SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
part
63,
subpart
GG)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
part
63,
subpart
GG).
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
aerospace
manufacturing
and
rework
facilities
published
at
40
CFR
Part
63,
Subpart
GG
were
proposed
on
June
6,
1994,
and
promulgated
on
September
1,
1995.
These
regulations
apply
to
existing
and
new
aerospace
manufacturing
and
rework
facilities
where
the
total
Hazardous
Air
Pollutants
(
HAPs)
emitted
are
greater
than
or
equal
to
10
tons
per
year
of
any
one
HAP;
or
where
the
total
HAPs
emitted
are
greater
than
or
equal
to
25
tons
per
year
of
any
combination
of
HAPs.
New
facilities
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
the
proposal.
Operations
covered
include:
cleaning,
primer
and
top
coat
application,
depainting,
chemical
milling
maskant
application,
and
handling
and
storage
of
waste.
This
information
is
being
collected
to
ensure
compliance
with
40
CFR
part
63,
subpart
GG.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance
and
are
required
of
all
sources
subject
to
NESHAP
standards.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
documents,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
notifications,
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Approximately
136
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.

The
active
(
previous)
Information
Collection
Request
(
ICR)
had
the
following
Terms
of
Clearance
(
TOC):
2
This
collection
is
approved
for
three
years.
OMB
notes
that
EPA
has
revised
its
burden
estimate
for
this
collection
substantially
in
response
to
comments
from
the
public.
Prior
to
resubmitting
the
collection
to
OMB
for
revision
or
renewal,
EPA
should
review
the
current
burden
estimate
in
consultation
with
the
regulated
entities.
EPA
should
also
evaluate
whether
it
is
possible
to
streamline
the
collection
in
order
to
reduce
burden
on
regulated
entities,
and
if
so,
undertake
any
needed
rulemaking
to
accomplish
this
objective.

EPA
has
addressed
each
item
of
concern
in
the
TOC
by
consulting
the
Aerospace
Industries
Association
to
identify
any
need
for
further
adjustment
of
the
burden
estimate,
and
by
examining
the
rule
to
evaluate
whether
it
would
be
possible
to
streamline
the
collection
in
order
to
reduce
burden
on
regulated
entities.
Consultation
with
the
Aerospace
Industries
Association
revealed
that
the
significant
increase
in
burden
due
to
personnel
training
shown
in
the
previous
ICR
was
overestimated
for
that
activity.
This
is
due
to
the
limited
need
for
extensive
retraining
in
successive
years
after
initial
coating
application
training.
Table
1,
Annual
Respondent
Burden
and
Cost,
has,
therefore,
been
revised
to
reflect
a
decrease
in
annual
per
person
training
burden.
EPA
also
examined
whether
it
would
be
possible
to
streamline
the
collection
in
order
to
reduce
burden
on
regulated
entities,
and
determined
that
the
information
collected
is
the
minimum
necessary
to
ensure
compliance
with
applicable
regulations.
Therefore,
no
additional
rulemaking
was
undertaken.

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,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
3
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
hazardous
air
pollutant
(
HAP)
emissions
from
aerospace
manufacturing
and
rework
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
for
this
source
category
were
promulgated
at
40
CFR
part
63,
subpart
GG.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
aerospace
manufacturing
and
rework
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
aerospace
manufacturing
and
rework
facilities
are
the
result
of
operation
of
the
affected
facilities.
These
standards
rely
on
the
capture
and/
or
reduction
of
HAP
emissions
by
control
technology,
and
by
the
use
of
work
practices
which
minimize
emissions.
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
appropriate
pollution
control
devices
are
properly
installed
and
operated;
compliant
coatings
and
solvents
are
being
used;
and
to
ensure
work
practices
are
being
adhered
to.
Performance
test
reports
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.
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,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
on
an
on­
going
basis
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
also
is
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
part
63,
subpart
GG.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
4
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
Office
of
Management
and
Budget
(
OMB)

An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
68
FR
62289)
on
November
3,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
EPA
consulted
Bob
Peters
of
the
Aerospace
Industries
Association
(
703­
358­
1055)
to
obtain
information
on
the
industry
and
associated
burden
for
this
ICR.
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
also
conducted
a
review
of
the
industry
during
initiation
of
the
Aerospace
Manufacturing
and
Rework
Facilities
Residual
Risk
Assessment.
Results
from
that
activity
were
used
in
preparation
of
this
ICR.

