(d)(4)

63.8075(d)(5)

63.8(c)(7), 63.8075(d)(6)

63.104(e), (f)(2)(i)-(iv), 

63.8075(d)(7)

63.1063(c)(2)(iv)(B) or (e)(2), 

63.8075(d)(8)

63.8075(d)(9)

63.1039(b)(1)-(8) and 

63.8075(d)(10)

63.1250-63.1260, 63.8060

A source must keep the following records:

Recordkeeping 

Record retention 63.10(b)(1), 63.8085

Documentation supporting initial notifications and 

notifications of compliance status

63.10(b)(2)(xiv), 63.8080(a)(1)

Startup, shutdown, and malfunction plan 63.6(e)(3)

Records related to startup, shutdown, and malfunction 63.6(e)(3)(iii)-(iv), 63.8080(a)(2)

Records of performance tests and CMS performance 

evaluations

63.10(b)(2)(viii), 63.8080(a)(3)

Records for equipment leaks 63.1038(b)-(c), 63.8080(a)(4)
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Recordkeeping 

Daily schedule or log of each operating scenario 63.8080(a)(5)

Records for process vessels complying with percent 

reduction emission limitation

63.8080(a)(6)

Planned routine maintenance records for storage tank 

control devices

63.8080(a)(7)

Maintenance wastewater plan 63.8080(a)(8)

Records for safety device openings 63.8080(a)(9)

Results of each CMS calibration, validation check, and 

inspection

63.8035(c)(6)-(8), (d)(4)-(5), 

(e)(4)-(7), (f)(3)-(4), 

63.8080(a)(10)

Records for emissions averaging 63.1250-63.1260, 63.8060

Records for each CMS 3.8(d)(3), 63.8(f)(6)(i), 

63.10(b)(2)(vi)-(xi), 63.8080(b)

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 20 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate opacity and/or parameter monitors.

Perform initial performance test 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.
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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 Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following the notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

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 are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports 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 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 
9

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost − NESHAP for Miscellaneous 

Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table1 below 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 171,406 hours (Total Labor Hours from Table 1

below). 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 $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)
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Clerical $50.51 ($24.05 + 110%)

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

2012, “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 the costs 

associated with continuous monitoring. The capital/startup costs are one time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitors and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring

(B)

Capital

Startup 

Cost

(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)

Process Vessels $30,000 1 $30,000 $16,000 135 $2,160,000

Transfer 

Operations N/A N/A N/A $3,100 135 $418,500

Wastewater 

Systems N/A N/A N/A $2,000 135 $270,000

Totals $30,000 $2,848,500

The total capital/startup costs for this ICR are $30,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $2,848,500. 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 $2,878,500 per year.

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

$38,038.

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), 2012 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 Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (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

135 existing respondents will be subject to the standard. It is estimated that one additional 

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below, is 135 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR.

Number of Respondents

Year

(A)

Number of New 

Respondents 1

(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 Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 133 0 0 134

2 1 134 0 0 135

3 1 135 0 0 136

Average 1 135 0 0 135

1

New respondent include sources with constructed, reconstructed, and modified affected facilities.

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 135.

The total number of annual responses per year is calculated using the following table:
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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

Notification of construction/reconstruction 1 1 N/A 1

Notification of anticipated startup 1 1 N/A 1

Notification of actual startup 1 1 N/A 1

Notification of applicability of standard 1 1 N/A 1

Emission averaging plan 1 0 N/A 0

Pre-compliance report 1 1 N/A 1

Notification of initial performance test 1 0 N/A 0

Notification of initial CMS performance 

evaluation 1 0 N/A 0

Notification of compliance status 1 1 N/A 1

Notification of process change 14 1 N/A 14

Semiannual report 135 2 N/A 270

Startup, shutdown, malfunction report 7 1 N/A 7

LDAR report 135 2 N/A 270

Emission averaging report 14 1 N/A 14

Total 581

The number of Total Annual Responses is 581.

The total annual labor costs are $16,597,393. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost − NESHAP for Miscellaneous 

Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal). 

6(e) Bottom Line Burden Hours 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 171,406 hours at a cost of $16,597,393. Details

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

− NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) 

(Renewal).

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

information is estimated to average 295 hours per response.
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The total annual capital/startup and O&M costs to the regulated entity are $2,878,500. 

