SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart
HHHHH) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Miscellaneous Coating Manufacturing (40 CFR Part 63, Subpart
HHHHH) (Renewal), EPA ICR Number 2115.03, OMB Control Number 2060-0535

1(b)  Short Characterization/Abstract

	Respondents are owners or operators of new and existing facilities that
manufacture a miscellaneous coating and are either located at, or are
part of, major sources of hazardous air pollutant (HAP) emissions. 
“Major source” means that the process equipment used to manufacture
the miscellaneous coatings and any other operations or equipment at the
facility emit, or have the potential to emit, 10 tons per year or more
of a single HAP or 25 tons per year or more of any combination of HAP. 
A facility is subject to the National Emission Standards for Hazardous
Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing if it
meets the following criteria:

1.  Manufactures coatings, including inks, paints, or adhesives
described by Standard Industrial Classification (SIC) codes 285, or 289,
or North American Industrial Classification System (NAICS) codes 3255,
or 3259;

	2.  Processes, uses, or produces HAP;

	3.  Not part of an affected source under another subpart of 40 CFR part
63.

	An average of approximately 132 existing miscellaneous coating
manufacturing respondents will be subject to the standard over the next
three years.  The number of respondents is expected to grow about two
percent over the next three years (0.67 percent per year) which adds
approximately one respondent per year to the inventory.  An annual
average of approximately 133 respondents would be subject to the
standard over the three-year period covered by this ICR.

Owners or operators of miscellaneous coating manufacturing facilities
subject to the standard must choose one of the compliance options
described in the standard, or install and monitor control systems that
reduce HAP emissions to the allowable emission rate.  Specifically,
owners, or operators are required to install, operate, and maintain a
continuous monitoring system (CMS) to demonstrate compliance with the
emission limitations in Tables 1 through 3 and 5 through 6 in the
standard and the operating limits in Table 7; and they also must record
the values of equipment operating parameters as specified in Table 7. 
Owners, or operators are required to conduct equipment inspections and
equipment leak monitoring to demonstrate compliance with the work
practice standards in Tables 1 through 5.

	Also, miscellaneous coating manufacturing facilities are subject to the
general provisions at 40 CFR part 63, subpart A which apply to all
NESHAP subject facilities.  These requirements include those associated
with the applicability determinations; notifications that the facilities
are subject to the rule; notifications of performance tests;
notifications of compliance status, including the results of performance
tests and design evaluations; and semiannual compliance reports.  In
addition to the requirements of subpart A, many respondents are required
to submit a precompliance report and leak detection and repair (LDAR)
reports; and existing facilities that wish to implement emissions
averaging provisions must submit an emissions averaging plan.

	All reports are to be submitted to the respondent’s state, or local
agency, or to the EPA regional office, whichever has been delegated
enforcement authority by EPA.  The information is used to determine
whether or not all sources subject to the rule are achieving the
emission limitations and work practice standards in the rule.

	If the owner, or operator identifies any deviation from an emission
limitation or work practice standard, a compliance report must be
submitted that includes all records that the source is required to
maintain that pertain to the periods during which such deviation
occurred, as well as data regarding: the magnitude of each deviation;
the reason for each deviation; a description of the corrective action
taken for each deviation, including action taken to minimize each
deviation and actions taken to prevent a recurrence; and a copy of all
quality assurance activities performed on any monitoring protocol.

	Owners, or operators of a miscellaneous coating manufacturing facility
must maintain a copy of all monitored equipment operating parameter
values that demonstrate compliance with the operating limits in the
rule, as well as records of inspections and results of equipment leak
monitoring that demonstrate compliance with the work practice standards
in the rule.  Also, owners, or operators are required to maintain
records of the occurrence and duration of any startup, shutdown, or
malfunction in the operation of a source, or any period during which the
monitoring system is inoperative.  Those records must be maintained for
a minimum of five years.  At a minimum, the most recent two years of
data must be retained onsite.  The remaining three years of data may be
retained offsite.

	A previous Information Collection Request (ICR) incorrectly identifies
“Federal Government” and “State, Local, or Tribal Government” as
part of the “Affected Public.”         The “Affected Public” is
comprised entirely of “Business, or other for profit” entities as
described in the previous approved ICR renewal.

The OMB approved the current ICR without any ”Terms of Clearance.” 

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost - NESHAP for Miscellaneous Coating
Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal).  The burden to
the “Federal government” is attributed entirely to work performed by
Federal employees or government contractors; this burden may be found
below in Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous
Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal).

