	SF tc \l2 "SF -83 SUPPORTING STATEMENT 

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Friction Materials Manufacturing (40 CFR part 63, subpart
QQQQQ)(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Friction Materials Manufacturing (40 CFR part 63, subpart
QQQQQ) (Renewal)

1(b)  Short Characterization/Abstract

The National Emissions Standards for Hazardous Air Pollutants (NESHAP)
for Friction Materials Manufacturing (40 CFR part 63, subpart QQQQQ),
were proposed on October 4, 2001, (66 FR 50768) and promulgated on
October 18, 2002 (67 FR 64506).  Respondents are owners or operators of
each new, reconstructed, or existing affected source.  Friction
materials manufacturing facilities manufacture friction material using a
solvent-based process.  Friction material is subsequently used to
manufacture friction products that include, but are not limited to, disc
brake pucks, disc brake pads, brake linings, brake shoes, brake
segments, brake blocks, brake discs, clutch facings, and clutches.  The
NESHAP contains an emission limitation for solvent mixers at friction
materials manufacturing facilities.  Solvent mixers are the affected
source.

A friction materials manufacturing facility is only subject to the
regulation if it is a major source of hazardous air pollutant (HAP)
emissions, and emits or has the potential to emit any single HAP at a
rate of 9.07 megagrams (10 tons) or more per year or any combination of
HAP at a rate of 22.68 megagrams (25 tons) or more per year.  Consistent
with the General Provisions for National Emission Standards for
Hazardous Air Pollutants (NESHAP) for Source Categories (40 CFR part 63,
subpart A), respondents do not include the owner or operator of any
facility that is not a major source of HAP emissions or any facility
that does not operate affected solvent mixers, even if the facility is a
major source.

The friction materials manufacturing NESHAP require respondents to
reduce the total organic HAP emissions from their solvent mixers by
preventing emission of no more than 15 percent (based on a 7-day block
average) of the HAP solvent that is loaded into the solvent mixer. 
Respondents will likely use a solvent recovery system to reduce the
amount of HAP solvent that is emitted.  To show compliance with the HAP
solvent emission limitation, respondents are required to use a weight
measurement system (e.g., floor scale system for measuring weight of
liquid contained in a small tank) to measure and record the weight of
HAP solvent loaded into the solvent mixer and the weight of HAP solvent
recovered for each mix batch.  No performance testing is required. 
However, respondents are required to conduct an initial compliance
demonstration, which consists of measuring and recording the weight of
HAP solvent loaded into each solvent mixer, and the weight of HAP
solvent recovered for each mix batch over the first seven consecutive
days after the compliance date.  Respondents also must maintain records
of specific information needed to determine that the standards are being
achieved and maintained.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They are also required to maintain records of the
occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility, or any period during which the
monitoring system is inoperative. These notifications, reports, and
records are essential in determining compliance, and are required of all
affected facilities subject to NESHAP.  Semiannual reports for periods
of operation during which the emission limitation is exceeded (or
reports certifying that no exceedances have occurred) also are required.

Based on our consultations with industry representatives, there is an
average of 1.75 solvent mixers at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

Approximately four respondents are currently subject to the regulation,
and it is estimated that no additional respondents per year will become
subject to the regulation in the next three years.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any (Terms of Clearance.(

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
In addition, Section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this Act to:

(A) Establish and 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 (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from affected solvent
mixers cause or contribute to air pollution that may reasonably be
anticipated to endanger public health or welfare.  Therefore, the NESHAP
were promulgated for this source category at 40 CFR part 63, subpart
QQQQQ.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility(s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standard are used to inform the Agency
or delegated authority when a source becomes subject to the requirements
of the regulations.  The reviewing authority may then inspect the source
to check if the pollution control devices are properly installed and
operated and leaks are being detected and repaired and the standard is
being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart QQQQQ.

3(a)  Nonduplication

If the subject standards have not been delegated, the information is
sent directly 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 its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agencies can be sent to 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 OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (69 FR 69909) on December 1, 2004.
 No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

For this information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR, and used several
different resources to obtain the most recent data available.  We
accessed the Air Facility System (AFS) database as maintained by the
Office of Compliance.  We reviewed information available from the United
States Census Bureau, and other websites covering friction materials
manufacturing.  We consulted with the EPA(s Office of Air Quality
Planning and Standards, Information Transfer, the Program Integration
Division, Link Testing Laboratories, Incorporated, Mr. Carlos Agudelo,
(313) 933-4900, and Motor & Equipment Manufacturers Association, Ms.
Stephanie G. Brown, (919) 406-8841.