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

3(
e)
General
Guidelines
The
reporting
and
recordkeeping
requirements
for
this
ICR
are
in
accordance
with
the
regulations
established
by
OMB
at
5
CFR
1320.5.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.
5
3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
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
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
aerospace
manufacturing
and
rework
facilities.
An
aerospace
manufacturing
or
rework
facility
is
defined
as
a
facility
that
produces
an
aerospace
vehicle
or
component,
or
a
facility
that
reworks
or
repairs
these
vehicles
or
components.
Aerospace
operations
at
any
facility
that
conducts
both
aerospace
and
non­
aerospace
work
would
be
subject
to
the
final
standards,
regardless
of
the
relative
proportion
of
aerospace
and
non­
aerospace
work
at
the
facility.
However,
only
the
aerospace
portion
of
the
work
is
covered
by
the
final
rule
(
except
for
use
of
cleaning
solvents).

Standard
SIC
Codes
NAICS
Codes
40
CFR
part
63,
subpart
GG
3720
Aircraft
and
Parts
3721
336411
Aircraft
3724
336412
Aircraft
Engines
and
Engine
Parts
3728
332912,
336411,
336413
Aircraft
Parts
and
Equipment
3760
Guided
Missiles,
Space
Vehicles,
and
Parts
3761
336414
Guided
Missiles
and
Space
Vehicles
3764
336415
Space
Propulsion
Units
and
Parts
6
3769
336419
Space
Vehicle
Equipment
4581
48819
Airports,
Flying
Fields,
and
Services
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
part
63,
subpart
GG.

A
source
must
make
the
following
reports:

Notification
Reports
Requirement
Regulation
reference
General
provisions
reference
!
Reports
of
startups,
shutdowns,
malfunctions,
construction,
and
modification
63.743(
a)(
2)
63.743(
a)(
3)
63.753(
a)
63.6(
e)
63.5(
d)
63.10(
d)(
5)

!
Notification
and
report
of
performance
tests
and
results
63.753(
a)
63.7(
b)
63.7(
g)(
1)
63.9(
e)
63.10(
d)(
2)

!
Notification
and
report
of
physical
and
operational
changes
63.743(
a)(
2)
63.753(
a)
63.5(
b)(
6)

!
Notification
and
report
of
production
capacity
63.753(
a)
63.9(
b)(
2)

!
Notification
and
report
of
compliance
status
63.753(
a)
63.9(
h)

!
Report
of
startup,
shutdown,
malfunction
plan
63.743(
b)
63.753(
a)
63.10(
a)
63.10(
d)(
5)

!
Notification
and
report
for
waiver
applications
63.753(
a)
63.7(
h)(
3)
7
!
Semiannual
report
63.753(
b)
63.753(
c)(
1)
63.753(
d)(
1)
63.753(
d)(
3)
63.753(
e)
63.6(
e)
63.10(
d)(
5)
63.10(
e)(
3)

!
Annual
report
63.753(
c)(
2)
63.753(
d)(
2)

A
source
must
keep
the
following
records:

Recordkeeping
!
5­
year
retention
of
records
63.752(
a)
63.10(
b)(
1)

!
Records
of
daily
and
monthly
inspections
63.743(
a)(
3)
63.752(
a)
63.6(
e)(
3)
63.10(
b)(
2)

!
Emission
testing
63.752(
a)
63.10(
b)(
2)

!
Facility
operation
and
maintenance
including
startups,
shutdowns,
malfunctions,
construction
and
modification
63.743(
a)(
2)
63.743(
a)(
3)
63.743(
b)
63.752
63.5(
b)
63.6(
e)

!
Cleaning
solvents,
all
information
records
63.752(
b)(
1)

!
Cleaning
solvents,
approved
composition
and
vapor
pressure,
solvent
usage
records
63.752(
b)(
2)

