SUPPORTING STATEMENT FOR

National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Paint Stripping and Miscellaneous Surface Coating Operations at Area
Sources (40 CFR PART 63, SUBPART HHHHHH)

	

	U.S. Environmental Protection Agency

	Office of Air Quality Planning and Standards

	Research Triangle Park, NC 27711

	December 2007

PART A OF THE SUPPORTING STATEMENT 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection.

This Information Collection Request (ICR) is entitled “NESHAP for
Paint Stripping and Miscellaneous Surface Coating Operations at Area
Sources (40 CFR PART 63, SUBPART HHHHHH)”. The ICR number for this is
2268.02.

1(b) Short Characterization/Abstract.

The National Emissions Standards for Hazardous Air Pollutants for Paint
Stripping and Miscellaneous Surface Coating Operations at Area Sources
(40 CFR part 63, subpart HHHHHH) are being made final. These standards
are part of EPA’s Integrated Urban Strategy to reduce cancer risk from
area sources under section 112(k)(3)(C) of the CAA. The affected sources
will have to comply with recordkeeping and reporting requirements of the
new rule.

This ICR includes the burden for activities that will be conducted in
the first three years following promulgation of the National Emissions
Standards for Hazardous Air Pollutants for Paint Stripping and
Miscellaneous Surface Coating Operations at Area Sources. The owners or
operators of facilities with these operations would read instructions to
determine how they will be affected by the rule. 

New and existing sources will also have to submit an initial
notification. New sources will also be required to submit a notification
of compliance status and maintain records. Because the compliance date
for existing sources is 3 years after the NESHAP is promulgated, other
recordkeeping and reporting activities for existing sources do not begin
until 3 years after promulgation. Therefore, they are not included in
the burden estimate for the first 3 years. 

	Although not necessary for this ICR, respondent burden estimates for
year 4 are included in Attachment A4, B3, C4, and the agency burden
estimates are provided in Attachment D4 to provide perspective on the
annual burden when the rule is fully implemented. 

This information is being collected to assure compliance with 40 CFR
part 63, subpart HHHHHH. Owners or operators will keep records and
submit required reports to EPA or the delegated State regulatory
authority. Notifications, reports, and records are essential in
determining compliance; and are required, in general, of all sources
subject to NESHAP. Owners or operators subject to the miscellaneous
surface coating NESHAP will maintain records and retain them for at
least 5 years following the date of such reports and records. 

2.	NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires EPA to develop NESHAP
for both new and existing major and area sources. A major source is
defined in section 112(a) as any stationary source or group of
stationary sources located within a contiguous area and under common
control that emits, or has the potential to emit, considering controls,
in the aggregate, 10 tons per year (tons/yr) of any one HAP or 25
tons/yr of any combination of HAP. An area source is defined in section
112(a) as any stationary source that is not a major source. Thus, area
sources do not emit nor have the potential to emit HAP at or above the
10 or 25 tons/yr thresholds. 

	The CAA further requires EPA to determine the HAP emitted by area
sources that pose the greatest threat to public health in urban areas.
Specifically, section 112(k)(3)(B) instructs EPA to develop a list of at
least 30 HAP emitted by area sources that pose the greatest threat to
public health in the largest number of urban areas. Once that is
accomplished, sections 112(c)(3) and 112(k)(3)(B)(ii) direct EPA to
identify source categories of area sources that represent 90 percent of
the emissions of the 30 identified HAP. Section 112(k)(3)(C) requires
EPA to also develop a strategy under section 112 or other laws to reduce
the incidence of cancer attributable to exposure to HAP emitted by
stationary sources by not less than 75 percent, considering control of
emissions of HAP from all stationary sources and resulting from measures
implemented by EPA or by the States under the Act or other laws. On July
19, 1999, EPA published its Integrated Urban Strategy, which included
both the list of 30 HAP and the initial list of area source categories
(64 FR 38706), which included “Paint Stripping Operations”.  On June
26, 2002 and November 22, 2002, EPA added “Autobody Refinishing Paint
Shops” (67 FR 43112) and “Plastic Parts and Products (Surface
Coating)” (67 FR 70427), respectively, to the list of area source
categories. The scope of the autobody refinishing category has since
been revised to include all motor vehicle and mobile equipment
refinishing to reflect the fact that sources that perform mobile
equipment refinishing use many of the same coatings as used in motor
vehicle refinishing, and motor vehicles and mobile equipment are often
refinished at the same or similar sources. The scope of the plastic
parts and products (surface coating) source category has also been
revised to include metal parts and products to more accurately reflect
the scope of the sources analyzed in identifying that area source
category as a source of urban HAP.