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-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.

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 to the recordkeeping and reporting requirements are
friction materials manufacturing facilities.  The United States Standard
Industrial Classification (SIC) codes for the respondents affected by
the standards, which correspond to the North American Industry
Classification System (NAICS) codes, are listed below for source
category description.

Standard (40 CFR part 63, subpart QQQQQ)	

SIC Codes	

NAICS Codes



Motor Vehicle Brake System Manufacturing	

3714	

336340



All Other Miscellaneous Nonmetallic Mineral Product Manufacturing	

3299	

327999



Mechanical Power Transmission Equipment Manufacturing	

3568	

333613



This table is not intended to be exhaustive, but rather provides a guide
for readers regarding entities likely to be regulated by this action. 
To determine whether your friction materials manufacturing facility is
regulated by this action, you should examine the applicability criteria
in Section 63.9205 of the final rule.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Friction Materials Manufacturing (40 CFR part 63, subpart
QQQQQ) (Renewal).

A source must make the following reports:

Notification Reports	

Standard Citation by Section



Initial notifications (including construction/reconstruction)	

63.9535(a)(b)(c)(d), 

63.05 and 63.09(b) 



Notification of compliance status	

63.9535(e) and 63.09(h)



Performance of sludge test and determine mercury emissions.	

61.54(a), (c), (d), (e)



Reports



Semiannual compliance report on startup, shutdown, and malfunction	

63.9540(b)(4) and (d), 63.10(d)(5)



Semiannual compliance report on no deviations	

63.9540(b)(5) and (6)



Annual report on deviations	

63.9540(c)



A source must keep the following records:

Recordkeeping



Maintain records of all reports and notifications	

63.9550 and 63.10(b)(1)



Maintain records for initial notification and notification of compliance
status	

63.9545(a)(1) and 63.10(b)(xiv)



Maintain records related to startup, shutdown or malfunction	

63.9545(1)(2)



Monitor records showing solvent mixers meeting the emission limitation	

63.9530, 63.9545(b) and 63.10(b)(2)(vi), (x) and (xi)



Electronic Reporting

At the present, respondents are using monitoring equipment that
automatically records parameter data, e.g., temperature, pressure drop,
leaks and spills of mercury, etc.  Although personnel at the affected
facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities	

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate solvent mixer at your iction
material manufacturing facility.



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.



Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources still need
to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

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

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.



Agency Activities



Review notifications and reports, including performance test reports,
and excess emissions reports, required to be submitted by industry.



Audit facility records.



Input, 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 test reports are used by
the Agency to discern a source(s initial capability to comply with the
emission standard, and the operating conditions under which compliance
was achieved. 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 approximately 125,000 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/operator for five years.

5(c)  Small Entity Flexibility

A majority of the respondents are large entities (e.g., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Friction Materials Manufacturing (40 CFR part 63, subpart QQQQQ)
(Renewal).

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 to be 1,296
( Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates:

Managerial	$96.41   ($45.91 + 110%)

Technical	$82.74   ($39.40 + 110%)

Clerical	$42.25   ($20.12 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2004, (Table 2. Civilian Workers, 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.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitors and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs



(A)

Continuous Monitoring 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)



Monitoring Control Device	

$2,139	

0	

$0	

$272	

4	

$1,088



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 operation and maintenance (O&M) costs for this ICR are $1,088.
 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 operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is estimated to be $1,000 (rounded).  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.

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
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $2,387.

This cost is based on the average hourly labor rate as follows:

Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2004
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden - NESHAP for Friction Materials Manufacturing (40 CFR part 63,
subpart QQQQQ) (Renewal).

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

Based on our research for this ICR, approximately four existing sources
are currently subject to the standard.  It is estimated that no
additional sources per year will become subject to the standard 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



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 	

(B)

Number of Existing Respondents	

(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

0	

4	

0	

0	

4



2	

0	

4	

0	

0	

4



3	

0	

4	

0	

0	

4



Average	

	

	

	

	

4



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 four.  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:



Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents 	

(C)

Number of Responses	

(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual Responses 

E=(BxC)+D



Notification of applicability	

0	

1	

N/A	

0



Notification of construction/reconstruction	

0	

1	

N/A	

0



Notification of anticipated startup	

0	

1	

N/A	

0



Notification of actual startup	

0	

1	

N/A	

0



Notification of compliance status	

0	

1	

N/A	

0



Annual report of deviation	

0.6	

1	

N/A	

0.6



Semiannual report with no deviation	

3.4	

2	

N/A	

6.8



Unplanned startup, shutdown, malfunction report.	