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, emissions from miscellaneous coating
manufacturers cause, or contribute to air pollution that may reasonably
be anticipated to endanger public health, or welfare.  Therefore, the
NESHAP for Miscellaneous Coating Manufacturing was promulgated at 40 CFR
part 63, subpart HHHHH.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information also is
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
requirements.  Continuous emission monitors are used to ensure
compliance at all times.

The notifications required in the standards are used to inform the
Agency, or delegated authority when a source becomes subject to the
requirements of the standard.  The reviewing authority may then inspect
the source to check if the pollution control devices are properly
installed and operated and the standards are being met.  The performance
test also may 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.  Non-duplication, Consultations, and Other Collection Criteria

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

3(a)  Non-duplication

 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 agency     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 at 74 FR 32580 on July 8, 2009. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

An industry consultation was conducted with Carolyn A. Wacker, (651)
737-3627, Specialist, Environmental Engineer, 3M Company.  The 3M
Company has five facilities that are complying with applicable
requirements of this NESHAP.  3M estimated that the burden hours to the
five facilities for ongoing compliance activities (Table 1, burden items
3C for semiannual reports excluding emissions averaging, items 4H and
4I) would not exceed the EPA estimates.  The cost for LDAR and reporting
is 100 to 200 hours per 3M facility; this ICR indicates 250 hours are
spent for the same activities.  Generally, the 3M estimates confirm the
burden hour estimates in this ICR.  One 3M facility contracts out the
LDAR monitoring.  The contractor cost to this facility is $1,300 higher
based on the EPA hourly rate for 30 hours.  

In addition to an industry-based consultation, the Agency’s industry
experts have been consulted during a previous renewal of this ICR.  Our
internal data sources and the Agency’s projections for industry growth
over the next three years were also considered.  Our most relevant data
source was the Air Facility System (AFS) which is operated and
maintained by EPA's Office of Compliance.  AFS is EPA’s database for
the collection, maintenance, and retrieval of all compliance data.  The
growth rate for the industry was based on our consultations with the
Agency’s internal industry experts.  An annual average of
approximately 133 respondents would be subject to the standard over the
three year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to carefully review any comments received since the
last ICR renewal including those submitted in response to the first
Federal Register notice and respond appropriately.  In this case, no
comments were received.

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting and recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 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.  The retention of records for five
years allows EPA to establish the compliance history of a source,
monitor any pattern of non-compliance, and determine the appropriate
level of enforcement action.  EPA has found that the most flagrant
violators have violations extending beyond five years.  In addition, EPA
would be prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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 (CBI) (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

The reporting and recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are the
owners, or operators of miscellaneous coating manufacturing facilities. 
The United States Standard Industrial Classification (SIC) codes for
such facilities are 285 and 289, which correspond to the North American
Industry Classification System (NAICS) codes 3255 and 3259.

4(b)  Information Requested

(i)  Data Items

In this ICR, all the data that are recorded or reported are required by
the NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63,
subpart HHHHH).

A source must make the following reports:

Notifications/Reports	Regulation References

Initial notifications (including construction/reconstruction)	63.5,
63.9(b), and 63.8070(a)-(c)

Notification of performance test, test plan, and emission profile
63.7(b)-(c), 63.9(e), and 63.8070(a),(d)

Notification of CMS performance evaluation	63.8(e)(2) and 63.9(g)

Notification of compliance status (including performance test results)
63.9(h), 63.10(d)(2), and 63.8070(e)

Notification of process change	63.8070(f)

Emissions averaging plan	63.1250-63.1260, 63.8060

Precompliance report	63.8075(c)

Semiannual compliance report

Startup, shutdown, and malfunction reports

Deviations/no deviations/out-of-control CMS

No out-of-control CMS

Heat exchange system reports (delay of repair)

Maintenance and inspection reports for storage tank control devices

Operating scenario reports

Equipment leak reports

Emissions averaging reports	63.10(e)(3) and 63.8075(b),(d)

63.10(d)(5) and 63.8075(d)(4)

63.8075(d)(5)

63.8(c)(7), 63.8075(d)(6)

63.104(e), (f)(2)(i)-(iv), 63.8075(d)(7)

63.1063(c)(2)(iv)(B) or (e)(2), 63.8075(d)(8)

63.8075(d)(9)

