**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 I CR Number 2115.0 4 , OMB Control Number 2060

- 0535 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants for Miscellaneous Coat ing 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 manufac ture 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 t o 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 ye ar or more of an y combination of HAP s . A facility is subject to the NESHAP if it meets the following criteria:

 Manufactures coatings, including inks, paints, or adhesives described b y S tandard Industrial Classification (SI C) codes 285, or 289, or North American In dustrial Classification System (NAI CS) 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 tho se 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 owne rs/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 sy stem is inope rative. 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 deleg ated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y 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 ye ars, an average of 135 respondents per ye ar will be subject to the standard, and on e additional respondent per year will become subject to the standard. The active (previous) IC R had the following Terms of Clearance (TOC): When this I CR is renewed, EPA should review the respondent burden, universe, labor rates, and capital costs an d 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 publicl y 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 res pondents is calculated below in Table 1 : Annual Respondent Burden and Cost

− NESHAP for Miscellaneous Coating Manufacturing (40 CFR P art 63, Subpart HHHHH) (Renewal)

. T he burden to the “Federal Government” is attributed entirely to work performed by either Federal employees or government contractor s . 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 mainta in 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, at3 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 certificati ons in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y 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 w as 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 acco rdance 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 d evices are properl y 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 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, duplication does not exist.4

**3(b) Public Notice Requir ed Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 7 7 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 Sy stem ( OTIS ) which is operated and maintained b y EPA’s Office of Compliance. OTI S is EPA’s database for the collection, maintenance, and retrieval of all compliance data. We es timate that there are 135 existing respondents subject to the reporting requirements of this standard, and that one new s ource will become sub

ject to the standard over the three

- ye ar period covered by this I CR. Industry trade associations and other i nterested parties were provided an opportunity to comment on the burden associated with the standard s as they were being developed and the se standard s have b een reviewed previously to determine the minimum information needed for compliance purposes. In de veloping this ICR, the Agency contacted : 1) the American Coatings Association (A C A) , at ( 202) 462

- 8731 ; and 2) the Adhesive and Sealant Council (ASC ) , at (301) 986

- 9700

. EPA did not receive an y comments from the se consultations. It is our policy

to resp ond 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) Gene ral Guidelines**  These reporting and recordkeeping requirements do not violate any of the regulations promulgated b y 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

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is5

based. The retention of records for five ye ars allows EPA to establish the compliance history of a source, an y 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 ye ars. 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 f or 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 4 3 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 m iscellaneous coating manufacturing plants

. The United States Standard Industrial Classification (SI C) codes for the respondents affect ed by the standards, and their corresponding North American Industry Classification System (NAI CS) codes, are listed below for the source category

. **Standard (40 CFR Pa**  **rt 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 record ed or reported is required by the NESHAP for Miscellaneous Coating Manufacturing (40 CFR P art 63, S ubpart HHHHH). A source must make the following reports:
**Notifications** Notification and application of construction or reconstruction 63.9(b) ( 1)

- (3 ) , 63.8070( a )6 **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 s ys tem 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 63.8 075(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)7 **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 t ank 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 sy stems to transmit data electronically . However, electronic reporting s ys tems 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 sy stems for the purpose of collecting, validating, and verifying information

. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information

.8

Develop, acquire, install, and utilize technology and s ys tems 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 s ys tem ) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has s ignificantl y 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard. Data and records maintained by the respond ents are tabulated and published for use in compliance and enforcement programs. The s emiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S 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 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 a

uthorities can edit, store, retrieve and anal yz e the data. The records required by

this regulation must be retained by the owner/operator for five9

ye ars. **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 ty pes 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, therefo re, 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 collec tion 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 d ocuments the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. 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 require ments 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 I CR uses the following labor rates: Managerial $121.44 ($57.83+ 110%) Technical $100.23 ($47.73 + 110%)10 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 increase d 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 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 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 13 5 $2,1 60 ,000 Transfer Operations N/A N/A N/A $3,100 13 5 $4 18 , 5 00 Wastewater Sy stems N/A N/A N/A $2,000 13 5 $2 70 ,000 Totals $30,000 $2, 848,5 00 The total capital/startup costs for this I CR are $30,000. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $2, 848 , 5 00. 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 IC R is estimated to be $2,8 78 , 5 00 per year. **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 pub lication and distribution of collec ted information.11

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 hourl y labor rate as follows: Managerial $6 2.27 (GS

- 13, Step 5, $38. 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), 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 I CR, on average over the next three ye ars, approximately 13 5 existing respondents will be subject to the standard. It is estimated that one additional r espondent per year will become subject . The overall average number of respondents, as shown in the table below, is 13 5 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** 

Year (A) Number of Ne w 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 13 3 0 0 13 4 2 1 13 4 0 0 13 5 3 1 13 5 0 0 13 6 Average 1 135 0 0 13 5 **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 ye ar period of this ICR is 13 5

. The total number of annual responses per ye ar is calculated using the following table:12 **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 1 4 1 N/A 1 4 Semiannual report 13 5 2 N/A 2 70 Startup, shutdown, malfunction report 7 1 N/A 7 LDAR report 13 5 2 N/A 2 70 Emission averaging report 1 4 1 N/A 1 4 Total 5 81 The number of Total Annual Responses is 5 81

. The total annual labor costs are $16,59 7,393 . 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 $16,59 7,393

. 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 burde n for this collection of information is estimated to average 295 hours per response.13

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. Opera tion and Maintenance (O&M) Costs.