0.4	

2	

N/A	

0.8



	

	

	

Total	

8.2



	

	

	

Total Rounded	

8



The number of Total Annual Responses is 8.  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 $103,424.  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, NESHAP for
Friction Materials Manufacturing (40 CFR part 63, subpart QQQQQ)
(Renewal).

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

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i)  Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor costs are $103,424.  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, NESHAP for
Friction Materials Manufacturing (40 CFR part 63, subpart QQQQQ)
(Renewal).  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 162
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $1,000.  This number is shown on the OMB 83-I form in block 14(c),
Total annualized cost requested.  The cost calculations are detailed in
Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 59 labor hours at a cost of $2,387.  See Table 2. 
Annual Agency Burden and Cost, NESHAP for Friction Materials
Manufacturing (40 CFR part 63, subpart QQQQQ) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the number of respondents identified in the active
ICR, however, there is a decrease of 94 hours in the estimated burden
currently identified in the OMB Inventory of Approved ICR Burdens.  The
decrease is attributed to the fact that the renewal ICR reflects that
all four sources are in compliance with the standard and there are no
new sources with reporting requirements.

Because there are no new sources with reporting requirements, no
capital/startup costs are incurred.  The cost that is incurred is for
the operation and maintenance (O&M) associated with this ICR, as
compared with the active ICR currently identified in the OMB inventory.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 162 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 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-2004-0031, 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 Ave., NW, Washington,
DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal 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 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, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number OECA-2004-0031
and OMB Control Number 2060-0481 in any correspondence.					

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

Table 1:  Annual Respondent Burden and Cost - NESHAP for Friction
Materials Manufacturing (CFR part 63, subpart QQQQQ) (Renewal)

	Burden item	

(A)

Technical

Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year b	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours per

year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Total Cost

 per year a



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Acquisition, installation and utilization          of technology and
systems	

54	

1	

54	

0	

0	

0	

0	

$0



4.  Reporting requirements 	

	

	

	

	

	

	

	





  A.  Read Instructions 	

0.5	

1	

0.5	

0	

0	

  0	

0	

$0



  B.  Required Activities	

	

	

	

	

	

	

	





       Startup, shutdown, malfunction plan	

32	

1	

32	

0	

0	

0	

0	

$0



  C.  Create information	

Included in 4B	

	

	

	

	

	





  D.  Gather existing information	

Included in 4B	

	

	

	

	

	





  E.  Write report	

	

	

	

	

	

	

	





       Notification of applicability	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of construction/                          
reconstruction	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of anticipated startup	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of actual startup	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of compliance status	

4	

1	

4	

0	

0	

0	

0	

$0



       Annual report of deviation c	

8	

1	

8	

0.6	

4.8	

0.24	

0.48	

$440.57



       Semiannual report of no deviation d	

8	

2	

16	

3.4	

54.4	

2.72	

5.44	

$4,993.14



       Startup, shutdown, malfunction report e	

8	

2	

16	

0.4	

6.4	

0.32	

0.64	

$587.43



5.  Recordkeeping Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

4	

1	

4	

0	

0	

0	

0	

$0



  B.  Plan activities	

Included in 5E	

	

	

	

	

	





  C.  Implement activities	

Included in 5E	

	

	

	

	

	





  D.  Develop record system	

Included in 5E	

	

	

	

	

	





  E.  Time to enter information	

	

	

	

	

	

	

	





       Records of solvent weight                              
measurements  f	

0.033	

2,600	

85.8	

4	

343.2	

17.16	

34.32	

$31,500.79



       Records of block average solvent                   weight g	

2	

52	

104	

4	

416	

20.8	

41.6	

$38,182.77



       Records of startup, shutdown,                         malfunction
g	

1	

52	

52	

4	

208	

10.4	

20.8	

$19,091.38



       Copies of notifications/reports  h	

0.25	

7	

1.75	

4	

7	

0.35	

0.7	

$642.50



  F.  Time to train personnel i	

20	

1	

20	

4	

80	

4	

8	

$7,342.84



  G.  Time to transmit or disclose                            
information h	

0.25	

7	

1.75	

4	

7	

0.35	

0.7	

$642.50



  H.  Time to audit	

N/A	

	

	

	

	

	

	





Subtotal Labor Burden	

	

	

	

	