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 the next three years is estimated to be

844 labor hours at a cost of $38,038. See Table 2 below: Average Annual EPA Burden and Cost 

– NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) 

(Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent burden hours and costs as currently 

identified in the OMB Inventory of Approved Burdens. This increase is not due to any program 

changes. The adjustment increase in burden from the most recently approved ICR is due to a 

projected growth in the respondent universe, which results in an increase in the total number of 

sources, as well as updated labors rates available from the Bureau of Labor Statistics. The 

growth in respondent universe also results in an increase in the total O&M costs. 

There is also a decrease in the EPA burden hours and costs due to a correction in this 

ICR. The previous ICR assumed that all existing sources have submitted an emission averaging 

plan, but it incorrectly presented the EPA burden for the annual review of emission averaging 

plans. This ICR corrects this inconsistency, which results in a decrease in Agency burden. 

6(g) Burden Statement

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

is estimated to average 295 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-2012-0701. An electronic version of the public docket is 
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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) 566-1752. 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-2012-0701 and OMB Control Number 2060-0535 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost − NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63,

 Subpart HHHHH) (Renewal)

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(F=Ex0.05)

(G)

Clerical 

person 

hours per 

year

(G=Ex0.1)

(H)

Total Cost 

Per year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read Instructions c1 1 1 1 1 0.05 0.1 $111.36

 B. Required Activities

 Initial CMS performance evaluation d10 1 10 0 0 0 0 $0

 Create Information Included in 4

 Gather Existing Information Included in 4

 C. Write Reports

 Notification of construction/reconstruction 2 1 2 1 2 0.1 0.2 $222.71

 Notification of anticipated startup 2 1 2 1 2 0.1 0.2 $222.71

 Notification of actual startup 2 1 2 1 2 0.1 0.2 $222.71

 Notification of applicability of standard

 i. Existing sources 2 0 0 0 0 0 0 $0

 ii. New sources 2 1 2 1 2 0.1 0.2 $222.71

 Emissions averaging plan e40 1 40 0 0 0 0 $0

 Pre-compliance report f40 1 40 1 40 2 4 $4,454.23 

 Notification of initial performance test g2 1 2 0 0 0 0 $0

 Notification of initial CMS performance 

 evaluation d 

2 1 2 0 0 0 0 $0

 Notification of compliance status g

 i. With performance test 80 1 80 0 0 0 0 $0

 ii. Without performance test 120 1 120 1 120 6 12 $13,362.68

 Notification of process change h8 1 8 14 112 5.6 11.2 $12,471.83

 Semi-annual compliance report i

 i. No deviations 8 1 8 121 968 48.4 96.8 $107,792.27 

 ii. Deviations 24 1 24 14 336 16.8 33.6 $37,415.50 

 Startup, shutdown, and malfunction report j8 1 8 7 56 2.8 5.6 $6,235.92 

 LDAR report k125 2 250 135 33,750 1,687.5 3,375 $3,758,253.19 

 Emissions averaging report l20 1 20 14 280 14 28 $31,179.58 

Subtotal for Reporting Requirements 41,021.65 $3,972,167.40
16

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(F=Ex0.05)

(G)

Clerical 

person 

hours per 

year

(G=Ex0.1)

(H)

Total Cost 

Per year b

4. Recordkeeping requirements

 A. Read instructions Included in 3A

 B. Plan activities N/A

 C. Implement Activities N/A

 D. Develop record system m40 1 40 1 40 2 4 $4,454.23

 E. Develop startup, shutdown, malfunction plan n100 1 100 1 100 5 10 $11,135.57 

 F. Develop QA/QC Plan for CMS o40 1 40 0 0 0 0 $0

 G. Time to enter information

 i. Records of startup, shutdown, and 

 malfunction 1.5 1 1.5 135 202.5 10.13 20.25 $22,549.52 

 ii. Records of CMS data

 a. Record continuously monitored 

 parameters 1 365 365 135 49,275 2,463.75 4,927.5 $5,487,049.65 

 b. Compile data 24 2 48 135 6,480 324 648 $721,584.61 

 c. Information for semi-annual reports 16 2 32 135 4,320 216 432 $481,056.41 

 d. LDAR recordkeeping Included in 3C

 H. Calibration of CMS 376 1 376 135 50,760 2,538 5,076 $5,652,412.79 

 I. Time to train personnel p40 1 40 1 40 2 4 $4,454.23 

 J. Refresher course q16 1 16 135 2,160 108 216 $240,528.20 

 K. Time for audits N/A

Subtotal for Recordkeeping Requirements 130,384.13 12,625,225.21

TOTAL LABOR BURDEN AND COST 

(rounded) 171,406 $16,597,393

Assumptions:

a. 135 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b. Labor cost assumes a rate of $100.23/hour for technical labor, $121.44/hour for management labor, and $50.51/hour for clerical labor.

