PART A OF THE SUPPORTING STATEMENT

1.	Identification of the Information Collection

1(a)	Title and Number of the Information Collection.

	“Information Collection Request Survey for the Aerospace
Manufacturing and Rework Industry.”  This is a new information
collection request (ICR), and the EPA ICR number 2395.01.  The OMB
Control number is 2060-NEW.

1(b)	Short Characterization.

	This information collection survey for aerospace manufacturing and
rework facilities was prepared by EPA’s Sector Policies and Programs
Division (SPPD) in the Office of Air Quality Planning and Standards
(OAQPS), and they are the intended users of the collected data. 
Respondents are owners or operators of aerospace manufacturing and
rework facilities.  Aerospace manufacturing and rework was listed as a
source category under the Clean Air Act (CAA) on July 16, 1992 (57 FR
31576).  The CAA requires that a risk and technology review (RTR) be
conducted for this source category by September 1, 2003.  This
information collection will provide SPPD with the data necessary to
conduct the RTR.  

	This survey was developed specifically for aerospace manufacturing and
rework facilities.  This information collection has been tailored to the
processes at aerospace facilities and uses an electronic submission
approach that will be less burdensome for both the facilities that must
respond and for EPA personnel who must compile the responses. 
Respondents are asked to complete simple forms from available
information and no request is made to create or develop emission
estimates from information in the literature.    

	Information is requested from approximately 1,000 aerospace
manufacturing and rework facilities on general facility information,
coatings and spray booth information, other process information (e.g.,
storage tanks, composite processing, etc.), emission control devices in
place and their basic design and operating features, quantity of air
emissions, pollution prevention programs at each facility, and
information regarding startup and shutdown events.  This information is
necessary for EPA to adequately characterize residual risk at these
facilities, to characterize emissions and control measures for
operations not currently regulated, and to develop standards for new and
existing aerospace facilities under section 112 of the CAA, if
appropriate.  The information will be collected from the electronic
completion of simple forms, which will be compiled to develop a computer
database.  The completed forms and the computer database will become
part of the rulemaking docket.  

	EPA estimates that there will be roughly 1,000 survey respondents and
that they will incur a total burden of 46,955 hours at an estimated cost
of $2,261,288 as a result of this one-time collection.  The cost to the
Agency is estimated to be approximately $47,633.

2.	Need For and Use of the Collection

2(a)	Need/Authority for the Collection.

	The EPA is charged under section 112 of the CAA with developing
national emission standards for 189 listed HAP.  The Aerospace
Manufacturing and Rework Facilities Maximum Achievable Control
Technology (Aerospace MACT) standard (40 CFR 63, subpart GG), is a
National Emission Standard for Hazardous Air Pollutants (NESHAP)
developed under the authority of section 112(d) of the CAA.  EPA is
required to review each MACT standard and to revise them “as necessary
(taking into account developments in practices, processes and control
technologies)” no less frequently than every eight years.  These
reviews are commonly referred to as “technology reviews.”  In
addition, EPA is required to assess the risk remaining (residual risk)
after each MACT standard and promulgate more stringent standards if they
are necessary to protect public health.  Under EPA’s RTR program, EPA
is addressing these two requirements concurrently.  EPA is updating the
information they currently possess and filling identified data gaps in
that information in order to provide a thorough basis for the RTR
efforts.  The data collection effort will gather additional information
to allow comprehensive and technically sound analyses that will form the
basis for future rulemaking decisions.  The information is being
collected under the authority of section 114 of the CAA.

2(b)	Practical Utility/Users of the Data.

	The SPPD of the OAQPS uses the information gathered through the survey
form to conduct the RTR, on which future rulemaking decisions will be
based. 

 3.	Nonduplication, Consultations and Other Collection Criteria

3(a)	Nonduplication.

	To the best of EPA’s knowledge, the data to be collected through this
survey is not available elsewhere.  A search of EPA’s ongoing
information collections revealed no duplication of information gathering
efforts, and the information that will be requested is not available
through other sources.  