Since the development of the area source category list, EPA has
determined that it is technically feasible to regulate emissions from
these three source categories by a single set of emission standards. 
The processes, emission points, emission characteristics, and emission
controls for plastic parts and products surface coating and autobody
refinishing are very similar.  Additionally, paint stripping is often
performed as part of the surface preparation for both plastic parts and
autobody refinishing which, by regulating within the scope of a single
set of standards, reduces the burden of complying with multiple
standards on the sources performing both the paint stripping and
subsequent coating. This single set of emission standards to address all
three categories also minimizes the cost of developing, permitting, and
enforcing the standards.  

In summary, the information obtained during the data gathering phase of
the project demonstrated that the processes, emission characteristics,
and applicable control technologies for facilities in these categories
are similar.  Based on these factors, EPA concluded that these three
categories are to be treated as a single source category for the
purposes of this rulemaking.  For purposes of the preamble and final
rule, the term paint stripping and miscellaneous surface coating is used
to indicate that the three source categories of plastic parts and
products (surface coating), autobody refinishing, and paint stripping
have been treated as a single source category.  

  SEQ CHAPTER \h \r 1 Certain notifications and reports, as described in
this information collection request, are necessary to enable the
Administrator to identify existing sources subject to the NESHAP and to
determine if the standards are being achieved.

	 

2(b) Practical Utility/Users of the Data.

	In order to minimize HAP emissions from paint stripping, motor vehicle
and mobile equipment refinishing operations, and miscellaneous surface
coating, facilities must comply with certain equipment requirements and
management practices. The information generated by the recordkeeping and
reporting requirements described in this ICR will be used by EPA to
ensure that personnel who spray coatings are certified in the proper
selection, mixing, and application of coatings. Additionally, the
information will ensure that filters and spray guns at spray booths of
affected facilities meet the minimum efficiency requirements. Further,
this information will help EPA to maintain an updated inventory of all
sources with paint stripping or surface coating operations.

	Adequate recordkeeping and reporting are necessary to ensure compliance
with the standards, as required by the CAA. The information collected
from recordkeeping and reporting requirements is also used for targeting
inspections, and is of sufficient quality to be used as evidence in
court. To minimize the burden, much of the information, which is kept on
site, could be reviewed by enforcement personnel during an inspection
and would not need to be routinely reported to the agency. 

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

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 their own similar standards to
implement the Federal standards, a copy of the notice or report
submitted to the State or local agency can be sent to the Administrator
in lieu of the notice or report required by the Federal standards. 

During the development of subpart HHHHHH, three different source
categories were combined to be regulated under a single subpart. 
Subpart HHHHHH now includes sources that perform surface coating on both
motor vehicles/mobile equipment, metal or plastic parts, or paint
stripping, and this consolidation removed any duplicate rule
requirements.  Therefore, no duplication exists. 

3(b) Public Notice Required Prior to ICR Submission to OMB.

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register on September 17, 2007 (72 FR
52958) as part of the proposed rulemaking.  No comments were received on
the burden published in the Federal Register that resulted in a change
in the burden estimate.

3(c) Consultations.

	During the development of this rule, EPA met with industry in order to
obtain data and input on the training, recordkeeping and reporting
requirements from the facilities potentially affected by this rule. 

For motor vehicle or mobile equipment finishing or refinishing, EPA met
with the Alabama Collision Repair Industries Association, Automotive
Aftermarket Industry Association, Automotive Service Association,
California Autobody Association, Cedar Rapids (Iowa) Autobody
Association, Coordinating Committee For Automotive Repair (C-CAR),
Collision Industry Council, Inter-Industry Conference on Auto Collision
Repair (I-CAR), I-CAR Education Foundation, National Association of
Fleet Administrators, National Automobile Dealers Association, National
Paint and Coatings Association, and the National Institute for
Automotive Service Excellence (ASE).