!
Cleaning
solvents,
non­
approved
composition,
approved
vapor
pressure,
solvent
usage
records
63.752(
b)(
3)

!
Cleaning
solvents,
usage
log
for
exempt
processes
63.752(
b)(
4)

!
Cleaning
solvents,
log
of
spray
gun
cleaner
leaks
63.752(
b)(
5)

!
Primers/
topcoats/
maskants:
Records
using
compliant
coatings
without
averaging
63.752(
c)(
1)
63.752(
c)(
2)
63.752(
c)(
3)
63.752(
f)(
1)

!
Primers/
topcoats/
maskants:
Records
using
averaging
63.752(
c)(
1)
63.752(
c)(
4)
63.752(
f)(
2)
8
Recordkeeping
!
Primers/
topcoats/
maskants:
Records
using
control
devices
63.752(
c)(
1)
63.752(
c)(
5)
63.752(
c)(
6)
63.752(
d)
63.752(
f)(
3)
63.752(
f)(
4)

!
Chemical
strippers,
records
and
parts
removed
63.752(
e)(
1)
63.752(
e)(
4)

!
Chemical
strippers,
records
using
control
devices
63.752(
e)(
2)
63.752(
e)(
3)

!
Depainting
equipment
malfunction
log
63.752(
e)(
5)

!
Annual
exempt
chemical
stripper
usage
log
and
reworked
airplane
log
for
spot
stripping
and
decal
removal
63.752(
e)(
6)

!
Depainting
control
device
maintenance
log
63.752(
e)(
7)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
inlet
and
outlet
concentrations
when
determining
percent
efficiency.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10%
of
the
respondents
use
electronic
reporting.

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
compliance
monitoring
system
(
CMS)
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber.

Perform
initial
performance
test,
Reference
Method
1,
1A,
2,
2A,
2C,
2D,
3,
4,
18,
24,
25A,
40,
301,
or
319
as
applicable,
and
repeat
performance
tests
if
necessary.
9
Respondent
Activities
Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

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

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.

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
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
excess
emissions
reports,
startup,
shutdown,
malfunction
plan,
and
quality
control
plan
for
CMS
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
10
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
Subpart
and
the
specific
process
equipment
and
pollutant.
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
recordkeeping
and
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.

Low­
volume
use
of
primers,
topcoats,
and
chemical
milling
maskants
which
do
not
exceed
50
gallons
(
189
liters)
per
year
per
formulation,
with
a
combined
annual
total
of
all
three
not
exceeding
200
gallons
(
757
liters)
are
exempt
from
any
information
collection
requirements
presented
by
this
regulation
for
primer,
topcoat,
and
chemical
milling
maskant
operations.
This
significantly
reduces
the
burden
on
small
businesses
which
meet
this
low
usage
threshold.

In
addition,
the
majority
of
small
businesses
selected
within
the
context
of
the
Aerospace
NESHAP
are
general
aviation
facilities.
Only
a
small
number
of
general
aviation
facilities
are
considered
major
sources
and,
therefore,
subject
to
the
NESHAP
information
collection
requirements.
The
March
1998
amendment
resulted
in
a
significant
reduction
of
general
aviation
monitoring
requirements
for
their
coatings
operations
and
pumpless
waterwash
systems.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
part
63,
subpart
GG).
11
6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
to
be
141,645
hours
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
review
and
discussions
with
the
industry
during
development
of
the
rule,
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
information
gathered
during
consultations
described
in
Section
3(
c)
of
this
ICR.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
This
section
covers
the
costs
associated
with
all
types
of
continuous
monitoring
equipment
[
e.
g.,
continuous
emissions
monitoring
systems
(
CEMS)
and
continuous
parameter
monitors].
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
subject
standards
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
12
13
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor(
s)
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startup
Cost
for
One
Respondent
(
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)