	In 1994, EPA surveyed aerospace manufacturing and rework facilities to
gather information to develop MACT standards for the aerospace industry.
 That survey was sent to a small portion of the industry and did not ask
for information about certain aerospace manufacturing operations and
emission source types.  The current survey does not duplicate the
previous survey.  Furthermore, in response to changes in market
conditions and regulatory requirements (such as the OSHA hexavalent
chromium exposure limit), EPA expects that many aerospace facilities
have changed their coatings, enclosed their spray booth operations and
reduced HAP content in solvents since 1994.  To the extent that some of
the questions in this survey are similar to those in the previous
survey, many of the answers that facilities will provide may have
changed in the intervening years.  Because the current survey will
collect different and updated information as compared to the previous
survey, the data collected in 1994 does not fulfill EPA’s current
needs, and the current survey is not duplicative of the previous survey.
 

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

	Pursuant to the Paperwork Reduction Act  (PRA) (44 U.S. C 3501 et
seq.), the EPA notified the public through a Federal Register notice
(see XX FR XXXX, date) of the Agency’s intent to submit the Aerospace
Industry Survey ICR to OMB.  The notice included a description of the
entities to be affected by the proposed survey, a brief explanation of
the need for the survey, identification of the statutory authority under
which the survey will be issued, and an estimate of burden to be
incurred by survey respondents.  Through the notice, the Agency
requested comments and suggestions regarding the survey and the
reduction of data collection burden.  A summary of the comments EPA
received and EPA’s responses are included in Attachment 3.  

3(c)	Consultations.

	Under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with
potential ICR respondents and data users about specific aspects of ICRs
before submitting an original or renewal ICR to OMB for review and
approval.  EPA sent out a letter providing potential respondents with a
list of the data elements that will be included in the survey and
requested feedback on these data elements via written communication or
by participation in a conference call with EPA.  This teleconference
meeting was held December 18, 2009, at the EPA facilities in Research
Triangle Park, NC.  The list of data elements is included as Attachment
2 to this supporting statement.  The letter was sent to relevant trade
organizations and to over 1,200 facilities believed to be aerospace
manufacturing or rework facilities.  No feedback, either written or at
the meeting, was provided by potential respondents directly relating to
the data elements of the survey.  Some facilities did respond to the
letter to inform EPA that they were not aerospace manufacturing and
rework facilities or were area sources. 

3(d)	Effects of Less Frequent Collection.

	This survey is to be administered one time only.  If this survey is not
conducted, the specific data sought in this survey will not be available
for EPA’s use in decision making about the need for and scope of
potential residual risk rules for the aerospace industry.  

3(e)	General Guidelines.

	This information collection complies with the guidelines in 5 CFR
1320.5(d)(2).

3(f)	Confidentiality.

	All 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 39999, September 8, 1978; 43
FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979.)

3(g)	Sensitive Questions.

	This section is not applicable because this survey does not involve
matters of a sensitive nature.

4.	The Respondents and the Information Requested

4(a)	Respondents/NAICS Codes.

	Respondents associated with this information collection are owners or
operators of existing aerospace manufacturing and rework facilities. 
The North American Industrial Classification Codes (NAICS) associated
with this industry are presented in Table 1.

Table 1.  North American Industrial Classification Codes for the
Aerospace Manufacturing and Rework Industry



NAICS Code	Description



	336411	Aircraft Manufacturing

336412	Aircraft Engine and Engine Parts Manufacturing

336413	Other Aircraft Parts and Auxiliary Equipment Manufacturing

336414	Guided Missile and Space Vehicle Manufacturing



336415	Guided Missile and Space Vehicle Propulsion Units and Propulsion
Units Parts Manufacturing

336419	Other Guided Missile and Space Vehicle Parts and Auxiliary
Equipment Manufacturing

481111	Scheduled Passenger Air Transportation

481112	Scheduled Freight Air Transportation

481211	Nonscheduled Chartered Passenger Air Transportation

481212	Nonscheduled Chartered Freight Air Transportation

481219	Other Nonscheduled Air Transportation



Approximately 1,000 aerospace manufacturing and rework facilities have
been identified to receive this survey.  EPA projects a total of about
1,000 responses under this ICR.  

4(b)	Information Requested.

	4(b)(i)	Data items, including recordkeeping requirements.  A copy of
the survey and instructions are provided as Attachment 1.  There are no
recordkeeping requirements associated with this request.  Information is
requested from each respondent on general facility information, coating
and spray booth information, other processes (e.g., storage tanks, metal
finishing, etc.), air emissions from these booths and other processes,
and identification of capture and control devices.  

	Part I (Introduction) provides guidance to the respondent and
highlights that no additional monitoring or testing is required to
respond to the request.  The introduction lists an EPA contact for
questions and provides the name and address to which the completed
survey should be mailed.  Instructions are also provided for submitting
the completed form electronically.  Finally, an outline of the
questionnaire form is provided.