	For miscellaneous parts and products surface coating, EPA contacted the
Composite Manufacturers Association in order to obtain data and input
from the facilities potentially affected by this rule.  The EPA also set
up a web-based pilot-project for sources to visit and submit data on
miscellaneous surface coating operations.  Neither of these sources
provided data or input on the proposed rulemaking or associated burdens.

	For paint stripping, the EPA will alert industry groups such as the
Halogenated Solvents Industry Alliance (HSIA), and State and Local
governments of its pending publication. The EPA will also involve the
Small Business Administration (SBA) to assist in outreach to small
business entities that may not otherwise be aware of the final rule.  

The public also had the opportunity to review and comment on the
proposed rule and the ICR during the specified comment period. 

3(d) Effects of Less Frequent Collection.

The final rule includes the minimum requirements needed to demonstrate
continuous compliance with the rule. Less frequent information
collection would decrease the margin of assurance that facilities are
continuing to meet the final standards. Requirements for information
gathering and recordkeeping are useful techniques to ensure that
equipment requirements and work practices are applied. If the
information required by the standards were collected less frequently,
the likelihood of detecting inadequate equipment or operating practices
would decrease and emissions would increase. 

3(e) General Guidelines.

The standards require affected facilities to maintain all records,
including reports and notifications for at least 5 years. This is
consistent with the General Provisions as applied to the standards.
Also, the retention of records for 5 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 5 years. The EPA would be prevented
from pursuing the worst violators due to the destruction or nonexistence
of records if records were retained for less than 5 years. 

Additionally,   SEQ CHAPTER \h \r 1 no reports or compliance
notifications from existing sources are submitted in the first 3 years
after promulgation of the rule. The only burden for owners and operators
of existing sources in the first 3 years is to read and understand the
rule requirements and submit an initial notification letter, and
maintain records indicating that all spray painters have received
appropriate training. The other activities take place after the
compliance date.  The compliance date is 3 years after the promulgation
date, so compliance reporting does not begin until the fourth year after
promulgation. 

3(f) Confidentiality.

  SEQ CHAPTER \h \r 1 All information submitted to EPA for which a claim
of confidentiality is made will be safeguarded according to EPA 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 39999, September 28, 1978;
43 FR 42251, September 28, 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 and NAICS Codes.

	Subpart HHHHHH has affected sources from three different source
categories, which include: paint stripping, miscellaneous surface
coating, and motor vehicle and mobile equipment surface coating. The
following are the industrial classification of entities potentially
regulated by the final rule. This list is not meant to be exhaustive,
but it serves as a guide for entities required to submit information
discussed in this ICR. 

Table   SEQ Table \* ARABIC  1 : NAICS Categories for Various Affected
Sources

Category	NAICS	Examples of Potentially Regulated Entities

Paint Stripping

Natural Gas Liquid Extraction	211112	Natural Gas Liquid Extraction.

Spices and Extracts	311942	Spices and Extracts.

Mobile Homes	321991	Mobile Homes.

Basic Chemical Manufacturing	325110

325120

325131

325188

325192

325193

325199	Petrochemicals, Industrial Gases, Inorganic Dyes and Pigments,
Basic Inorganic and Organic Chemicals, Cyclic Crude and Intermediates,
Ethyl Alcohol.

Plastics Material Synthetic Resins, and Nonvulcanizable Elastomers
325211	Plastics Material Synthetic Resins, and Nonvulcanizable
Elastomers.

Paint and Coating Manufacturing	325510	Paint and Coating Manufacturing.

Miscellaneous Chemical Production and Preparation	325998	Miscellaneous
Chemical Production and Preparation.

Alumina Refining	331311	Alumina Refining.

All Other Plastics Products	326199	All Other Plastics Products.

All Other Miscellaneous Manufacturing   	339999	All Other Miscellaneous
Manufacturing.  

Waste Treatment and Disposal	562211

562212

562213

562219	Hazardous Waste Treatment and Disposal, Solid Waste Landfill,
Solid Waste Combustors and Incinerators, Other Nonhazardous Waste
Treatment and Disposal.

Materials Recovery 	562920	Materials Recovery.

Reupholstery and Furniture Repair 	811420	Reupholstery and Furniture
Repair. 

