INFORMATION COLLECTION REQUEST

for

Aerospace Manufacturing and Rework Industry Information Collection

EPA ICR number 2395.01, OMB Control number is 2060-NEW

RESPONSE TO COMMENT

On June 22, 2010, EPA published a notice in the Federal Register (75 FR
35454) announcing their intent to submit a request to the Office of
Management and Budget (OMB) for a new Information Collection Request
(ICR).  The ICR will be used to collect certain information from
aerospace manufacturing and rework facilities potentially subject to the
National Emission Standards for Aerospace Manufacturing and Rework
Facilities (Aerospace NESHAP).

	The notice included a request for comments on specific aspects of the
proposed ICR; we received two comments in response to the notice. 
Comments were received from United Airlines (United) and the Aerospace
Industries Association (AIA).  Their comments and suggested responses to
those comments are summarized below.

I.  United Airlines

	Comment:  United is concerned that abrasive blasting may be further
regulated based on its inclusion in the draft ICR.  These operations are
generally exempt or excluded entirely from existing local regulations.

	The draft ICR requests information on metal finishing and depainting
activities already regulated under other existing NESHAP.  Including
these operations in the aerospace NESHAP would be duplicative and
burdensome.

	Response:  Section 112 of the CAA establishes a two-stage regulatory
process to address emissions of hazardous air pollutants (HAP) from
stationary sources.  The first stage is to develop NESHAP for major
sources.  EPA is then required to review these technology-based
standards and to revise them “as necessary (taking into account
developments in practices,

processes, and control technologies)” no less frequently than every 8
years, under CAA section 112(d)(6).  The second stage in the regulatory
process focuses on reducing any remaining “residual” risk according
to CAA section 112(f).  CAA section 112(f)(2) requires us to determine,
for source categories subject to certain CAA section 112(d) standards,
whether the emissions limitations provide an ample margin of safety to
protect public health.  The ICR will be used as a data gathering tool
for both technology review and the residual risk review of the Aerospace
NESHAP.  Additionally, we are evaluating whether operations exempted or
excluded from the Aerospace NESHAP should now be regulated.  Thus, we
must collect information for all operations at aerospace facilities, not
just those currently regulated under the Aerospace NESHAP.  

	We do not intend to further regulate under the Aerospace NESHAP those
operations at aerospace facilities that are regulated under other
NESHAP.  We have amended the instructions for the ICR to clarify that
reporting is not required for operations regulated under NESHAP other
than the Aerospace NESHAP.  For example, even though the ICR requests
information on electroplating operations, reporting is not required for
chromium electroplating regulated under the Chromium Electroplating
NESHAP.

	The one exception is cleaning operations covered under the Halogenated
Solvent Cleaning NESHAP (40 CFR 60, subpart T).  The initial residual
risk analysis for the aerospace source category indicated that emissions
of certain halogenated solvents are significant drivers in the risk to
exposed populations near some aerospace facilities.  We suspect that
emissions of halogenated solvents may have been reported in the National
Emissions Inventory (NEI) database as total halogenated solvent
emissions from the facility rather than distinguishing the halogenated
solvent emissions from each source category (e.g., Aerospace NESHAP and
Halogenated Solvent Cleaning NESHAP).  For these reasons, it is
important that we have better data regarding the source of the
halogenated solvent emissions before we conduct the residual risk
analysis for both the Aerospace NESHAP and the Halogenated Solvent
Cleaning NESHAP.

	Comment:  The portion of the ICR related to composite materials does
not distinguish between HAP and non-HAP materials.  Requesting
information on non-HAP materials appears to be unnecessary and beyond
the scope of the Aerospace NESHAP.

	Response:  Throughout the ICR we request information on coatings,
solvents, resins, and cleaning materials.  Many of these materials will
contain no HAP.  We are requiring the ICR recipients to report these
non-HAP materials so that we can accurately assess the level of control
of HAP emissions that represents current technology in the industry. 
Control of HAP emissions includes the use of low HAP and non-HAP
materials.  To assess the current level of control, we need to
understand where low HAP and non-HAP materials are available for a
specific operation.  

	Comment:  At large aerospace facilities such as United’s San
Francisco Maintenance Center, wastewater is collected into a single
stream from numerous sources throughout the facility.  Separating out
the streams that originate from Aerospace NESHAP sources is likely
infeasible.

	Response:  We understand the complexity of wastewater systems at large
facilities.  When completing the ICR response forms, provide the
requested information to the best of your ability given the records and
information at your disposal or that are readily available.  You are not
required to perform additional testing for the purposes of this ICR.