	Part II (Instructions) provides instructions on how to complete each
form in the questionnaire.  There are general instructions and
instructions specific to each form.

	Form A-1 (Parent Company Information) asks for information about the
parent company, and size of the parent company, in order for EPA to
conduct an appropriate economic analysis for this category and evaluate
potential small entity impacts. 

	  Form A-2 (Facility Information) is where the respondent (facility
contact person), company and facility are identified.  EPA will use this
information to ensure that its facility list is current and accurate, a
necessary component of achieving to represent the universe of sources in
any analyses.  Coordinates are requested, along with a typical operating
schedule for the facility.  In addition, questions are asked about the
products produced at the facility and if the facility is a major source
of HAP emissions.

	Form B-1 (Spray Booth Information) requests data for each spray booth
at the facility, including the type of booth, the location coordinates
of each booth, and the dimensions of each booth.  Information is also
requested on the type of particulate filter system used in the booth. 
Control device information should also be provided.  

	Form C-1 and C-2 (Coatings) are the same form except one requests the
information in English units and the other requests the information in
metric units.  Respondents do not have to fill out both forms, but can
fill out whichever one utilizes the data they have easily available. 
Information is requested on the type of coating, including specialty
coatings and the HAP contained in each coating.  The forms also include
a section for the respondents to identify the spray booth that each
coating was applied in and the amount of coating that was applied.  

	Form D-1 (Chemical Milling and Metal Finishing Operations) requests HAP
usage and emissions from chemical milling and metal finishing operations
at the facility.  Coordinates, dimensions and hours of operation are
requested for each tank.  Control device and work practice information
is also requested.

	Form E-1 (Blast Depainting/Cleaning Operations) is where the respondent
will report HAP emissions from blast depainting and cleaning operations
that use blasting methods.  In addition to emissions, coordinates,
dimensions and hours of operation are also requested.  Control device
and work practice information should also be recorded on this form.

	Form E-2 (Solvent Depainting Operations) is where the respondent will
report HAP emissions from depainting operations that use solvent
materials.  The same information is requested (e.g., emissions,
coordinates, control device) as in Form E-1.

	Form E-3 (Solvent Cleaning Operations) requests information on HAP
emissions from solvent cleaning operations such as hand-wipe cleaning of
aerospace components, cleaning of spray guns and cleaning of spray
booths.  In addition to HAP emissions, information is requested on
location coordinates, building dimensions, control devices and work
practices.  

	Form E-4 (Solvent Cleaning Operations) requests information similar to
that requested on Form E-3, except that only cleaning operations subject
to the Halogenated Solvent Cleaning NESHAP (40 CFR 63, subpart T) should
be reported.  Even though halogenated solvent cleaning operations are
not subject to the aerospace NESHAP, the EPA is concerned that some
aerospace facilities may have mistakenly reported emissions from these
operations as emissions from operations subject to the aerospace NESHAP
in part reporting to state or local agencies.  In order to estimate the
residual risk accurately from each of these categories, the EPA is
attempting to first develop accurate emissions estimates.  The
respondents’ efforts to properly report halogenated solvent cleaning
operations on Form E-4 and not on Form E-3 will play an important role
in the EPA’s development of emissions estimates from these two
categories.  

	Form F-1 and F-2 (Composite Processing Operations) are the same form
except one requests the information in English units and the other
requests the information in metric units.  Respondents do not have to
fill out both forms, but can fill out whichever one utilizes the data
they have easily available.  Information is requested on the type of
resins used in composite processing operations, the total volume of
resin used and information related to the spray booth used to apply the
resins.  

	Form G-1 (Storage Tanks) is where the respondent will provide HAP
emissions from storage tanks used to store materials used in aerospace
manufacturing and rework operations.  The type of tank, the coordinates
of the tank, the dimensions of the tank, the HAP component of the
material in the tank and control device information are all requested.  

	Form H-1 (Wastewater Treatment Operations) requests information on
wastewater treatment operations as they pertain to aerospace
manufacturing and rework operations.  The coordinates, dimensions, hours
of operation, HAP emissions and control device information are all
requested.  

	Form I-1 (Startups and Shutdowns) provides examples of startup and
shutdown events that would be reported on this form.  Information on
this form is requested if it is readily available.  Additional testing
or data gathering is not required to complete this form for startup and
shutdown events.