Miscellaneous Surface Coating

Aerospace Equipment	336413 336414 336415 

54171	Aircraft engines, aircraft parts, aerospace ground equipment.

Automobile Parts	335312 336111 336211 336312

 33632

 33633 

33634 

33637 

336399	Engine parts, vehicle parts and accessories, brakes, axles, etc.

Motor vehicle body manufacturing and automobile assembly plants.

Extruded Aluminum	331316 331524 332321 332323	Extruded aluminum,
architectural components, coils, rod, and tubes.

Heavy Equipment	33312 

333611 	Tractors, earth moving machinery.

Job Shops	332722 332813 332991 334119 336413 339999	Any of the products
from the miscellaneous metal parts and products segments.

Manufacturing industries not elsewhere classified (e.g., bezels,
consoles, panels, lenses).

Large Trucks and Buses	33612 

336211	Large trucks and buses.

Metal Buildings	332311	Prefabricated metal: buildings, carports, docks,
dwellings, greenhouses, panels for buildings.

Metal Containers	33242 

81131 

322214  331513 	Drums, kegs, pails, shipping containers.

Metal Pipe and Foundry	331111 331513 

33121 

331221 331511	Plate, tube, rods, nails, etc.

Rail Trans-portation	33651 336611 482111	Brakes, engines, freight cars,
locomotives.

Recreational Vehicles	3369 

331316 336991 336211 336112 336213 336214 336399	Motorcycles, motor
homes, semi trailers, truck trailers.

Rubber-to- Metal Products	326291 326299	Engine mounts, rubberized tank
tread, harmonic balancers.

Structural Steel	332311 332312	Joists, railway bridge sections, highway
bridge sections.

Other 

Transportation Equipment	336212 336213 336214 336999 

33635 

56121 

8111 

56211	Miscellaneous transportation related equipment and parts. Truck
trailer manufacturing. Motor home manufacturing.   Travel trailer and
camper manufacturing.

Other industrial and commercial	337214	Office furniture, except wood.

Miscellaneous Plastic Parts	32614

32615

326199	Plastic foam products (e.g., pool floats, wrestling mats, life
jackets).

Plastic products not elsewhere classified (e.g., name plates, coin
holders, storage boxes, license plate housings, cosmetic caps, cup
holders).

Office Equipment	333313	Office machines.

Electronics	33422	Radio and television broadcasting and communications
equipment (e.g., cellular telephones).

Medical Equipment	339111, 339112	Medical equipment and supplies.

Sporting Equipment	33992	Sporting and athletic goods.

Signs	33995	Signs and advertising specialties.

Marine Equipment	336612

713930	Boat building

Marinas, including boat repair yards

Motor Vehicle and Mobile Equipment Refinishing

Commercial	441110

441120

811121	New Car Dealers; Used Car Dealers; Automotive Body, Paint, and
Interior Repair and Maintenance.

Government	Not Applicable	Government entities, besides Department of
Defense, that maintain vehicles, such as school buses, police and
emergency vehicles, transit buses, or highway maintenance vehicles.



4(b) Information Requested. 

  SEQ CHAPTER \h \r 1 (i) Data items. The recordkeeping and reporting
requirements of the final rule include the following:

Initial notification letter §63.11175(a) 

Notification of compliance status §63.11175(b)

Annual notification of changes reports §63.11176(a)1

Records of painter certification §63.11177(a)

Records of filter efficiency §63.11177(b)

Records of spray gun efficiency §63.1177(c)

Records of notifications and annual reports §63.11177(d)1

Records of annual usage of methylene chloride (MeCl) in paint strippers
§63.11177(e)

Records of current methylene chloride minimization §63.11177(f)3

Records of deviations from compliance §63.11177(g)1

(ii) Respondent Activities. Both new and existing sources 

must read the rule and understand the rule requirements. Respondents
must also submit notifications and annual reports according to the
timelines specified in the rule. Each source must maintain all
applicable records for 5 years.	 

5.	THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT

5(a) Agency Activities.

	A list of Agency Activities is provided in Attachments D1 to D3.

5(b) Collection Methodology and Management.

	Reports submitted to the Agency and records maintained by the
respondents may be tabulated and published for use in compliance and
enforcement programs.

5(c) Small Entity Flexibility.