1,126.8	

56.34	

112.68	

$103,423.92



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

1,296	

$103,424



Assumptions:

a  This ICR uses the following labor rates:  $96.41 per hour for
Executive, Administrative, and Managerial labor; $82.74 per hour for
Technical labor, and $42.25

per hour for Clerical labor.  These rates are from the United States
Department of Labor, Bureau of Labor Statistics, December 2004, (Table
10. Private industry, by occupational and industry group.(  The rates
are from column 1, (Total compensation.(  The rates have been increased
by 110% to account for the benefit packages available to those employed
by private industry.

b  We have assumed that there are four existing sources, and that no
additional new or reconstructed sources will become subject to the rule
over the next three years.  Within those four existing sources, there is
a total of seven existing solvent mixers for an average of (7/4=1.75)
1.75 mixers per source, with no additional new or reconstructed solvent
mixers expected to be constructed over the three-years of this ICR. 

c  We have assumed that 15 percent of respondents will report deviation
. 

d  We have assumed that 85 percent of respondents will report no
deviation. 

e  It is assumed that 10 percent of respondents will have a startup,
shutdown, or malfunction occur that is not managed according to the
regulation.

f  We have assumed that solvent weights are recorded once per hour (2
minutes [0.033 hr] per record) for 2,600 hours per year.  This is the
industry average solvent mixer annual operating hours.

g  It is assumed that information would be entered once per week for 52
weeks per year.

h  We have assumed that a typical plant transmits one-time notification
of applicability and compliance status; startup, shutdown, and
malfunction plan semiannually;

deviation report once a year; and no deviation report semiannually for a
total of seven times per year. 

i   We have assumed that it will take 20 hours per plant once a year to
train personnel.



Table 2:  Average Annual EPA Burden -  NESHAP for Friction Materials
Manufacturing (CFR part 63, subpart QQQQQ) (Renewal)

	Burden item	

(A)

Technical

Person

Hours Per

Occurrence	

(B)   

Number  of

Occurrences

Per Year	

(C)

Technical

Person Hours Per Plant Per

Year

(C=AxB)	

(D)

Plants Per  Year b	

(E)

Technical Hours 

Per Year

(E=CxD)	

(F)

Management   Hours Per Year

(F=0.05xE)	

(G)

Clerical

Hours Per

Year

(G=0.1xE)	

(H)

Total

Cost, 

Per Yeara





1.  Excess emissions enforcement activities c	

48	

1	

48	

0.2	

9.6	

0.48	

0.96	

$447.56



2.  Review reports      	

	

	

	

	

	

	

	





    Notification of applicability	

2	

1	

2	

0	

0	

0	

0	

$0



    Notification of construction/reconstruction	

2	

1	

2	

0	

0	

0	

0	

$0



    Notification of anticipated startup	

2	

1	

2	

0	

0	

0	

0	

$0



    Notification of actual startup	

2	

1	

2	

0	

0	

0	

0	

$0



    Notification of compliance status	

40	

1	

40	

0	

0	

0	

0	

$0



    Annual report of deviation d	

20	

1	

20	

0.6	

12	

0,6	

1.2 	

$559.45



    Semiannual report of no deviation e	

2	

2	

4	

3.4	

13.6	

0.68	

1.36	

$634.04



    Startup, shutdown, malfunction report f	

20	

2	

40	

0.4	

16	

0.8	

1.6	

$745.94



TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	

	

59	

	

$2,387



Assumptions:

a  This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $56.02 for Managerial (GS-13, Step 5, $35.01 x 1.6), $41.57
for Technical (GS-12, Step 1, $25.98 x 1.6) and $22.50 Clerical (GS-6,
Step 3, $14.06 x 1.6).  These rates are from the Office of Personnel
Management (OPM) (2004 General Schedule( which excludes locality rates
of pay.

b  We have assumed that there are four existing sources, and that no
additional new or reconstructed sources will become subject to the rule
over the next three years. Within those four existing sources, there is
a total of seven existing solvent mixers for an average of (7/4=1.75)
1.75 mixers per source, with no additional new or reconstructed solvent
mixers expected to be constructed over the three-years of this ICR.

c  We have assumed that 5 percent of plants will be involved in excess
emission enforcement activities.

d  We have assumed that 15 percent of respondents will report deviation.


e  We have assumed that 85 percent of respondents will report no
deviation.

f   It is assumed that 10 percent of respondents will have a startup,
shutdown, or malfunction occur that is not managed according to the
regulation.

 PAGE  19 