	Forms J-1 to J-11 (Air Pollution Control Devices) provide a form for
each control device likely to be in use at aerospace manufacturing and
rework facilities.  If an air pollution control device is not in use at
the facility, the relevant form does not need to be filled out.  The
information requested for these forms should be readily available.  No
additional testing or data gathering is required in order to complete
these forms.

	Form K-1 (Air Pollution Control Device Costs) is where the respondent
will enter readily available information related to the cost of each air
pollution control device for which information was provided in Forms J-1
to J-11.  

	4(b)(ii)	Respondent activities.  The survey will be sent to each
aerospace manufacturing and rework facility, who will be asked to
complete and return the survey instrument.  Completion of the survey
involves the following steps:

Reviewing instructions:  Respondents will need to read the instructions
for the survey;

Search data sources:  Respondents may need to consult records and review
facility information, in addition to gathering available data from
files, regarding coating usage, booth types, and other requested
information prior to completing the survey;

Complete and review the collection of information:  Respondents will
need to complete the survey and review their answers; and

Transmit or otherwise disclose the information:  Respondents will need
to return the completed survey to EPA.

The request does not require respondents to make measurements of
emissions or otherwise create information, and it relies on information
that should be readily available to the respondent.  Consequently, it is
consistent and compatible with existing reporting and recordkeeping
requirements because the survey asks only for this existing information.
 There is no need for respondents to develop or acquire technology or
systems to collect, process or disclose the information.

	Non-respondents will receive up to two reminder calls encouraging them
to participate.  If EPA decides to issue subpoenas because it does not
receive a sufficient response rate to accurately characterize the
industry, the initial non-respondents will need to review the subpoena,
as well as following the steps outlined above.

	This questionnaire asks for readily obtainable information, e.g.,
information known or easily accessible by technical, managerial or
supervisory employees of the facility who are responsible for
manufacturing, processing, technical services or marketing.  The
facility does not need to generate new information to complete the
survey.  

	The collection will be a one-time event, and there will be no
requirement for respondents to maintain records to support their
responses.  However, EPA is suggesting that respondents keep a copy of
the completed questionnaire for their files in case the Agency contacts
them with any follow-up questions after reviewing their responses.  

5.	The Information Collected – Agency Activities, Collection
Methodology and 	Information Management

5(a)	Agency Activities.

	Agency activities associated with the information collection include
preparing the questionnaire, answering respondent questions about the
questionnaire, reviewing data submissions, addressing requests for
confidentiality and compiling the data into a database.

5(b)	Collection Methodology and Management.

	Data collection will be accomplished using an electronic survey tool. 
Recipients of the letter announcing the survey’s availability will be
directed to an EPA web page to download the files.  The respondent will
be asked to complete and return the survey within a three-month
timeframe.  Respondents will be encouraged to complete an electronic
copy of the survey and upload it to the EPA web page, which reduces
transcription errors when EPA processes the responses.  Non-respondents
will receive up to two reminder calls encouraging them to participate. 
The web page will also have instructions on how to submit data that is
CBI.

	A written survey is being used because some of the information EPA is
requesting may require the respondent to consult records or other
documents at the facility, which would be difficult to do during a
telephone survey given the type of information requested and the number
of potential respondents.  In addition, the written survey method will
allow the respondent to complete the survey at his or her convenience. 
Electronic transmission of the empty and completed survey forms will
lead to more efficient data collection, both in terms of reducing
mailing costs and paper usage and reducing transcription errors.  The
survey has been designed to be easily compiled into a database upon
receipt of the completed survey files.  

	For this information collection, the submissions will be monitored for
completeness, and follow-up calls will be made to maximize the response
rate.  Confidential information will be maintained in secure locations
as required by procedures for handling CBI.  Confidential Business
Information will not be entered into the computer database.  Public
access to non-CBI information will be provided through the rulemaking
docket, which will contain the survey responses and a copy of the
resulting database.

5(c)	Small Entity Flexibility.

	EPA has identified a list of roughly 1,000 U.S. facilities with
aerospace manufacture or rework operations.  Some of these manufacturers
are small businesses as defined by the Small Business Administration’s
size standards.  EPA considered collecting data from only a sample of
manufacturers, but determined that a census (a survey administered to
the entire population of aerospace manufacturing and rework facilities,
including small businesses) is appropriate.  A census will more
accurately characterize the industry.  EPA needs to include small
businesses in the survey so that it can better estimate potential small
business impacts in the event the Agency ultimately decides to proceed
with a regulatory action.  