	Affected facilities are primarily small entities (e.g., small
businesses). Because of the large number of small businesses that are
likely to be affected by this rule, the reporting requirements for the
individual facilities are minimal. There are no quarterly or semiannual
requirements as there are with most regulated large industries. The
burden is further minimized since costly monitoring equipment, or
performance tests are not required. For this ICR, it is estimated that
out of the existing sources 93.5 percent (37,224 sources) are estimated
to be small businesses.

5(d) Collection Schedule.

	The information collection schedule is different for new and existing
sources subject to the final rule. New sources are required to submit
their initial notification and notification of compliance within 180
days after their initial start-up or 180 days after this rule is
promulgated. Existing sources have two year from the date the rule is
promulgated to submit the initial notification and three years and 60
days after the rule is promulgated to submit the notification of
compliance, if required. These two notifications are one-time-only
burdens.

	New and existing sources must also submit an annual report5 for each
calendar year by March 1 of the following year if there are any changes
in the information contained in the initial notification since the
initial notification or a previous report of changes, starting with the
year of the initial compliance date for the source. This corresponds to
the first annual report being submitted in years 2 and 4 of this ICR for
new and existing sources, respectively.

	Records of each notification, annual report and deviations from
compliance, if required, must be kept at the source for five years.
Owners of affected surface coating operations must maintain additional
records of painter certification dates and refresher training dates,
spray booth filter efficiency, and spray gun efficiency provided by the
manufacturers.  Owners of an affected paint stripping operation must
maintain additional records of annual MeCl usage in paint stripping
operations. Owners of affected paint stripping operations that use more
than one ton of MeCl in paint strippers, per year, must maintain a
record of their MeCl minimization plan on-site for the duration of their
facility’s operations.  The data items and respondent activities for
surface coating operations are summarized in Attachments A1 to A3
(commercial entities), Attachments B1 to B3 (government-owned entities).
Since the respondent activities are slightly different, the requirements
for affected paint stripping operations are summarized in Attachments C1
to C3.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden.

	Tables A1-A3, B1-B3, and C1-C3 in Attachments A to C present an
itemized breakdown of the reporting and recordkeeping requirements in
the first 3 years for the respondents subject to the final NESHAP. 

	The individual burdens are expressed under standardized headings
consistent with the concept of burden under the Paperwork Reduction Act.
Where appropriate, the specific tasks and major assumptions have been
identified. Responses to this information collection are mandatory. An
agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number. 

6(b) Estimating Respondent Costs.

Labor Costs. 

	  SEQ CHAPTER \h \r 1 Labor rates, on a per-hour basis, are from the
United States Department of Labor, Bureau of Labor Statistics,
Occupational Employment Statistics, May 2005. The occupational category
that is the most similar to personnel at affected facilities with
miscellaneous surface coating operations or paint stripping operations
is assumed to be an average (mean) of “Automotive Body, Paint,
Interior, and Glass Repair,” “Plastics Product Manufacturing,” and
“Fabricated metal product manufacturing.”   This ICR uses the labor
rates for the following occupations within these categories: for
technical labor, an average of automotive body and related repairers,
and environmental engineers; for managerial labor, first-line
supervisors/managers of mechanics/installers/repairers, and engineering
managers; for clerical labor, file clerks and secretaries.   SEQ CHAPTER
\h \r 1 The hourly mean wage rates from May 2005 have been multiplied by
a factor of 1.6 so that overhead and benefits are included in the
per-hour labor rates used to estimate respondent costs. The resulting
rates used are $45 for technical personnel, $58 for management and $19
for clerical personnel.

	(ii) Capital Costs. 

	Capital costs usually include any produced physical good needed to
provide the information, such as machinery, computers, and other
equipment. EPA does not anticipate that respondents will incur capital
costs in carrying out the information collection requirements covered in
this ICR.

	(iii) Operations and Maintenance Costs. 

	Sources will incur costs for photocopying and mailing notifications and
reports. For this ICR, a one-time operations cost of $1 for mailing and
making a photocopy of each initial notification and notification of
compliance, and a $3 operations cost for mailing and making a photocopy
of each annual report is included in the burden estimate. 

6(c) Estimating Agency Burden and Cost.