**(ii) The Agency Tally** The average annu al 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 currentl y 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 recentl y approved I CR is due to a projected growth in the respondent universe, which result s 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 burd en 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 incorrectl y presented the EPA burden for the annual review of emission averaging plans. This I CR corr ects 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 tot al 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 technolo gy and sy stems 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 an y previously

applicable instructions and requi rements; 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 I CR under Docket ID Number EPA

- HQ

- OEC A

- 2012

- 0701. An electronic version of the public docket is14

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 sy stem , 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 holiday s. 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 In formation and Regulatory Affairs, Office of Managem ent 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.15

**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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Management person hours**  **per year (**  **F= Ex**  **0.05) (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 c 1 1 1 1 1 0 .05 0 .1 $ 111.36 B. Required Activities Initial CMS performance evaluation d 10 1 10 0 0 0 0 $0 Create Information Included in 4 Gather Existing Information Included in 4 C . Write Report s 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 e 40 1 40 0 0 0 0 $0 Pre

- compliance report f 40 1 40 1 40 2 4 $4,454.23 Notification of initial performance test g 2 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 h 8 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 j 8 1 8 7 56 2.8 5.6 $6,235.92 LDAR report k 125 2 250 135 33 , 750 1 , 687.5 3 , 375 $3,758,253.19 Emissions averaging report l 20 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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Management person hours**  **per year (**  **F= Ex**  **0.05) (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 m 40 1 40 1 40 2 4 $4,454.23 E

. Develop s tartup, shutdown, m alfunction plan n 100 1 100 1 100 5 10 $11,135.57 F

. Develop QA/QC Plan for CMS o 40 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 10.1 3 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 p 40 1 40 1 40 2 4 $4,454.23 J. Refresher course q 16 1 16 135 2 , 160 108 216 $240,528.20 K

. Time for a

udits N/A **Subtotal for Recordkeeping Requirements 130,384.13**  **12,625,225.21 TOTAL LABOR BURDEN AND COST**  **(rounded) 171,**  **406 $16,59**  **7,393 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. Assu mes 10 hours to conduct a CMS performance evaluation and 2 hours to prepare a notification.
e. Assu mes that all existing facilities hav e complied with the emissions averaging requirements; new facilities are not allowed to use emissions averaging. f. Assu mes 50 percent of the new facilities will submit a pre

- compliance report [50% x 1= 0.5]. g. Assu mes 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. Assu mes 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 (round ed)].17

m. Assumes 40 hours to develop a record system for recording parameter monitoring informat ion.
n. Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total o f 100 hours.
o. Assu mes 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. Assu mes no facilities will use the alternative standard, which requires CEMS and QA/QC plans. q
. Assu mes 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**  **person**   ** hours per** **occurrence (B)** 

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Management person**  **- hours**  **per year**
**(Ex0.05) (G)** 

**Clerical person**  **** **hours 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 c 8 1 8 0 0 0 0 $0 G. Repeat Performance Test d 8 0 0 0 0 0 0 $0 H. Review Notification of Initial CMS Performance Evaluation e 2 1 2 0 0 0 0 $0 I. CMS Performance Evaluation e 4 1 4 0 0 0 0 $0 J. Review Emissions Averaging Plan f 12 1 12 0 0 0 0 $0 K. Review Pre

- compliance Report g 2 1 2 0 0 0 0 $0 L. Review Notification of Compliance Status i. With performance test h 4 1 4 0 0 0 0 $0 ii. Without performance test i 4 1 4 1 4 0.2 0.4 $207.29 M. Review Notification of Process Change j 6 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 l 2 1 2 7 14 0.7 1.4 $725.51 R. LDAR report m 2 1 2 135 270 13.5 27 $13,992.05 S. Emissions averaging report f 4 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. Assu mes no initial performance tests because all facilities will comply by submitting engineering calculations. d. Assu mes no repeat performance tests.19

e. Assu mes no performance evaluations are required for the parameter monitoring systems included in the rule. f. Assu mes that all existing facilities have already submitted emissions averaging plans. g. Assu mes 50 percent of the new facilities will submit a pre

- compliance report [50% x 1= 0.5]. h. Assumes one new facility will conduc t 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. Assu mes 10 percent will have deviations [10% x 135=14 (rounded), and 121 remain].