	In developing the information request, SPPD considered whether a
separate request or no request for information should be made to small
facilities.  A major consideration was that the burden of responding to
the questionnaire is not excessive for small facilities.  Because they
have fewer and simpler processes, smaller facilities will require less
time to prepare a response than larger facilities.  The information
requested from the smaller facilities should be readily available and no
requests are made to perform measurements or create information.

	Many of the aerospace manufacturing and rework facilities meet the
definition of small business (e.g., companies with fewer than 1,000 or
1,500 employees total at all facilities for facilities in NAICS 2-digit
code 33, and companies with less than $7 million in annual average
receipts for facilities in NAICS 2-digit code 48), and information from
small entities is important to this regulatory development.  The
information collected from small entities will improve the analyses that
must be performed to assess the economic impact of a potential MACT
standard on them.  A Regulatory Flexibility Analysis must be performed
under the Regulatory Flexibility Act of 1980 if a proposed regulation
will have a significant economic impact on a substantial number of small
entities.  The information from small entities will also assist in
addressing the requirements of the Small Business Regulatory Enforcement
Fairness Act of 1996.

	Although many of these small businesses are not likely to be major
sources of HAP emissions, information on emissions and the level of
control performance achieved is needed from all facilities in the
industry to determine with reasonable accuracy the “average emission
limitation achieved” by the top-performing 12 percent of sources.  The
coverage of small facilities is especially important if any are in this
top 12 percent.

	In addition, the best controlled sources may include some of the
smaller facilities, which would affect the determination of MACT for new
aerospace facilities.  Information on smaller facilities will aid in
determining if a facility size cutoff is warranted, and if so, which of
the smaller facilities should be exempt from the MACT standard.  The
information on small facilities will also provide insight into pollution
prevention measures that might be applicable to larger facilities.  Even
if the smaller facilities are not major sources, the information from
their responses to the survey will be useful in determining if they are
significant area sources that may warrant regulation.

5(d)	Collection Schedule.

	The proposed mailing date for the survey is XXXX.  The respondents are
given three months to reply, with XXXX being the anticipated date when
all data is available for analysis by EPA.  The data will be used to
develop residual risk standards, if warranted, with proposal targeted
for August 2011 and promulgation in June 2010.

6.	Estimating the Burden and Cost of the Collection

6(a)	Estimating Respondent Burden.

	EPA will request that all U.S. aerospace manufacturing and rework
facilities complete the questionnaire forms.  Each section of the
questionnaire is expected to be completed by technical and clerical
staff and reviewed by managerial staff.  Respondent activities include
reading the cover letter and downloading the forms, reading the
instructions, gathering data, manipulating data for entry into the
forms, entering data into the forms and uploading the forms.  The
exhibit reflects the assumption that technical and clerical staff will
devote their time to reading instructions, gathering information,
completing the questionnaire forms and transmitting the information;
managerial staff will devote their time to reading instructions and
reviewing questionnaire responses.  

	Table 2 presents the average number of hours required for each task for
respondents of three sizes:  small, medium and large.  Due to the wide
range in sizes of aerospace facilities, it was necessary to estimate the
burden for each size of facility.  Based on the industry’s facility
size breakdown contained in the proposal Background Information Document
for the Aerospace NESHAP, it is assumed that 84 percent of the
respondents are small facilities, 14 percent are medium facilities and
two percent are large facilities.  There are approximately 1,000
respondents expected to complete the questionnaire.  

	A typical small-size facility respondent is estimated to need an
average of 30.75 hours to complete the questionnaire, while a typical
medium-size facility respondent is estimated to need an average of 86.74
hours to complete the questionnaire and a typical large-size facility
respondent is estimated to need an average of 142.75 hours to complete
the questionnaire.  These burden estimates include technical, management
and clerical hours.  Table 3 presents the burden estimate for small-size
facilities, while Table 4 presents the burden estimate for medium-size
facilities and Table 5 presents the burden estimate for large-size
facilities.  These unit burden estimates are average values.  As with
any average, some respondents will be above the average and others will
be below.  

6(b)	Estimating Respondent Costs.