63.1039(b)(1)-(8) and 63.8075(d)(10)

63.1250-63.1260, 63.8060



A source must keep the following records:

Recordkeeping Requirements	Regulation Reference

Record retention	63.10(b)(1) and 63.8085

Documentation supporting initial notifications and notifications of
compliance status	63.10(b)(2)(xiv) and 63.8080(a)(1)

Startup, shutdown, and malfunction plan	63.6(e)(3)

Records related to startup, shutdown, and malfunction
63.6(e)(3)(iii)-(iv) and 63.8080(a)(2)

Records of performance tests and CMS performance evaluations
63.10(b)(2)(viii) and 63.8080(a)(3)

Records for equipment leaks	63.1038(b)-(c) and 63.8080(a)(4)

Daily schedule or log of each operating scenario	63.8080(a)(5)

Records for process vessels complying with percent reduction emission
limitation	63.8080(a)(6)

Planned routine maintenance records for storage tank control devices
63.8080(a)(7)

Maintenance wastewater plan	63.8080(a)(8)

Records for safety device openings	63.8080(a)(9)

Results of each CMS calibration, validation check, and inspection
63.8035(c)(6)-(8), (d)(4)-(5), (e)(4)-(7), (f)(3)-(4), 63.8080(a)(10)

Records for emissions averaging	63.1250-63.1260, 63.8060

Records for each CMS	3.8(d)(3), 63.8(f)(6)(i), 63.10(b)(2)(vi)-(xi), and
63.8080(b)



Electronic Reporting

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 20 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate opacity and/or parameter
monitors

Perform initial performance test and repeat performance tests if
necessary

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

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

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 the notification of startup, the reviewing authority may
inspect the affected facility 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.  Data and records maintained by the
respondents are tabulated and published for use in compliance and
enforcement programs.  Immediate startup, shutdown and malfunction
notifications and reports alert the Agency to atypical operations
conditions which result in violations of the emission limitations. 
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 Air Facility
System (AFS), which is operated and maintained by the EPA Office of
Compliance.  AFS is the EPA 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

	Based on review of the following sources: Final Rule (71 FR 58499);
Proposed Rule (71 FR 28639); Summary of Public Comments and Responses
(EPA 450/R-02-XXXX, August 2003); and the Implementation Tool for the
Miscellaneous Coating Manufacturing NESHAP (EPA-305-B-06-003, Sept.
2006), an estimate of the number of small entities affected by this rule
could not be determined.	

Based on the previous ICR renewal, there are few, if any, small entities
(i.e., small businesses) affected by this regulation.  However, any
impact on small entities was taken into consideration during the
development of the standard.  Generally, only major sources of pollution
are regulated under the standard.

	5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63,
subpart HHHHH) (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 respondents. 
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.

6(a)  Estimating Respondent Burden

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the respondents. 
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.  

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$100.99 ($48.09 + 110%)  

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 2005, ”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 types of industry costs associated with the information collection
activities in the 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 that occur
when a facility becomes subject to the regulation.  The annual operation
and maintenance costs are the ongoing costs to maintain the monitors and
include 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	(B)

Capital/Startup Cost	(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)

Process Vessels	$30,000	1	$30,000	$16,000	132	$2,112,000

Transfer Operations 	N/A	N/A	N/A	$3,100	132	$409,200

Wastewater Systems	N/A	N/A	N/A	$2,000	132	$264,000

Totals	$30,000



	$2,785,200

	The total capital/startup costs for this ICR are $30,000.  This is the
total of column D in the above table.  The total operation and
maintenance (O&M) costs for this ICR are $2,785,200.  This is the total
of column G.

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 $2,815,000 per year.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $41,417.

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

	Managerial	$57.20  (GS-13, Step 5, $35.75 x 1.6)  

	Technical	$42.45  (GS-12, Step 1, $26.53 x 1.6)

	Clerical	$22.96  (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) ”2006
General Schedule“ which excludes locality rates of pay.  Details upon
which this estimate is based appear below in Table 2: Average Annual EPA
Burden - NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63,
subpart HHHHH) (Renewal).

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

Based on our research for this ICR, on average over the next three
years, approximately 9 of the 132 existing respondents will be subject
to the standard.  It is estimated that one additional respondent per
year will become subject over the three-year period covered by this ICR.