	The only costs to Agency are those costs associated with EPA Regions
and States reviewing the rule, and reviewing notifications and reports
submitted by the respondents and maintaining a list of units subject to
the Miscellaneous Surface Coating Operations at Area Sources rule. The  
SEQ CHAPTER \h \r 1 labor rates for Agency employees are based on the
estimated labor rates from the United States Department of Labor, Bureau
of Labor Statistics, Occupational Employment Statistics, May 2005 for
“Federal, State and Local Government”. This ICR uses the labor rates
for the following occupations within this category:  engineering
managers for managerial labor; environmental engineering technicians for
technical labor; and secretaries, except legal, medical, and executive
for clerical labor. The hourly mean wage rates from May 2005 have been
multiplied by a factor of 1.6 so that overhead and benefits are included
in the per-hour labor rates used to estimate respondent costs. The
resulting rates used are $32.75 for technical personnel, $72.45 for
management and $25.06 for clerical personnel. 

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

	  SEQ CHAPTER \h \r 1 The EPA estimates that the total number of
potentially affected facilities is approximately 39,812 sources. This
number of sources is expected to remain constant over the period of this
ICR. However, it is expected that an average of 1,593 new
commercially-owned motor vehicle and mobile equipment refinishing
sources and 25 new miscellaneous surface coating sources will start-up
each year over the next three years to replace existing sources which
may go out of business. No new state or local government-owned mobile
equipment refinishing shops are expected to start-up during this ICR
period.  A table showing the estimated number of sources for each
category is shown in Table 2 below.

Table   SEQ Table \* ARABIC  2  Summary of Respondent Universe

Category	Number of Existing Sources in Year 1	New Sources in Year 1 of
ICR*	New Sources in Year 2 of ICR	New Sources in Year 3 of ICR

Miscellaneous Surface Coating	781	50	25	25

Commercial Motor Vehicle and Mobile Equipment Refinishing	32,545	3,186
1,593	1,593

Government Motor Vehicle and Mobile Equipment Refinishing	250	0	0	0

Paint Stripping	3,000	0	0	0

Totals	  =SUM(ABOVE)  36,576 	  =SUM(ABOVE)  3,236 	  =SUM(ABOVE)  1,618
	  =SUM(ABOVE)  1,618 

* See Table A1, note (d).  The total number of sources in Year 1 is
39,812.

	The total number of annual responses per year is calculated using the
following table:

Table   SEQ Table \* ARABIC  3  Number of Responses per Respondent per
Year

Category

	

(A)

Annual Number of New Respondents (Average Year 1,2, and 3)	

(B)

Number of Reports for New Respondents	

(C)

Number of Existing Respondents	

(D)*

Number of Reports for Existing Respondents	

(F)

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

(E)

Total Annual Responses

E=(AxB)+(CxD)+F

Miscellaneous Surface Coating	33	3	781	1	0	 
=SUM(PRODUCT(b2,c2),PRODUCT(d2,e2),f2)  1081 

Commercial Motor Vehicle and Mobile Equipment Refinishing	2,124	3	32,545
1	0	38,917

Government Motor Vehicle and Mobile Equipment Refinishing	0	3	250	1	0	 
=SUM(PRODUCT(b4,c4),PRODUCT(d4,e4),f4)  250 

Paint Stripping	0	3	1,050	1	1,950	1,050

Total	  =SUM(ABOVE)  6,472 

  =SUM(ABOVE)  34,426 

	41,298

* Responses for existing sources are only the initial notification,
which is a one-time burden during this three year ICR period.

The number of Total Annual Responses is 41,298, these responses include
initial notifications, notifications of compliance status, and annual
compliance reports and it does not count recordkeeping activities as a
response. Details regarding these estimates may be found in Attachment
Tables A1 to C3.

	Due to the schedule of information collected under this ICR, the number
of sources subject to reporting and recordkeeping requirements will vary
over the three-year period.   SEQ CHAPTER \h \r 1 Respondent burden is
calculated based on the assumption that the total number of units will
remain constant during years one through three even though some units
will qualify as new units under this final rule.