	The information collection activities and estimated costs for all
respondents are presented in Tables 3, 4  and 5.  The costs are based on
hourly rates estimated as follows:  technical at $49.80/hr, management
at $62.08/hr and clerical at $24.79/hr.  For a typical small-size
facility respondent, the costs are estimated as $1,703 (30.75 hours),
while for a typical medium-size facility respondent the costs are
estimated as $4,804 (86.75 hours), and for a typical large-size facility
the costs are estimated as $7,906 (142.75 hours).  There are no capital
or operation and maintenance costs.  A summary of the burden and costs
for all respondents is presented in Table 6.

6(c)	Estimating Agency Burden and Cost.

	The costs the federal government would incur would be for preparing the
questionnaire, answering respondent questions about the questionnaire,
reviewing data submissions, addressing requests for confidentiality and
compiling the data into a database.  The burden estimate is presented in
Table 7 at the end of this supporting statement.  Hourly labor rates
were taken from the Office of Personnel Management Salary Table 2010-GS
(effective January 2010) and are as follows:  technical (GS-12, Step 5)
at $32.73/hour, management (GS-15, Step 5) at $54.10/hr, and clerical
(GS-5, Step 5) at $14.90/hr.  The total costs for the Agency are
estimated as $47,633.    

6(d)	Estimating the Respondent Universe and Total Burden and Costs.

	For small-size facilities, the total burden shown in Table 3 is
estimated as 1,291.5 management hours, 25,830 technical hours and 2,583
clerical hours at a cost of $1,430,543.  The total burden and costs are
based on 840 small-size aerospace facilities completing the survey.

	For medium-size facilities, the total burden shown in Table 4 is
estimated as 607.3 management hours, 12,145 technical hours and 1,214.5
clerical hours at a cost of $672,627.  The total burden and costs are
based on 140 medium-size aerospace facilities completing the survey.  

	For large-size facilities, the total burden shown in Table 5 is
estimated as 142.8 management hours, 2,855 technical hours and 285.5
clerical hours at a cost of $158,118.  The total burden and costs are
based on 20 large-size aerospace facilities completing the survey.     

6(e)	Bottom Line Burden Hours and Cost Tables.

	6(e)(i)	Respondent tally.  The total respondent burdens are given in
Table 6 and are estimated as 29,704.5 hours and $1,430,543 for
small-size respondents, 13,966.8 hours and $672,627 for medium-size
respondents and 3,283.3 hours and $158,118 for large-size respondents. 
For all respondents, the total burden is estimated as 46,954.6 hours and
$2,261,288.

	6(e)(ii)	The Agency tally.  The total Agency burden is given in Table 7
and is estimated as 1,483.5 hours and $47,633.

	6(e)(iii)Variations in the annual bottom line.  This section does not
apply since no significant variation is anticipated.

6(f)	Reasons for Change in Burden.

	This section does not apply since this is a new collection.

6(g)	Burden Statement.

	The average respondent burden for each small-size facility is estimated
as 30.75 hours and a cost of $1,703.  The average respondent burden for
each medium-size facility is estimated as 86.75 hours and a cost of
$4,804.  The average respondent burden for each large-size facility is
estimated as 142.75 hours and a cost of 7,906.  This includes time to
read the cover letter and download the forms, read the instructions,
gather data, manipulate data for entry into forms, enter data into forms
and upload forms.  No capital costs or operation and maintenance costs
will be incurred.

	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 currently valid OMB control number. 
The OMB control numbers for EPA’s regulations are listed in 40 CFR
part 9 and 48 CFR chapter 15.

	Send comments on the Agency’s need for this information, the accuracy
of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of automated
collection techniques to the Director, Office of Policy, Planning and
Evaluation (OPPE) Regulatory Information Division, U.S. Environmental
Protection Agency (2137), 401 M St., S.W., Washington, DC  20460; and to
the Office of Information and Regulatory Affairs, OMB, 725 17th Street,
NW, Washington, DC  20503, Attention:  Desk Officer for EPA.  Include
the EPA ICR number and OMB control number in any correspondence.

	PART B OF THE SUPPORTING STATEMENT

	This section is not applicable because statistical methods are not used
in the data collection associated with this information collection.