CEM
$
14,000
0
0
$
1,000
136
$
136,000
The
total
Capital/
Startup
costs
for
this
ICR
are
$
0.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
136,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
Capital/
Startup
costs,
and
the
annual
O&
M
costs.
The
average
annual
cost
for
Capital/
Startup
and
O&
M
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
136,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.
The
continuous
monitoring
costs
that
are
included
in
this
section
consist
only
of
those
capital/
start­
up
and
O&
M
costs
that
a
source
incurs
as
a
result
of
the
standard.
Some
continuous
monitoring
costs
may
not
be
included
in
this
section.
For
instance,
if
a
particular
industry
typically
utilizes
a
control
device
that
must
have
a
continuous
monitor
(
e.
g.,
temperature,
pressure
drop,
etc.)
to
function
properly,
and
the
recordation
of
additional
measurements
beyond
the
minimum
are
required
by
the
standard,
then
there
is
no
capital/
startup
or
O&
M
cost,
but
there
is
a
labor
cost
to
record
the
additional
readings.
Such
a
cost
would
not
appear
in
this
section,
but
in
the
industry
burden
Section
6(
d)
below.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
and
reports
maintained
by
the
respondents,
periodic
evaluation
of
sources
of
emissions,
and
the
analysis,
publication
and
distribution
of
collected
information.
14
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
170,809
[
see
Table
2
in
Section
6(
e)].
This
cost
is
based
upon
the
following
labor
breakdown:

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
there
are
approximately
136
existing
sources
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Year
(
A)
Number
of
New
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
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
0
136
0
0
136
2
0
136
0
0
136
3
0
136
0
0
136
Average
0
136
0
0
136
To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
136.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:
15
Total
Annual
Responses
(
A)
Number
of
New
Respondents
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)+
F
0
7
136
4
0
544
The
number
of
Total
Annual
Responses
is
544.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
8,960,770.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost.

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
136,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
versus
O&
M
Costs.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
appear
in
Table
2
and
Table
1,
respectively.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
297
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
reduction
in
annual
burden
due
to
an
improved
estimate
of
the
number
of
facilities
and
a
decrease
in
annual
per
person
training
burden.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
297
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
16
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's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0146,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0146
and
OMB
Control
Number
2060­
0314
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
1
Table
1.
Summary
of
Annual
Respondent
Burden
and
Cost
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
Part
63,
Subpart
GG)

Burden
Item
Total
hours
per
year
Annual
costs
in
dollars
(
rounded)

1a.
Cleaning
49,299
$
3,118,743
1b.
Coating
Application
91,439
$
5,784,550
1c.
Depainting
907
$
57,477
Total
Burden
and
Cost
141,645
$
8,960,770
2
Table
1a.
Annual
Respondent
Burden
and
Cost
For
Cleaning
Operations
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
Part
63,
Subpart
GG)

Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
1.
Applications
Not
Applicable
2.
Survey
and
studies
Not
Applicable
3.
Reporting
requirements
A.
Read
instructions
1
1
1
136
136
7
14
$
9,928.41
B.
Required
activities
Not
Applicable
C.
Create
information
See
3E
and
4C
D.
Gather
existing
information
See
3E
and
4C
E.
Write
report
­­
Notification
of
construction/

reconstructionb
2
1
2
0
0
0
0
0
­­
Notification
of
physical
and
operational
changesc
8
1
8
7
56
3
6
$
4,108.45
­­
Notification
of
actual
startupb
2
1
2
0
0
0
0
0
­­
Notification
of
change
in
production
capacityb
2
1
2
0
0
0
0
0
­­
Compliance
status
information
report
20
1
20
136
2,720
136
272
$
197,878.64
­­
Waiver
applicationd
4
1
4
14
56
3
6
$
4,108.45
­­
Startup,
shutdown,
malfunction
plane
4
1
4
136
544
27
54
$
39,541.25
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
3
­­
Preparation
of
site­
specific
test
plan
Not
Applicable
­­
Notification
of
initial
performance
test
Not
Applicable
­­
Report
of
initial
test
Not
Applicable
­­
Startup,
shutdown,
malfunction
reportf
2
1
2
27
54
3
5
$
3,940.54
­­
Semiannual
report
­­
Includes
report
of
periods
of
noncomplianceg
12
2
24
109
2,616
131
262
$
190,347.17
4.
Record
keeping
requirements
A.
Read
instructions
See
3A
B.
Plan
activities
4
1
4
136
544
27
54
$
39,541.25
C.
Implement
activitiesh
­­
Solvent
information
records
4
2
8
136
1,088
55
109
$
79,215.24
­­
Approved
composition
solvent
records
(
demonstrating
compliance)
4
1
4
41
164
8
16
$
11,896.44
­­
Non­
approved
list
solvent
usage
records
1
12
12
122
1,464
73
146
$
106,470.79
­­
Solvent
usage
log
for
exempt
processes
0.5
12
6
95
570
29
57
$
41,513.76
­­
Log
of
gun
cleaner
leaks
1
6
6
27
162
8
16
$
11,768.18
D.
Develop
record
systemi
20
1
20
136
2,720
136
272
$
197,878.64
E.
Time
to
enter/
maintain
information
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
4
­­
Records
of
startup,
shutdown,