	Comment:  United believes that the request for precise latitude and
longitude locations of emission sources is unduly burdensome and
unnecessary.  Instead, United believes that providing an accurate
facility map that identifies the location of emission sources, as well
as sensitive receptors outside the property line, would be adequate.

	Response:  Latitude and longitude coordinates are a necessary input
into the air dispersion models we will be using as part of the residual
risk analysis.  Precise location of emission points in relation to the
facility boundaries is an important factor in the analysis.  Therefore,
the latitude and longitude coordinates are required in your response to
the ICR.  We believe that adequate methods for determining latitude and
longitude coordinates are readily available, and the requirement to
supply this information is not overly burdensome for any one facility.

	Comment:  United made the following suggestions concerning the
information requested for control equipment:

Provide definitions and examples relevant to the aerospace industry for
each type of control device.

Provide a drop down list in the tables for selection of control device
type.  

For fabric filters, include a choice for cartridge filters.  Place
method of cleaning and cleaning cycle frequency on separate lines and
include drop down lists of choices.  Since HEPA filters are frequently
used in the industry, perhaps a separate sheet could be included for
them.

The information requested for filters appears to be unnecessary and much
of it is not available.  United specifically mentioned inlet grain
loading, average stack opacity, and quantity of solid waste collected as
examples.  Each sheet should include an instruction that information not
known can be listed as “unknown” or N/A.

	Response:  We appreciate the commenter’s helpful suggestions
concerning the survey forms.  We will review the forms in light of these
comments and incorporate the suggestions as appropriate.

	Comment:  The notice included an estimate on the number of hours
required to complete the ICR.  United does not believe that the estimate
is accurate.  Due in part to the large number of materials used at
United’s San Francisco facility, along with the need to obtain and
analyze data sheets for materials not currently regulated under the
Aerospace NESHAP, United believes a more accurate estimate of the time
required to complete the ICR is four times the EPA estimate.

	Response:  We have reviewed our estimate of the level of effort
required to complete the ICR in light of this comment and a similar
comment from AIA.  We concur with the commenters that our original
estimate of the labor hours was low and revised our level of effort
estimates.  We used the midpoint of the labor hour estimates provided in
the AIA comments.  These values roughly correlated with United’s
suggestion that our estimate was off by a factor of four.  Our revised
estimate of the total industry burden for the ICR is now 227,700 labor
hours at a cost of $10,956,834.

II.  Aerospace Industries Association

	Comment:  The AIA believes that the level of effort required to respond
to the ICR may be formidable.  To reduce the burden, AIA suggests that
EPA perform a screening analysis be conducted to identify which sources
will have an impact on assessing risk.

	Response:  The history of the residual risk analysis for the aerospace
industry includes several air dispersion modeling efforts, including a
screening analysis.  We found that 35 out of 128 facilities modeled had
a cancer risk greater than 1 in 1 million.  Based on these results, we
believe that the best course of action is to obtain the most current and
accurate emission and emission point data for all aerospace facilities
and perform at least one additional air dispersion modeling analysis
with these data.  

	Comment:  Minor source aerospace facilities may be regulated under
subparts HHHHHH (paint stripping) and WWWWWW (plating and polishing). 
The preambles to these rules state that the decision to include or
exclude operations was determined using the National Emissions Inventory
and the level of urban residual risk.  Thus, EPA has already evaluated
residual risk from these sources and requiring data from minor sources
is unnecessary.

	Response:  We are not requiring area sources to respond to the survey
and have amended the ICR instructions to make this clear.  However,
facilities that have taken enforceable permit restrictions to limit HAP
emissions to less than major source thresholds will have to respond to
the ICR.

	Comment:  Many aerospace facilities are located in local jurisdictions
that are stringently regulated.  AIA suggests that EPA contact
regulatory agencies in these jurisdictions to obtain emissions data and
risk determinations.

	Response:  As discussed previously, we have determined that the best
course of action is to model all aerospace facilities.  Only a limited
number of these facilities have had modeling performed by state or local
authorities, and there may not be consistency between these modeling
efforts.  Therefore, we do not believe obtaining available information
from state and local authorities would achieve the necessary goals of
the residual risk and technology review projects.

	Comment:  AIA believes that much of the information requested in the
ICR is not readily available and may not be pertinent to the current
rulemaking.  AIA recommends that EPA update the database created for the
risk and technology review with the data and subsequent updates that the
industry provided in 2007.

	Response:  As discussed previously, the data gathering effort will be
used for the residual risk and technology review project, among others. 
The diverse data requirements of these efforts dictate the level of
detail we have specified in the ICR.  We have reviewed the ICR in light
of this and similar comments and believe that each question asked is
useful and justified.  

	In response to the comment on the 2007 industry data, we did
incorporate that data into the database used for the residual risk
analysis.  