The number of respondents is calculated using the following table that
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 1	(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	1	131	0	0	132

2	1	132	0	0	133

3	1	133	0	0	134

Average	1	133	0	0	133

1  New respondents include sources with constructed, reconstructed, and
modified affected facilities.

Column D is subtracted to avoid double-counting respondents.  As shown
above, the average Number of Respondents over the three year period of
this ICR is 133.

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 construction/reconstruction	1	1	N/A	1

Notification of anticipated startup	1	1	N/A	1

Notification of actual startup	1	1	N/A	1

Notification of applicability of standard	1	1	N/A	1

Emission averaging plan	1	0	N/A	0

Precompliance report	1	1	N/A	1

Notification of initial performance test	1	0	N/A	0

Notification of initial CMS performance evaluation	1	0	N/A	0

Notification of compliance status	1	1	N/A	1

Notification of process change	13	1	N/A	13

Semiannual report	132	2	N/A	264

Startup, shutdown, malfunction report	7	1	N/A	7

LDAR report	132	2	N/A	264

Emission averaging report	13	1	N/A	13



	Total	567



The number of Total Annual Responses is 567.

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 annual labor hours are 167,572 per year over the three years of this
ICR.  The total annual labor costs are $14,192,714.  The annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 296 hours per response.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Miscellaneous Coating Manufacturing (40 CFR part 63,
subpart HHHHH) (Renewal).

The total annual capital/startup and O&M costs to the regulated entity
are $2,815,200.  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  1,001 labor hours at a cost of $41,416.  See below
Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating
Manufacturing (40 CFR part 63, subpart HHHHH) (Renewal)

6(f)  Reasons for Change in Burden

There is no change in the calculation methodology for labor hours or
costs to the respondents in this ICR compared to the previous ICR.  This
is due to two considerations: (1) the regulations have not changed over
the past three years and are not anticipated to change over the next
three years; and (2) the growth rate for respondents is very low,
negative, or non-existent.  Therefore, the labor hours and cost figures
in the previous ICR reflect the current burden to the respondents and
are reiterated in this ICR.  

In the previous ICR renewal, the total respondent burden approved in the
“Notice of Office of Management and Budget Action” was 167,832
hours.  This burden does not match the total burden as calculated below
in Table 1 of the Supporting Statement.  This ICR uses the same
calculation methodology as the past ICR renewal.  This renewal requests
approval of 167,572 hours—260 less hours than previously approved.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 296 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 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
EPA-HQ-OECA-2009-0405.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Avenue, N.W., 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 docket center is (202) 566-1752.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention:
Desk Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0405 and OMB Control Number 2060-0535 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 Miscellaneous
Coating Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal)

















	A	B	C	D	E	F	G	H	I



	Burden hours per occurrence	Number of occurrences per year	Technical
hours per respondent per year	Respondents per yeara	Technical hours per
respondent	Management hours per year	Clerical hours per year	Respondent
hours per year	Labor Cost, $



     Burden item



























	(C = A * B)

(E = C * D)	(F = E * 0.05)	(G = E * 0.1)	(H = E + F + G)

1	Applications	 N/A 









2	Surveys and Studies	 N/A 









3	Reporting Requirements











A.	Read Instructionsc	1.0	1.0	1.0	1	1.0	0.1	0.1	1.2	97

	B.	Required Activities 











	Initial CMS performance evaluationd	10.0	1.0	10.0	0	0.0	0.0	0.0	0.0	0



Create Information	 Included in item 4 









	Gather Existing Information	 Included in item 4 









C.	Write Reports











	Notification of construction/reconstruction	2.0	1.0	2.0	1	2.0	0.1	0.2
2.3	195



Notification of anticipated startup	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195



Notification of actual startup	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195



Notification of applicability of standard











 1. Existing sources	2.0	0.0	0.0	0	0.0	0.0	0.0	0.0	0



 2. New sources	2.0	1.0	2.0	1	2.0	0.1	0.2	2.3	195



Emissions averaging plane	40.0	1.0	40.0	0	0.0	0.0	0.0	0.0	0



Precompliance reportf	40.0	1.0	40.0	1	40.0	2.0	4.0	46.0	3,896



Notification of initial performance testg	2.0	1.0	2.0	0	0.0	0.0	0.0	0.0
0



Notification of initial CMS performance evaluationd	2.0	1.0	2.0	0	0.0
0.0	0.0	0.0	0