malfunction,
etc.
f
2
1
2
27
54
3
5
$
3,940.54
­­
Records
of
all
measurements
and
information
required
by
standard
See
4C
F.
Time
to
train
personnel
4
50
200
136
27,200
1,360
2,720
$
1,978,786.40
G.
Time
for
audits
20
1
20
136
2,720
136
272
$
197,878.64
H.
Total
Burden
(
hrs)
and
Costs
42,868
2,145
4,286
$
3,118,742.79
49,299
aThis
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

bAssumes
no
net
growth
for
the
industry.

cAssumption
based
on
5
percent
of
total
existing
facilities.

dAssumes
10
percent
of
the
total
existing
facility
population
will
request
a
waiver.

eBased
on
number
of
facilities
with
add­
on
control
systems
that
require
the
development
of
inspection
and
maintenance
and
startup,
shutdown,
malfunction
plan.
Assumes
100
percent
will
have
enclosed
gun
cleaners.

fAssumes
20
percent
of
facilities
with
add­
on
control
system
will
have
a
malfunction.

gAssumes
that
80
percent
of
facilities
will
have
excess
emissions
or
will
change
their
process
in
some
way.

hSee
regulation
for
details.
Assumes
30
percent
of
facilities
will
use
approved
list
solvents.
Assumes
90
percent
of
facilities
will
use
some
solvents
not
on
the
approved
list.
Assumes
70
percent
of
the
facilities
will
use
some
solvents
for
exempt
processes.
Assumes
20
percent
of
facilities
will
have
a
leak
in
their
enclosed
gun
cleaner.

iAll
facilities
will
need
to
develop
a
record
keeping
system.
5
Table
1b.
Annual
Respondent
Burden
and
Cost
For
Coating
Operations
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
Part
63,
Subpart
GG)

Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
1.
Applications
Not
Applicable
2.
Survey
and
studies
Not
Applicable
3.
Reporting
requirements
A.
Read
instructions
1
1
1
136
136
7
14
$
9,928.41
B.
Required
activities
­­
Initial
performance
testb
280
1
280
4
1,120
56
112
$
81,479.44
­­
Repeat
performance
testc
280
1
280
1
280
14
28
$
20,369.86
C.
Create
information
See
3E
and
4C
D.
Gather
existing
information
See
3E
and
4C
E.
Write
report
­­
Notification
of
construction/

reconstructiond
2
1
2
0
0
0
0
0
­­
Notification
of
physical
and
operational
changese
8
1
8
7
56
3
6
$
4,108.45
E.
Write
report
continued
­­
Notification
of
actual
startupd
2
1
2
0
0
0
0
0
­­
Notification
of
change
in
production
capacityd
2
1
2
0
0
0
0
0
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
6
­­
Compliance
status
information
report
10
1
10
136
1,360
68
136
$
98,939.32
­­
Waiver
applicationf
4
1
4
14
56
3
6
$
4,108.45
­­
Startup,
shutdown,

malfunction
plang
4
1
4
41
164
8
16
$
11,896.44
­­
Preparation
of
site­
specific
test
plan
Included
in
3B
­­
Notification
of
initial
performanceb
2
1
2
4
8
1
1
$
645.78
­­
Report
of
initial
test
Included
in
3B
­­
Startup,
shutdown,