	Comment:  AIA requests that EPA clarify the specific purposes for which
the ICR data will be used, including specific modeling programs and how
the ICR data will be used within those programs to ensure that results
obtained accurately portray facility operating conditions.  AIA also
suggests that EPA use a screening survey to limit the distribution of
the full ICR to only those facilities that pose a measurable risk
impact.

	Response:  As discussed above, we will be using the data collected with
the ICR to complete the air dispersion modeling for the residual risk
analysis, as well as to assess the current level of emission control
technology used by the industry.  The air dispersion modeling will rely
on the HEM-3 with AERMOD.

	Comments:  AIA suggests that EPA consider the following factors to
assure that the modeling programs accurately reflect operating
conditions and limit the collection in extraneous information:

Establish a minimum threshold for usage of HAP-containing materials.

Establish a minimum vapor pressure for HAP-containing materials.

Remove wastewater treatment operations from further consideration since
these operations primarily deal with metals in solution and have little
or no HAP emissions.

Clarify that laboratories and R&D operations are excluded.

Clarify that emission sources with no HAP emissions and materials that
contain no HAP are excluded from the ICR

Only spray-applied resins should be included for composite operations.

Autoclaves should be exempt from reporting because of low emissions.

Operations related to the manufacture and testing of electronic
components are covered by state regulations or the recently published
area source NESHAP and should be excluded from the ICR.

	Response:  Due to the complexity of factors involve with air dispersion
modeling, we do not believe we can make an accurate assessment of risk
solely from the amount of a HAP-containing material used or the amount
of HAP emissions.  If an accurate estimate of risk could be achieved
from product usage or emissions data, air dispersion modeling would not
be needed.  However, factors such as toxicity, emission point
characteristics, and climatic data affect the risk assessment and
necessitate the need to use modeling programs such as HEM-3.

	Concerning which operations to include or exclude from ICR reporting,
we believe the ICR instructions clearly define which operations to
include in the responses.

	Comment:  AIA believes that the EPA’s burden estimate is
significantly understated.  While the burden may not necessarily be
related to facility size, AIA members estimated the burden to be 150-200
hours for small facilities, 200-400 hours for medium facilities, and
400-500 hours for large facilities.  Additionally, a combination of
in-house and consulting services may be required to complete the
questionnaire.  AIA believes the true labor costs to be in the range of
$150-200 per labor hour.

	Response:  We agree with the commenter.  As stated previously, we have
revised our labor hour level of effort estimates reflecting the
recommendations received from both commenters; we used the midpoint of
the labor hour estimates provided in the AIA comments which roughly
correlate with United’s suggestion that our estimate was off by a
factor of four.  Our revised estimate of the total industry burden for
the ICR is now 227,700 labor hours at a cost of $10,956,834.  However,
we continue to use the labor cost values from the Bureau of Labor
Statistics, National Compensation Survey, Employer Costs for Employee
Compensation Supplementary Tables December 2007.  While labor costs may
vary among facilities, we believe the BLS data accurately portrays labor
costs for the industry as a whole.

	Comment:  Due to the level of effort required to complete the survey,
AIA requests that EPA provide a 90-day response time.

	Response:  We understand that responding to the ICR is a large
undertaking.  However, EPA has strict deadlines for completing this
project and must have responses to the ICR within the timeframe provided
in order to have adequate time to thoroughly and completely analyze the
ICR responses.  In addition, we met with the industry on December 18,
2009 to discuss the specific data needed and made the draft ICR
available to the public on June 22, 2010.  Facilities that know or
suspect that they will be required to respond to the ICR should at their
earliest convenience begin to assess the required data and work with
their suppliers to obtain the data.

	Comment:  In addition to the factors listed above for assuring the
modeling effort reflects actual operating conditions, AIA provided
additional suggestions to reduce the burden of the ICR:

Establish calculation criteria for concentration ranges of HAP
constituents as listed on product data sheets and material safety data
sheets.  

EPA should provide guidance for how to address constituents listed as
proprietary on product data sheets and material safety data sheets.

Form J-10, which requests information on ventilation systems, appears to
be overly burdensome particularly for buildings that do not use or store
HAP-containing materials.

	AIA also provided a listing of issues needing clarification specific to
many of the ICR forms.

	Response:  We appreciate the helpful suggestions for clarifying the ICR
forms.  We will review each of these comments and modify the forms
accordingly.

	We do not believe it is necessary or appropriate for us to provide
definitive guidelines on how to interpret concentration ranges or
proprietary information as reported on product literature.  We urge each
respondent to work with their suppliers to obtain the data needed to
respond to the ICR.

 40 CFR part 63, subpart GG.

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