	

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

	(i) Respondent Tally.   SEQ CHAPTER \h \r 1 An annual breakdown for
each of the reporting, and recordkeeping activities required by the
final rule is presented in Tables A1 through C3 in Attachments A, B,
and C, which represent years 1 through 3 of this ICR. Attachment A
presents the burden on commercially-owned surface coating facilities,
Attachment B presents the burden on government-owned surface coating
facilities, and Attachment C presents the burden on paint stripping
sources.  The estimate of total annual hours requested from the
respondents was based on the assumptions outlined in section 6(d) of
this ICR. The EPA estimated the respondent burden for the first 3 years
after the promulgation of the NESHAP by totaling the hours per year for
technical, managerial, and clerical staff at the facility. Due to the
absence of capital or start-up costs in the first 3 years, there are no
annualized capital costs. There are minimal operating and maintenance
costs incurred in the first 3 years for each notification and report
that is mailed to the Agency and copied for a facility record. The
average annual respondent burden for the 3-year period is 246,703 hours,
$10,154,722 in labor costs and $24,670 in operating and maintenance
costs. A summary of the total annual burden and costs are shown in Table
4 below.

Table 4 Summary of Burden and Costs for the Affected Source Categories

 	Sector	Commercial Surface Coating	Government Surface Coating	Paint
Stripping	Total

Year 1	Burden Hours	           604,346 	              4,175 	         
17,250 	      625,771 

	Labor Cost	 $  25,332,136 	 $ 174,920 	 $    749,655 	$ 26,256,711 

	O&M cost	 $  38,967 	 $ 250 	 $         3,000 	 $ 42,217 

 

Year 2	Burden Hours	              41,801 	                    -  	      
     9,660 	  51,461 

	Labor Cost	 $ 1,629,992 	 $ - 	 $  419,807 	 $   2,049,798 

	O&M cost	 $ 12,944 	$ -	 $ -   	 $ 12,944 

 

Year 3	Burden Hours	              45,620 	                     - 	      
   17,258 	  62,878 

	Labor Cost	 $ 1,795,962 	 $ -  	 $ 361,695 	 $   2,157,657 

	O&M cost	 $17,798 	 $                  - 	 $ 1,050 	 $       18,848 

 

Annual  Average	Burden Hours	           230,589 	              1,392 	  
       14,723 	            246,704 

	Labor Cost	 $  9,586,030 	 $ 58,307 	 $ 510,386 	 $10,154,723 

	O&M cost	 $  23,236 	 $ 83 	 $ 1,350 	 $  24,669 



	  SEQ CHAPTER \h \r 1 (ii) The Agency Tally. The bottom line Designated
Administrator burden hours and costs, presented in Tables D1 through D3
in Attachment D, were calculated by totaling the hours per year for
technical, managerial, and clerical staff, and by totaling the cost
column. The average annual Agency burden over the first 3 years is
12,004 hours and $698,462 of labor costs. There are no capital, start-up
or operating and maintenance costs in the first 3 years. A summary of
each year of Agency Burden is presented below in Table 5.

Table 5  Summary of Agency Burden for Years 1-3 of this ICR.

 	 	Agency

Year 1	Burden Hours	               27,035 

	Labor Cost	 $ 1,790,172 

	O&M cost	 $              -   

 

Year 2	Burden Hours	                 3,721 

	Labor Cost	 $   126,528 

	O&M cost	 $              -   

 

Year 3	Burden Hours	           5,256 

	Labor Cost	 $   178,687 

	O&M cost	 $              -   

 

3-year Average	Burden Hours	    12,004 

	Labor Cost	 $  698,462 

	O&M cost	 $              -   



(iii) Variation in the Annual Bottom Line.   SEQ CHAPTER \h \r 1 The
total respondent labor costs for years 1, 2, and 3 are $26,256,711;
$2,049,798; and $2,157,657, respectively. The total O&M costs are
$42,217; $12,944; and $18,848, respectively. The corresponding total
number of respondent hours during this period is 625,771 hours, 51,461
hours, and 62,877 hours, which are shown in Table 4 above and
Attachments A1 to C3. The variation in the burden for each of the three
years is a result of the number of information collection activities
required, based on the initial collection schedule and the fact that
some burdens are one-time-only information collection activities.
Starting in year four, which is shown in Attachments A4, B4, and C4,
both existing and new sources are required to meet all the reporting and
recordkeeping requirements and the annual burden is expected to stay
relatively constant from that point forward.