Notification of compliance status











 1. With performance testg	80.0	1.0	80.0	0	0.0	0.0	0.0	0.0	0



 2. Without performance testg	120.0	1.0	120.0	1	120.0	6.0	12.0	138.0
11,688



Notification of process changeh	8.0	1.0	8.0	13	104.0	5.2	10.4	119.6
10,130



Semiannual compliance report











	  1. No Deviationsi	8.0	1.0	8.0	119	952.0	47.6	95.2	1,094.8	92,725



  2. Deviationsi	24.0	1.0	24.0	13	312.0	15.6	31.2	358.8	30,389



Startup, shutdown and malfunction reportj	8.0	1.0	8.0	7	56.0	2.8	5.6
64.4	5,454



LDAR reportk	125.0	2.0	250.0	132	33,000.0	1,650.0	3,300.0	37,950.0
3,214,217



Emission averaging reportl	20.0	1.0	20.0	13	260.0	13.0	26.0	299.0	25,324

	Subtotal Reporting



	40,081	40,081	$3,394,700

4	Recordkeeping Requirements











A.	Read Instructions	 Included in 3A









B.	Plan Activities	 N/A 









	C.	Implement Activities	 N/A 









	D.	Develop Record Systemm	40.0	1.0	40.0	1	40.0	2.0	4.0	46.0	3,896

	E.	Develop Startup, Shutdown, Malfunction Plann	100.0	1.0	100.0	1	100.0
5.0	10.0	115.0	9,740

	F.	Develop QA/QC Plan for CMSo	40.0	1.0	40.0	0	0.0	0.0	0.0	0.0	0

	G.	Time for Audits	N/A









	H.	Time to Enter Information











	  1. Records of startup, shutdown and malfunction	1.5	1.0	1.5	132	198.0
9.9	19.8	227.7	19,285



  2. Records of CMS data











	  a. Record Continuously monitored parameters	1.0	365.0	365.0	132
48,180.0	2,409.0	4,818.0	55,407.0	4,692,756



  b. Compile data	24.0	2.0	48.0	132	6,336.0	316.8	633.6	7,286.4	617,130



  c. Information for semiannual reports	16.0	2.0	32.0	132	4,224.0	211.2
422.4	4,857.6	411,420



  d. LDAR recordkeeping	Included in 3C









I.	Calibration of CMS	376.0	1.0	376.0	132	49,632.0	2,481.6	4,963.2
57,076.8	4,834,182

	J.	Personnel Trainingp	40.0	1.0	40.0	1	40.0	2.0	4.0	46.0	3,896

	K.	Refresher Coursep	16.0	1.0	16.0	132	2,112.0	105.6	211.2	2,428.8
205,710

	L	Time for Audits	N/A



0.0	0.0	0.0	0.0	0

Subtotal Recordkeeping



	127,491	127,491	$10,798,014

Totals



	167,572	167,572	$14,192,714













	Assumptions:









	a	132 existing major source facilities subject to the NESHAP.  Assuming
2 percent growth over 3 years, 1 new facility will be built each year.

	b	Labor cost assumes a rate of $87.97/hour for technical labor,
$100.99/hour for management labor, and $43.81/hour for clerical labor.

	c	This will occur only in the first year after a facility becomes
subject to the rule.





	d	Assumes 10 hours to conduct a CMS performance evaluation and 2 hours
to prepare a notification.





e	Assumes that all existing facilities have complied with the emissions
averaging requirements; new facilities are not allowed to use emissions
averaging.

f	Assumes 50 percent of the new facilities will submit a precompliance
report [50% x 1= 1 (rounded)].





g	Assumes all facilities will comply by submitting engineering
calculations, design calculations, etc. with no performance tests. 



h	Assumes 10 percent of the facilities will implement process changes
[(10% x 132= 13 (rounded)].





i	Assumes 90 percent of facilities will have no deviations, and
10 percent will have deviations [90% x 132=119 (rounded), 10% x 132 =
13 (rounded)]. 

j	Assumes 5% of all facilities will report actions taken during a
startup, shutdown, or malfunction is not consistent with the plan [5% x
132 = 7 (rounded)}.

k	Assumes all facilities will be subject to the equipment leak standards
with an average of 125 hours per report.



l	Assumes that 10 percent of existing facilities will use with the
emissions averaging reports to comply [10% x 132 = 13 (rounded)].

	m	Assumes 40 hours to develop a record system for recording parameter
monitoring information.



	n	Assumes 80 hours to draft the startup, shutdown, and malfunction plan
and another 20 hours of review/revisions, for a total of 100 hours.

	o	Assumes 40 hours to develop/review the QA/QC plan for the CMS.  No
QA/QC plan is required for the parameter monitoring systems included in
the rule.

