1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
MACT
Subpart
II
National
Emission
Standards
For
Shipbuilding
and
Ship
Repair
(
Surface
Coating)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
MACT
Subpart
II
­
National
Emission
Standards
For
Shipbuilding
and
Ship
Repair
(
Surface
Coating)

1(
b)
Short
Characterization/
Abstract
The
Maximum
Achievable
Control
Technology
(
MACT)
for
the
National
Emission
Standards
For
Shipbuilding
and
Ship
Repair
(
Surface
Coating)
were
proposed
on
December
6,

1994
and
promulgated
on
December
15,
1995.
These
standards
apply
to
all
new
and
existing
shipbuilding
and
repair
facilities
that
are
major
sources
of
hazardous
air
pollutants
(
HAP).
The
Clean
Air
Act
(
CAA)
defines
major
source
as
a
source,
or
group
of
sources
located
within
a
contiguous
area
and
under
common
control
that
emits
or
has
the
potential
to
emit,
considering
controls,
10
tons
per
year
or
more
of
any
individual
HAP,
or
25
tons
per
year
or
more
of
any
combination
of
HAP.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63
Subpart
II.

Owners
or
operators
of
shipbuilding
and
ship
repair
facilities
to
which
this
regulation
is
applicable
must
choose
one
of
the
four
compliance
options
described
in
the
final
rule
or
install
and
monitor
a
specific
control
system
to
control
coating
emissions
and
reduce
HAP
emissions
to
the
compliance
level.
The
respondents
would
be
subject
to
sections
of
subpart
A
relating
to
national
2
emission
standards
for
hazardous
air
pollutants.
These
requirements
include
those
associated
with
the
initial
notification
and
the
notification
of
compliance
status
for
the
first
six
months,
and
every
six
months
thereafter.
In
addition,
respondents
would
be
required
to
submit
with
the
initial
notification
an
implementation
plan
that
describes
the
coating
compliance
procedures;
record
keeping
procedures;
and
transfer,
handling,
and
storage
procedures
that
the
source
intends
to
use.

Respondents
choosing
any
of
the
four
compliance
options
described
in
the
final
rule
must
record
the
following:
the
total
volume
of
coating
applied
at
the
source
to
ships;
the
volume
of
each
low­
usage­
exempt
coating
applied;
the
identities
of
the
coatings
used,
their
appropriate
coating
categories,
and
applicable
volatile
organic
hazardous
air
pollutants
(
VOHAP)
limits;

certifications
of
the
as­
supplied
volatile
organic
compounds
(
VOC)
content
of
each
batch
of
coating;
a
determination
of
whether
containers
meet
the
standards;
and
the
results
of
any
Method
24
or
approved
VOHAP
measurement
test
conducted
on
individual
containers
of
coating,
as
applied.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
MACT
surface
coating
rules.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
5
years
following
the
date
of
such
measurements.

Respondents
are
owners
and
operators
of
new
and
existing
shipbuilding
and
ship
repair
facilities
that
emit
hazardous
air
pollutants.
Of
the
598
facilities
that
comprise
the
source
category,
45
facilities
are
expected
to
meet
the
applicability
criteria
defined
in
the
final
rule.
No
new
facilities
are
expected
to
be
constructed
in
the
next
three
years.
The
cost
of
this
ICR
will
be
$
1,195,603.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
3
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

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
or
operator
subject
to
any
requirement
of
this
Act
to
(
A)
establish
and
maintain
such
records,
(
B)
make
such
reports,
(
C)

install,
use,
and
maintain
such
monitoring
equipment
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)

provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
HAP
emissions
from
surface
coating
at
shipbuilding
and
repair
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
MACT
standards
were
promulgated
for
this
source
category
at
40
CFR
Part
63
SUBPART
II.
4
2(
b)
Practical
Utility/
Users
of
the
Data
These
standards
rely
on
the
reduction
of
HAP
emissions
by
using
coatings
which
comply
with
the
volatile
organic
compound
(
VOC)
limits
set
forth
in
this
MACT
standard.
In
some
cases,
the
control
of
emissions
of
HAP
from
surface
coating
at
shipbuilding
and
repair
facilities
also
requires
the
installation
of
properly
designed
equipment,
and
the
operation
and
maintenance
of
that
equipment.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
standard
is
being
met.
The
implementation
plans
from
facilities
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
In
addition,
the
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
record
keeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
MACT
achieve
continuous
compliance
with
the
regulation.
Adequate
monitoring,
record
keeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
record
keeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
record
keeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
II.

If
the
standard
has
not
been
delegated
the
information
is
sent
to
the
appropriate
EPA
Regional
5
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
a
copy
of
the
report
submitted
to
the
State
or
Local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
Standard.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
May
27,
1999.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
EPA
solicits
comments
to:

(
i)
evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
agency,
including
whether
the
information
will
have
practical
utility;

(
ii)
evaluate
the
accuracy
of
the
Agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,
including
the
validity
of
the
methodology
and
assumptions
used;

(
iii)
enhance
the
quality,
utility,
and
clarity
of
the
information
to
be
collected;
and
(
iv)
minimize
the
burden
of
the
collection
of
information
on
those
who
are
to
respond,

including
through
the
use
of
appropriate
automated
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology,
e.
g.,

permitting
electronic
submission
of
responses.