malfunction
reporth
4
1
4
27
108
6
11
$
7,920.73
­­
Semiannual
report
­­
Includes
report
of
periods
of
noncompliancei
11
2
22
109
2,398
120
240
$
174,470.54
4.
Record
keeping
requirements
A.
Read
instructions
See
3A
B.
Plan
activities
4
2
8
136
1,088
55
109
$
79,215.24
C.
Implement
activitiesj
­­
Compliant
coating
records
1
12
12
136
1,632
82
163
$
118,756.49
­­
Daily
records
of
weighted
average
massk
1
250
250
14
3,500
175
350
$
254,623.25
­­
Control
device
maintenance
or
rolling
material
balance
log
(
organics)
0.5
250
125
4
500
25
50
$
36,374.75
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
7
C.
Implement
activities
(
continued)
j
­­
Control
device
maintenance
log
(
inorganics)
0.25
250
63
136
8,568
429
857
$
623,381.50
D.
Develop
record
systeml
10
1
10
136
1,360
68
136
$
98,939.32
E.
Time
to
enter/
maintain
information
­­
Records
of
startup,
shutdown,

malfunction,
etc.
h
2
1
2
27
54
3
5
$
3,940.54
­­
Records
of
all
measurements
and
information
required
bystandard
See
4C
F.
Time
to
train
personnel
8
50
400
136
54,400
2,720
5,440
$
3,957,572.80
G.
Time
for
audits
20
1
20
136
2,720
136
272
$
197,878.64
H.
Total
Burden
(
hrs)
and
Costs
79,508
3,979
7,952
$
5,784,549.95
91,439
aThis
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

bAssumes
no
net
growth
for
the
industry.

bSee
Chrome
NESHAP.
Assumes
10
percent
of
facilities
will
use
add­
on
control
equipment
for
maskant
application
(
10%
of
40).

cSee
Chrome
NESHAP.
Assumes
20
percent
of
facilities
with
add­
on
control
equipment
will
repeat
performance
test
(
20%
of
10%
of
40).

dAssumes
no
net
growth
for
the
industry.

eAssumption
based
on
5
percent
of
total
existing
facilities.

fAssumes
10
percent
of
the
total
existing
facility
population
will
request
a
waiver.

gBased
on
number
of
facilities
with
add­
on
control
systems
that
require
the
development
of
inspection
and
maintenance
and
startup,
shutdown,
malfunction
plan.
Assumes
100
percent
will
have
add­
on
control
equipment
including
particulate
filters
for
coating
application.
Assumes
70
percent
will
operate
particulate
systems
according
to
manufacturer's
specifications
8
and
that
only
30
percent
will
be
required
to
submit
operational
plans
due
to
deviations
from
manufacturer's
specifications.

hAssumes
20
percent
of
facilities
with
add­
on
control
system
(
including
particulate
filters)
will
have
a
malfunction.

iAssumes
that
80
percent
of
facilities
will
have
excess
emissions
or
will
change
their
process
in
some
way.

jSee
regulation
for
details.
Assumes
10
percent
of
facilities
will
average
coatings.
Assumes
10
percent
will
use
add­
on
control
equipment
for
maskant
application.
Assumes
100
percent
of
facilities
will
use
particulate
filters
for
coating
application.

kThe
final
rule
requires
monthly
records.
Daily
averaging
was
included
in
the
cost
analysis
because
90
percent
of
the
industry
is
located
in
nonattainment
areas
and
will
be
required
to
use
daily
averaging
by
the
permitting
agency.

lAll
facilities
will
need
to
develop
a
record
keeping
system.