	Assumes no facilities will use the alternative standard, which requires
CEMS and QA/QC plans.





p	Assumes 40 hours to train personnel and 16 hours for an annual
refresher course.





	



Table 2: Average Annual EPA Burden - NESHAP for Miscellaneous Coating
Manufacturing (40 CFR Part 63, Subpart HHHHH) (Renewal)













	Activity	A	B	C	 D 	 E 	 F 	G



Agency hours per occurrence	Occurrences per yeara	Technical hours per
year	Management hours per year	Clerical hours per year	Total hours per
year	Labor Costb, $













	 	(C = A * B)	 (D = C * 0.05) 	 (E = C * 0.1) 	 (F = C + D + E) 	 

	 	Notifications/Reports	 	 	 	 	 	 	 

	A.	 	Performance Testc	8	0	0	0	0	0	0

	B.	  Repeat Performance Testd	8	0	0	0	0	0	0

	C.	  CMS Performance Evaluatione	4	0	0	0	0	0	0

	D.	Review Notification of Construction/Reconstruction	2	1	2	0.1	0.2	2.3
95

	E.	 	Review Notification of Anticipated Startup	2	1	2	0.1	0.2	2.3	95

	F.	 	Review Notification of Actual Startup	2	1	2	0.1	0.2	2.3	95

	G.	 	Review Notification of Applicability of Standard	2	1	2	0.1	0.2
2.3	95

	H.	 	Review Emissions Averaging Planf	12	13	156	7.8	15.6	179.4	7,427

	I.	 	Review Precompliance Reportg	4	1	4	0.2	0.4	4.6	190

	J.	 	Review Notification of Initial Performance Test	2	0	0	0	0	0	0

	K.	 	Review Notification of Initial CMS Performance Evaluatione	2	0	0
0	0	0	0

	L.	 	Review Notification of Compliance Status	 	 	 	 	 	 	 

	 	 	  1. With performance testh	4	0	0	0	0	0	0

	 	 	  2. Without performance testi	4	1	4	0.2	0.4	4.6	190

	M.	 	Review Notification of Process Changej	6	13	78	3.9	7.8	89.7	3,713

	N.	 	Review Semiannual Compliance Report	 	 	 	 	 	 	 

	O.	 	    No deviationsk	2	119	238	11.9	23.8	273.7	11,330

	P.	 	    Deviationsk	4	13	52	2.6	5.2	59.8	2,476

	Q.	 	Startup, shutdown, and malfunction reportl	2	7	14	0.7	1.4	16.1
666

	R.	 	LDAR reportm	2	132	264	13.2	26.4	303.6	12,568

	S.	 	Emissions averaging reportf	4	13	52	2.6	5.2	59.8	2,476

	Totals	870	44	87	1,001	$41,416













	Assumptions:









a	132 existing major source facilities subject to the NESHAP.  Assuming
2 percent growth over 3 years, 1 new facility will be built each year.

	b	Labor cost assumes a rate of $42.45/hour for technical labor,
$57.20/hour for management labor, and $22.96/hour for clerical labor.

	c	Assumes no initial performance tests because all facilities will
comply by submitting engineering calculations.



d	Assumes no repeat performance tests.







	e	Assumes no performance evaluations are required for the parameter
monitoring systems included in the rule.



f	Assumes that 10 percent of existing facilities will use with the
emissions averaging reports to comply [10% x 132 = 13 (rounded)].

	g	Assumes 50 percent of the new facilities will submit a precompliance
report [50% x 1= 1 (rounded)].



	h	Assumes one new facility will conduct initial performance tests.





	i	Assumes all existing facilities have complied by submitting
engineering calculations.





j	Assumes 10 percent of the facilities will implement process changes
[(10% x 132= 13 (rounded)].



	k	Assumes 90 percent of facilities will have no deviations, and
10 percent will have deviations [90% x 132=119 (rounded), 10% x 132 =
13 (rounded)]. 

l	Assumes 5% of all facilities will report actions taken during a
startup, shutdown, or malfunction is not consistent with the plan [5% x
132 = 7 (rounded)}.

m	Assumes all facilities will report the specified information for
processes subject to the equipment leak standards.

















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