3(
d)
Effects
of
Less
Frequent
Collection
6
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
record
keeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
the
reporting
or
record
keeping
requirements
contained
in
(
40
CFR
Part
63
Subpart
II,
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,

September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
record
keeping
requirements
contained
in
40
CFR
Part
63
Subpart
II
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
7
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
record
keeping
and
reporting
requirements
are
owners
and
operators
of
new
and
existing
shipbuilding
and
ship
repair
facilities
that
are
classified
as
major
sources
(
of
HAP)
under
Section
112
of
the
CAA.
The
primary
SIC
code
for
the
respondents
affected
by
the
rule
is
3731
(
Shipbuilding
and
Repairing).
The
regulation
applies
only
to
shipbuilding
and
ship
repair
operations
affecting
commercial
and
military
vessels;
it
does
not
apply
to
boat
yards
that
only
build
or
repair
pleasure
crafts,
which
the
final
rule
defines
as
any
marine
or
fresh­
water
vessel
that
is
used
by
individuals
for
non­
commercial,
non­
military,
and
recreational
purposes
and
which
is
less
than
20
meters
in
length.

4(
b)
Information
Requested
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
II.
The
two
tables
further
on
in
this
document
specify
the
reporting
and
record
keeping
requirements
of
affected
sources.
Records
are
required
to
be
retained
for
5
Years.
The
first
2
years
of
records
must
be
kept
onsite.

The
respondents
will
have
to
undertake
the
following
activities:

­
Read
instructions(
63.10(
b)(
1));

­
Install,
calibrate,
maintain,
and
operate
control
devices
(
if
control
device
approved
and
used)(
63.10
(
c)
and
(
e));

­
perform
initial
performance
test
(
if
control
device
approved
used)
(
63.10
(
c)
and
(
e));

­
write
the
notifications
and
reports
listed
above
(
63.10
(
c)
and
(
e))
and
(
63.9
(
a)
­(
d));
­
enter
information
required
to
be
recorded
above
(
63.10
(
c)
and
(
e));
8
­
submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information
(
63.6(
e));

­
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information;

­
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
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;

­
transmit,
or
otherwise
disclose
the
information.

­
volume
of
coating
applied/
supplied
coating
(
63.788
(
b)(
2));

­
certification
of
applied/
supplied
coating
(
63.788
(
b)(
2));

­
calculate
maximum
allowable
thinning
ratios
(
63.788
(
b)(
3));

­
calculate
allowable
and
used
volume
of
thinner
(
63.788
(
b)(
3)).

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
information
required
under
40
CFR
Subpart
II:

­
Observes
initial
performance
tests
and
repeat
performance
tests
if
necessary;

­
Reviews
notifications
and
reports,
including
performance
test
reports,
and
9
excess
emissions
reports,
required
to
be
submitted
by
industry;

­
Audits
facility
records;

­
Inputs,
analyze,
and
maintains
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database.

5(
b)
Collection
Methodology
and
Management
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
implementation
plan,
and
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
The
record
keeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant(
s).
The
requirements
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
Although
the
record
keeping
and
10
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.
However,
there
is
a
"
low
usage"
exemption,
which
may
reduce
the
record
keeping
and
reporting
burden
for
some
small
businesses.
This
"
low
usage"
exemption
stipulates
that
the
provisions
of
the
regulation
do
not
apply
to
coatings
used
in
volumes
of
less
than
200
liters
per
year.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
1
below.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
each
of
the
record
keeping
and
reporting
requirements
applicable
to
the
industry.
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
record
keeping
and
reporting
requirements
is
estimated
at
22,149
(
total
from
industry
table)
person­
hours.

These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
MACT
program,
the
11
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry.
The
wage
rates
have
been
loaded
by
adding
110%
overhead.

Executive,
Administrative,
and
Managerial
$
73.90
Technical
$
54.94
Clerical
$
34.42
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital
or
operations
and
maintenance
costs,
unless
a
new
source
gains
the
approval
of
the
Administrator
and
uses
an
alternative
compliance
option
which
includes
the
use
of
a
control
device
for
coatings
operations.
This
is
not
anticipated
in
the
next
3
years.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
This
is
not
applicable
since
there
is
no
continuous
monitoring
required.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.

Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
12
The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
6,711.
This
cost
is
based
on
an
average
wage
of
a
GS10
step
1
employee
rate.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Agency
Burden
(
table
2).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
63
Subpart
II
is
45,
and
these
sources
are
expected
to
meet
the
record
keeping
and
reporting
criteria.
The
total
annual
labor
costs
are
$
1,195,603.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
Table
1.
Estimated
Annual
Burden
and
Total
Capital
and
Start­
Up
Cost
to
Industry
to
Implement
Reporting
and
Record
keeping
Requirements
B
Over
the
Next
Three
Years.

Table
2.
Estimate
of
Annual
Burden
and
Cost
To
The
Federal
Government
to
Reporting
and
Record
keeping
Requirements
B
Over
the
Next
Three
Years.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.

This
burden
a
more
accurate
estimate
of
existing
sources,
and
the
number
of
person­
hours
required
to
respond
to
the
ICR.
In
addition,
cost
burden
increase
is
mostly
due
to
more
accurate
(
higher)
labor
rate
estimates.
The
compliance
date
for
this
regulation
was
over
two
years
ago,

and
therefore
most
facilities
in
this
industry
have
completed
the
initial
implementation
work
required
for
this
ICR.
This
reduces
the
number
of
person­
hours,
industry
wide,
required
to
fulfill
regulatory
requirements
associated
with
this
regulation.

6(
g)
Burden
Statement
13
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,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,

Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1712.03,
and
OMB
control
number
2060­
0330
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