	  SEQ CHAPTER \h \r 1 During the first 3 years, the Agency will be
reviewing the regulation, and reviewing the initial notifications from
all sources and the compliance notifications and initial annual
compliance reports from the new sources. In years 1, 2, and 3, the
Agency will expend 27,035; 3,721; and 5,256 total hours in labor,
respectively. The corresponding costs for each year are $1,790,172;
$126,528; and $178,687.

6(f) Reasons for Change in Burden.

       SEQ CHAPTER \h \r 1 There was no comment on the ICR during the
comment period that resulted in a change in the burden estimate.
Therefore, the burden for the final rule remains unchanged from the
proposed rule. 

6(g) Burden Statement.

     The annual public reporting and recordkeeping burden for this
collection of information is estimated to average approximately 6 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 currently
valid OMB control number. The OMB control numbers for EPA's regulations
are listed in 40 CFR part 9 and 48 CFR chapter 15. 

	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 docket for this ICR under Docket ID No.
EPA-HQ-OAR-2005-0526, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket in the EPA Docket Center (EPA/DC), EPA West Building, Room 3334,
1301 Constitution Ave., NW, Washington, DC. The EPA/DC Public Reading
Room is open from 8 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 Air and Radiation Docket
Center is 202-566-1742.

	An electronic version of the public docket is available at
www.regulations.gov. This site can be used 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
Office for EPA. Please include the EPA Docket ID No.
EPA-HQ-OAR-2005-0526 and OMB Control Number 2060-NEW in any
correspondence.



	Part B of the Supporting Statement

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

List of Attachments

Note:  Where we use the term “Miscellaneous Surface Coating
Operations” in these table headings, we are referring to both the
plastic/metal surface coating operations and autobody refinishing
surface coating operations.

Attachment A

Table A1. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Commercial Miscellaneous Surface Coating
Operations at Area Sources - Year 1

Table A2. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Commercial Miscellaneous Surface Coating
Operations at Area Sources - Year 2

Table A3. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Commercial Miscellaneous Surface Coating
Operations at Area Sources - Year 3

Table A4. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Commercial Miscellaneous Surface Coating
Operations at Area Sources - Year 4 (all existing sources comply)

Attachment B

Table B1. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Government Surface Coating Operations at Area
Sources - Year 1

Table B2. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Government Surface Coating Operations at Area
Sources - Year 2 

Table B3. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Government Miscellaneous Surface Coating
Operations at Area Sources - Year 3

Table B4. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Government Miscellaneous Surface Coating
Operations at Area Sources - Year 4 (all existing sources comply)

Attachment C

Table C1. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Paint Stripping Operations at Area Sources -
Year 1

Table C2. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Paint Stripping Operations at Area Sources -
Year 2

Table C3. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Paint Stripping Operations at Area Sources -
Year 3

Table C4. Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements of Paint Stripping at Area Sources - Year 4 (all
existing sources comply)

Attachment D

Table D1. Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the Paint Stripping and
Miscellaneous Surface Coating Operations At Area Sources - Year 1 

Table D2. Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the Paint Stripping and
Miscellaneous Surface Coating Operations At Area Sources - Year 2

Table D3. Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the Paint Stripping and
Miscellaneous Surface Coating Operations At Area Sources - Year 3

Table D4. Annual Designated Administrator Burden and Cost of
Recordkeeping and Reporting Requirements of the Paint Stripping and
Miscellaneous Surface Coating Operations At Area Sources - Year 4 (all
existing sources comply)

 These notifications/reports/records are not required of paint stripping
facilities using one ton or less of methylene chloride (MeCl) for paint
stripping per year.

 These records are only required if a source does not have a polyester
fiber or fiberglass filter.  If a source has another type of filter, it
is assumed that the manufacturer of the alternative filter would perform
the test.  The only burden on the source would be the burden associated
with recording and maintaining a file of this filter efficiency as
reported by the manufacturer.

 These records are only required for sources without an HVLP that opt to
test non-HVLP type spray guns. 

 These records are only required of sources with paint stripping
operations that have an annual usage of more than one ton of MeCl.

 

 Notifications of compliance and annual compliance reports are not
required from paint stripping facilities with annual usage of 1 ton or
less of MeCl in paint stripping operations.

 See the Memorandum in Docket #EPA-OAR-2005-0526 entitled “Estimating
The Number Of Automotive Refinishing Shops And The Projected Number Of
New Shops”.

 

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