c. This will occur only in the first year after a facility becomes subject to the rule.

d. Assumes 10 hours to conduct a CMS performance evaluation and 2 hours to prepare a notification.

e. Assumes that all existing facilities have complied with the emissions averaging requirements; new facilities are not allowed to use emissions averaging.

f. Assumes 50 percent of the new facilities will submit a pre-compliance report [50% x 1= 0.5].

g. Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. 

h. Assumes 10 percent of the facilities will implement process changes [(10% x 135= 14 (rounded)].

i. Assumes 10 percent will have deviations [10% x 135=14 (rounded), and 121 remain]. 

j. Assumes 5% of all facilities will report actions taken during a startup, shutdown, or malfunction is not consistent with the plan [5% x 135 = 7 (rounded)].

k. Assumes all facilities will be subject to the equipment leak standards with an average of 125 hours per report.

l. Assumes that 10 percent of existing facilities will use with the emissions averaging reports to comply [10% x 135 = 14 (rounded)].
17

m. Assumes 40 hours to develop a record system for recording parameter monitoring information.

n. Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours.

o. Assumes 40 hours to develop/review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule.

p. Assumes no facilities will use the alternative standard, which requires CEMS and QA/QC plans.

q. Assumes 40 hours to train personnel and 16 hours for an annual refresher course. 
18

Table 2: Average Annual EPA Burden and Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart 

HHHHH) (Renewal)

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours per 

year

(Ex0.1)

(H)

Total Cost

per year

$ b

Notifications/Reports

 A. Review Notification of Construction/ 

 Reconstruction 2 1 2 1 2 0.1 0.2 $103.64

 B. Review Notification of Anticipated Startup 2 1 2 1 2 0.1 0.2 $103.64

 C. Review Notification of Actual Startup 2 1 2 1 2 0.1 0.2 $103.64

 D. Review Notification of Applicability of Standard 2 1 2 1 2 0.1 0.2 $103.64

 E. Review Notification of Initial Performance Test 2 1 2 0 0 0 0 $0

 F. Performance Test c8 1 8 0 0 0 0 $0

 G. Repeat Performance Test d8 0 0 0 0 0 0 $0

 H. Review Notification of Initial CMS Performance 

 Evaluation e2 1 2 0 0 0 0 $0

 I. CMS Performance Evaluation e4 1 4 0 0 0 0 $0

 J. Review Emissions Averaging Plan f12 1 12 0 0 0 0 $0

 K. Review Pre-compliance Report g2 1 2 0 0 0 0 $0

 L. Review Notification of Compliance Status

 i. With performance test h4 1 4 0 0 0 0 $0

 ii. Without performance test i4 1 4 1 4 0.2 0.4 $207.29

 M. Review Notification of Process Change j6 1 6 14 84 4.2 8.4 $4,353.08

 N. Review Semiannual Compliance Report k

 i. No deviations 2 1 2 121 242 12.1 24.2 $12,541.02

 ii. Deviations 4 1 4 14 56 2.8 5.6 $2,902.05

 O. Startup, shutdown, and malfunction report l2 1 2 7 14 0.7 1.4 $725.51

 R. LDAR report m2 1 2 135 270 13.5 27 $13,992.05

 S. Emissions averaging report f4 1 4 14 56 2.8 5.6 $2,902.05

Subtotals Labor Burden and cost 734 36.7 73.4 $38,037.61

TOTAL ANNUAL BURDEN AND COST (rounded) 844 $38,038

Assumptions:

a. 135 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b. Labor cost assumes a rate of $46.21/hour for technical labor, $62.27/hour for management labor, and $25.01/hour for clerical labor.

c. Assumes no initial performance tests because all facilities will comply by submitting engineering calculations.

d. Assumes no repeat performance tests.
19

e. Assumes no performance evaluations are required for the parameter monitoring systems included in the rule.

f. Assumes that all existing facilities have already submitted emissions averaging plans. 

g. Assumes 50 percent of the new facilities will submit a pre-compliance report [50% x 1= 0.5].

h. Assumes one new facility will conduct initial performance tests.

i. Assumes all existing facilities have complied by submitting engineering calculations.

j. Assumes 10 percent of the facilities will implement process changes [(10% x 135= 14 (rounded)].

k. Assumes 10 percent will have deviations [10% x 135=14 (rounded), and 121 remain].