Table
1c.
Annual
Respondent
Burden
and
Cost
For
Depainting
Operations
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
Part
63,
Subpart
GG)

Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)

Clerical
person
hours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
1.
Applications
Not
Applicable
2.
Survey
and
studies
Not
Applicable
3.
Reporting
requirements
A.
Read
instructions
1
1
1
5
5
1
1
$
453.39
B.
Required
activities
­­
Initial
performance
testb
280
1
280
0
0
0
0
0
­­
Repeat
performance
testc
280
1
280
0
0
0
0
0
C.
Create
information
See
3E
and
4C
D.
Gather
existing
information
See
3E
and
4C
E.
Write
report
­­
Notification
of
construction
reconstructiond
2
1
2
0
0
0
0
0
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)

Clerical
person
hours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
9
­­
Notification
of
physical
and
operational
changese
8
1
8
0
0
0
0
0
E.
Write
report
(
continued)

­­
Notification
of
actual
startupd
2
1
2
0
0
0
0
0
­­
Notification
of
change
in
production
capacityd
2
1
2
0
0
0
0
0
­­
Compliance
status
information
report
10
1
10
5
50
3
5
$
3,684.02
­­
Waiver
applicationf
4
1
4
0
0
0
0
0
­­
Startup,
shutdown,

malfunction
plang
5
1
5
0
0
0
0
0
­­
Preparation
of
site­
specific
test
plan
NA
­­
Notification
of
initial
performance
test
b
2
1
2
0
0
0
0
0
­­
Report
of
initial
test
Included
in
3B
­­
Startup,
shutdown,

malfunction
reporth
4
1
4
0
0
0
0
0
­­
Semiannual
report
­­
Includes
report
of
periods
of
noncompliancei
12
2
24
4
96
5
10
$
7,018.43
4.
Record
keeping
requirements
A.
Read
instructions
See
3A
B.
Plan
activities
4
1
4
5
20
1
2
$
1,454.99
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)

Clerical
person
hours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
10
C.
Implement
activitiesj
­­
Chemical
stripper
records
(
demonstrating
compliance)
8
1
8
4
32
2
3
$
2,357.29
­­
Chemical
stripper
usage
log
1
12
12
4
48
3
5
$
3,555.76
­­
Depainting
equipment
malfunction
log
4
3
12
2
24
1
2
$
1,711.51
­­
Exempt
stripper
usage
log
and
reworked
airplane
log
for
spot
stripping
and
decal
removal
1
12
12
5
60
3
6
$
4,364.97
­­
Record
of
parts
removed
for
parts
depainting
8
2
16
5
80
4
8
$
5,819.96
­­
Control
device
maintenance
log
0.5
250
125
2
250
13
25
$
18,233.92
D.
Develop
record
systemk
10
1
10
5
50
3
5
$
3,684.02
E.
Time
to
enter/
maintain
infor
mation
­­
Records
of
startup,

shutdown
malfunction,
etc.
h
2
1
2
0
0
0
0
0
­­
Records
of
all
measurements
and
information
required
by
standard
See
4C
F.
Time
to
train
personnel
4
1
4
5
20
1
2
$
1,454.99
G.
Time
for
audits
10
1
10
5
50
3
5
$
3,684.02
H.
Total
Burden
(
hrs)
and
Costs
785
43
79
$
57,477.27
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Person­
hours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
E
x
0.05)
(
G)

Clerical
person
hours
per
year
(
E
x
0.1)
(
H)

Annual
costs
in
dollars
11
907
aThis
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

bAssumes
no
net
growth
for
the
industry.

bAssumes
1
percent
of
the
total
existing
facilities
will
use
add­
on
control
equipment
for
HAP­
containing
chemical
stripper
usage
(
70%
of
5).

cAssumes
20
percent
of
facilities
with
add­
on
control
equipment
will
repeat
performance
test
(
20%
of
1%
of
5).

dAssumes
no
net
growth
for
the
industry.

eAssumption
based
on
5
percent
of
total
existing
facilities.
(
Total
facilities
include
only
the
96
rework
facilities.)

fAssumes
10
percent
of
the
total
existing
facility
population
will
request
a
waiver.

gBased
on
number
of
facilities
with
add­
on
control
systems
that
require
the
development
of
inspection
and
maintenance
and
startup,
shutdown,
malfunction
plan.
Assumes
15
percent
will
use
blasting
equipment
that
must
have
add­
on
control
equipment.
Assumes
29
percent
of
blasting
operations
will
operate
particulate
control
systems
according
to
manufacturer's
specifications
and
that
only
30
percent
will
be
required
to
submit
operational
plans
due
to
deviations
from
manufacturers
specifications.
Also
assumes
1
percent
of
all
facilities
will
use
HAP­
containing
chemical
strippers
with
emissions
control
systems
and
70
percent
will
use
non­
HAP
chemical
strippers
which
do
not
require
add­
on
control
equipment.