TABLE 2.  ESTIMATED RESPONDENT BURDEN FOR THE AEROSPACE ICR



Task	Technical Labor Hours by Facility Size

	Small	Medium	Large

Read cover letter/download forms	0.75	0.75	0.75

Read instructions	1.5	1.5	1.5

Gather data	20	60	100

Manipulate data for entry into forms	4	12	20

Enter data into forms	4	12	20

Upload forms	0.5	0.5	0.5

TOTAL TECHNICAL LABOR HOURS	  =SUM(ABOVE)  30.75 	  =SUM(ABOVE)  86.75 	
 =SUM(ABOVE)  142.75 



TABLE 3.  ANNUAL RESPONDENT BURDEN AND COST FOR SMALL FACILITIES



Burden Item	(A)

Person hours per respondenta	(B)

Number of respondents	(C)

Technical person hours

(C = A x B)	(D)

Management person hours (0.05 x C)	(E)

Clerical person hours (0.1 x C)	(F)

Costb ($)

Read cover letter/download forms	0.75	840	630.0	31.5	63.0	34,891

Read instructions	1.5	840	1,260.0	63.0	126.0	69,783

Gather data	20	840	16,800.0	840.0	1,680.0	930,434

Manipulate data for entry into forms	4	840	3,360.0	168.0	336.0	186,087

Enter data into forms	4	840	3,360.0	168.0	336.0	186,087

Upload forms	0.5	840	420.0	21.0	42.0	23,260.86

TOTAL LABOR BURDEN AND COST	30.75	n/a	25,830.0	1,291.5	2,583.0	1,430,543

a See values in Table 1.

 b Costs were taken from the Bureau of Labor Statistics, National
Compensation Survey, Employer Costs for Employee Compensation
Supplementary Tables December 2007.  Supplementary Table 2 – Employer
costs per hour worked for employee compensation and costs as a percent
of total compensation:  Private industry workers in manufacturing
industries, by occupational group, establishment size and bargaining
status.  December 2007.  Available on-line at   HYPERLINK
"http://www.bls.gov/ect"  http://www.bls.gov/ect .  The cost for
technical person hours is $49.80/hour, taken from the total compensation
value for the “professional and related” occupational group.  The
cost for management person hours is $62.08/hr, taken from the total
compensation value for the “management, business and financial”
occupational group.  The cost for clerical person hours is $24.79/hr,
taken from the total compensation value for the “office and
administrative support” occupational group.





TABLE 4.  ANNUAL RESPONDENT BURDEN AND COST FOR MEDIUM FACILITIES



Burden Item	(A)

Person hours per respondenta	(B)

Number of respondents	(C)

Technical person hours

(C = A x B)	(D)

Management person hours (0.05 x C)	(E)

Clerical person hours (0.1 x C)	(F)

Costb ($)

Read cover letter/download forms	0.75	140	105.0	5.3	10.5	5,815

Read instructions	1.5	140	210.0	10.5	21.0	11,630

Gather data	60	140	8,400.0	420.0	840.0	465,217

Manipulate data for entry into forms	12	140	1,680.0	84.0	168.0	93,043

Enter data into forms	12	140	1,680.0	84.0	168.0	93,043

Upload forms	0.5	140	70.0	3.5	7.0	3,877

TOTAL LABOR BURDEN AND COST	86.75	n/a	12,145.0	607.3	1,214.5	672,627

a See values in Table 1.

b Costs were taken from the Bureau of Labor Statistics, National
Compensation Survey, Employer Costs for Employee Compensation
Supplementary Tables December 2007.  Supplementary Table 2 – Employer
costs per hour worked for employee compensation and costs as a percent
of total compensation:  Private industry workers in manufacturing
industries, by occupational group, establishment size and bargaining
status.  December 2007.  Available on-line at   HYPERLINK
"http://www.bls.gov/ect"  http://www.bls.gov/ect .  The cost for
technical person hours is $49.80/hour, taken from the total compensation
value for the “professional and related” occupational group.  The
cost for management person hours is $62.08/hr, taken from the total
compensation value for the “management, business and financial”
occupational group.  The cost for clerical person hours is $24.79/hr,
taken from the total compensation value for the “office and
administrative support” occupational group.  





TABLE 5.  ANNUAL RESPONDENT BURDEN AND COST FOR LARGE FACILITIES



Burden Item	(A)

Person hours per respondenta	(B)

Number of respondents	(C)

Technical person hours

(C = A x B)	(D)

Management person hours (0.05 x C)	(E)

Clerical person hours (0.1 x C)	(F)

Costb ($)

Read cover letter/download forms	0.75	20	15.0	0.8	1.5	831

Read instructions	1.5	20	30.0	1.5	3.0	1,661

Gather data	100	20	2,000.0	100.0	200.0	110,766

Manipulate data for entry into forms	20	20	400.0	20.0	40.0	22,153

Enter data into forms	20	20	400.0	20.0	40.0	22,153

Upload forms	0.5	20	10.0	0.5	1.0	554

TOTAL LABOR BURDEN AND COST	142.75	n/a	2,855.0	142.8	285.5	158,118

a See values in Table 1.