hAssumes
20
percent
of
facilities
with
add­
on
control
system
will
have
a
malfunction
(
20%
of
30%).

iAssumes
that
80
percent
of
facilities
will
have
excess
emissions
or
will
change
their
process
in
some
way.

jSee
regulation
for
details.
Assumes
1
percent
of
facilities
will
use
HAP­
containing
chemical
strippers
as
the
primary
stripping
technique.
Assumes
29
percent
of
facilities
will
use
media
blasting
equipment.
Assumes
70
percent
of
facilities
will
use
non­
HAP
chemical
strippers.
Assumes
100
percent
of
the
facilities
will
use
some
HAP
stripper
for
exempt
processes.

kAll
facilities
will
need
to
develop
a
record
keeping
system.
1
Table
2:
Annual
Agency
Burden
and
Cost
NESHAP
for
Aerospace
Manufacturing
and
Rework
Facilities
(
40
CFR
Part
63,
Subpart
GG)

Burden
Item
(
A)

EPA
hours
per
occurrence
(
B)
Respondents
per
yra
(
C)
Technical
person­
hours
per
year
(
C
=
A
x
B)
(
D)
Management
personhours
per
year
(
C
x
0.05)
(
E)

Clerical
personhours
per
year
(
C
x
0.1)
(
F)

Annual
costs
in
dollars
1.
Initial
performance
testc
80
0
0
0
0
0
2.
Repeat
performance
test
­­
Retesting
preparationd
16
1
16
1
2
$
727.82
­­
Retestinge
80
0
0
0
0
0
3.
Report
review
­­
Notification
of
construction/

reconstructionf
2
0
0
0
0
0
­­
Notification
of
physical
or
operational
changesa
2
14
28
2
3
$
1,276.30
­­
Notification
of
anticipated
startupf
2
0
0
0
0
0
­­
Notification
of
actual
startupf
2
0
0
0
0
0
­­
Notification
of
changes
in
production
capacityf
2
0
0
0
0
0
­­
Compliance
status
information
reporta
6
279
1,674
89
167
$
74,413.30
Burden
Item
(
A)

EPA
hours
per
occurrence
(
B)
Respondents
per
yra
(
C)
Technical
person­
hours
per
year
(
C
=
A
x
B)
(
D)
Management
personhours
per
year
(
C
x
0.05)
(
E)

Clerical
personhours
per
year
(
C
x
0.1)
(
F)

Annual
costs
in
dollars
2
­­
Waiver
applicationa
6
28
168
8
17
$
7,423.54
­­
Review
of
startup,
shutdown,

malfunction
plana
6
177
1,062
53
106
$
47,025.32
­­
Review
of
site
specific
test
plana
N/
A
0
0
0
0
0
­­
Notification
of
initial
performance
test
a
2
4
8
1
1
$
390.52
4.
Report
review
(
continued)

­­
Report
of
initial
testa
8
0
0
0
0
0
­­
Review
of
startup,
shutdown,

malfunction
reports
a
4
55
220
11
22
$
9,743.58
­­
Review
of
semiannual
reportsa
3
222
666
39
67
$
29,808.38
Total
Burden
(
hrs)
and
Costs
3,842
204
385
$
170,808.76
4,431
aData
for
Respondents
per
year
taken
from
Table
1a
through
1c
bCosts
are
based
upon
the
following
per­
hour
labor
breakdown:
Managerial,
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6),
Technical,
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6),
and
Clerical,
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6).

cAssumes
10
percent
of
the
performance
tests
are
attended
by
EPA
personnel.
(
10%
of
4)

dAssumes
20
percent
fail
the
initial
performance
test
and
retest.(
20%
of
4)

eAssumes
10
percent
of
retests
are
attended
by
EPA
personnel.

fAssumes
no
net
growth
for
the
industry.