b Costs were taken from the Bureau of Labor Statistics, National
Compensation Survey, Employer Costs for Employee Compensation
Supplementary Tables December 2007.  Supplementary Table 2 – Employer
costs per hour worked for employee compensation and costs as a percent
of total compensation:  Private industry workers in manufacturing
industries, by occupational group, establishment size and bargaining
status.  December 2007.  Available on-line at   HYPERLINK
"http://www.bls.gov/ect"  http://www.bls.gov/ect .  The cost for
technical person hours is $49.80/hour, taken from the total compensation
value for the “professional and related” occupational group.  The
cost for management person hours is $62.08/hr, taken from the total
compensation value for the “management, business and financial”
occupational group.  The cost for clerical person hours is $24.79/hr,
taken from the total compensation value for the “office and
administrative support” occupational group.



TABLE 6.  SUMMARY OF ESTIMATED RESPONDENT BURDEN FOR THE AEROSPACE ICR



	Value by Facility Size

	Small	Medium	Large

Total Number of Respondents	840	140	20

Total Labor Hours	29,704.5	13,966.8	3,283.3

Labor Hours Per Respondent	30.75	86.75	142.75

Total Labor Cost ($)	1,430,543	672,627	158,118

Labor Cost Per Respondent ($)	1,703	4,804	7,906



	

TABLE 7.  ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT



Burden Item	(A)

EPA Hrs/Occurrence	(B)

Contractor Hrs/Occurrence	(C)

Number of Occurrences	(D)

Total EPA Hrs (AxC)	(E)

Total Contractor Hrs (BxC)	(F)

Total Hrs (D+E)c

Develop survey and industry mailing list	50.0	350.0	1	50.0	350.0	400.0

Distribute survey	40.0	0.0	1	40.0	0.0	40.0

Answer questionsa	0.1	0.25	200	20.0	50.0	70.0

Audit/review submissions	0.25	0.1	1000	250.0	100.0	350.0

Enter into database/QA check	0.0	0.3	1000	0.0	300.0	300.0

Analyze submissions and summarize results	0.0	80.0	1	0.0	80.0	80.0

Respond to requests for confidentialityb	0.3	0.2	100	30.0	20.0	50.0

TOTAL LABOR BURDEN AND COST	n/a	n/a	n/a	390.0	900.0	1,290.0

a It is assumed that questions will need to be answered for 20 percent
of the respondents.

b It is assumed that responses to requests for confidentiality will be
needed for 10 percent of the respondents.

c For the purposes of the cost calculations in this table, it is assumed
that EPA and Contractor hours for technical, management, and clerical
positions cost the same amount.





TABLE 7.  ANNUAL BURDEN AND COST FOR THE FEDERAL GOVERNMENT (cont.)



Burden Item	(G)

Technical person hours (=F) (GS12)	(H)

Management person hours (G x 0.05) (GS15)	(I)

Clerical person hours (G x 0.1) (GS5)	(J)

Costd ($)

Develop survey and industry mailing list	400.0	20.0	40.0	14,770.00

Distribute survey	40.0	2.0	4.0	1,477.00

Answer questionsa	70.0	3.5	7.0	2,584.75

Audit/review submissions	350.0	17.5	35.0	12,923.75

Enter into database/QA check	300.0	15.0	30.0	11,077.50

Analyze submissions and summarize results	80.0	4.0	8.0	2,954.00

Respond to requests for confidentialityb	50.0	2.5	5.0	1,846.25

TOTAL LABOR BURDEN AND COST	1,290.0	64.5	129.0	47,633.25

d Costs were taken from the U.S. Office of Personnel Management, Salary
Table 2010-GS, effective January 2010, available on-line at   HYPERLINK
"http://www.opm.gov/oca/10tables/html/gs_h.asp" 
http://www.opm.gov/oca/10tables/html/gs_h.asp .  All hourly rates are
baseline values.  It was assumed that the technical person is a GS-12,
Step 5 employee with a rate of $32.73 per hour, that the management
person is a GS-15, Step 5 employee with a rate of $54.10 per hour, and
that the clerical person is a GS-5, Step 5 employee with a rate of
$14.90 per hour.  



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