SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP - Reporting and Recordkeeping for the Friction Materials
Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP - Reporting and Recordkeeping for the Friction Materials
Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal), EPA ICR Number
2025.05, OMB Control Number 2060-0481

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 requires respondents to
reduce the total organic HAP emissions from their solvent mixers by
preventing emissions 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.

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.

There are approximately four friction materials manufacturing facilities
in the United States, which are owned and operated by the friction
material manufacturing industry.  None of the four facilities in the
United States are owned by state, local, tribal, or the Federal
government.  They are owned and operated by privately owned for-profit
businesses.  You can find the burden to the “Affected Public” listed
below in Table 1: Annual Industry Burden and Cost – NESHAP –
Reporting and Recordkeeping Requirements for the Friction Materials
Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal).  The Federal
government burden does not include work performed by Federal employees. 
The burden refers only to work performed by contractors, which could be
found listed below in Table 2: Average Annual EPA Burden - NESHAP –
Reporting and Recordkeeping Requirements for the Friction Materials
Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal)..

In the development of the ICR, we addressed the Office of Management and
Budget (OMB) “Terms of Clearance (TOC)” on the active ICR.  The TOC
are as follows:

When this ICR is renewed, EPA should review the respondent burden,
universe, labor rates, and capital costs and ensure these estimates have
been updated.

EPA has addressed each item of concern in the TOC.  The respondent
burden, universe, labor rates, and capital cost, have been thoroughly
checked, and all estimates updated.

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 (HAP). 
These standards are applicable to new or existing sources of HAP and
shall require the maximum degree of emission reduction.  In addition,
section 114(a) states that the Administrator may require any owner or
operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (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
was 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 where 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 tests, 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

The information generated by the monitoring, recordkeeping, and
reporting requirements described in this ICR is used by the agency to
ensure that facilities affected by the NESHAP continue to operate the
control equipment in compliance with the regulation.

3.  Non-duplication, Consultations, and Other Collection Criteria

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

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 their own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to 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 (76 FR 26900) on May 9, 2011.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts. 
Approximately four respondents will 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.  In developing this ICR, we contacted the Motor
and Equipment Manufacturers Association (MEMA) at (202) 393-6362, and
Dynax America Corporation at (540) 966-6010.  

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.

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 that 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

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.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance, and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the 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 (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 corresponds 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



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

In this ICR, all the data recorded or reported is required by National
Emission Standards for Hazardous Air Pollutants – Reporting and
Recordkeeping Requirements for the Friction Materials Manufacturing (40
CFR Part 63, Subpart QQQQQ).

A source must make the following reports:

Notification Reports

Initial notifications, including construction/reconstruction
63.9535(a-d), 63.05, 63.09(b) 

Notification of compliance status	63.9535(e), 63.09(h)

Performance of sludge test and determine mercury emissions.	61.54(a),
(c-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)(5-6)

Annual report on deviations	63.9540(c)



A source must keep the following records:

Recordkeeping

Maintain records of all reports and notifications	63.9550, 63.10(b)(1)

Maintain records for initial notification and notification of compliance
status	63.9545(a)(1), 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), 63.10(b)(2)(vi), (x-xi)



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a 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.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate solvent mixers at fiction
material manufacturing facility.

Write the notification 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 monitoring equipment that provides
parameter data in an automated way e.g., continuous parameter monitoring
system.  Although personnel at the source still need to evaluate the
data, this type of monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.

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 Online Tracking Information
System (OTIS).



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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note 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.

Information contained in the reports is entered into OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA delegated Authorities can
edit, store, retrieve, and analyze the data.

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

5(c)  Small Entity Flexibility

The majority of the respondents are large entities (i.e., 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 EPA considers these to be the minimum requirements
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 –
Reporting and Recordkeeping Requirements for the Friction Materials
Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal), below.

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.  Wherever 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	$118.92 ($56.63 + 110%)   

Technical	$97.78 ($46.56 + 110%)

Clerical	$48.76 ($23.22 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2010, "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.

The total operation and maintenance (O&M) costs consists of
photocopying, and postage are $1,088.  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 $1,100 (rounded).

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 $2,653.

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011
General Schedule” which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear in Table 2: Average Annual EPA Burden, NESHAP – Reporting
and Recordkeeping Requirements for the Friction Materials Manufacturing
(40 CFR Part 63, Subpart QQQQQ) (Renewal), below.

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 four respondents will be subject to the standard. 
It is estimated that no additional sources per year will become subject
in the next three years.  The overall average number of respondents, as
shown in the table below is four per year. 

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

Number of Respondents

Year	(A)

Number of New Respondents 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	0	4	0	0	4

2	0	4	0	0	4

3	0	4	0	0	4

Average	0	4	0	0	4

1 New respondents include sources with constructed, reconstructed, and
modified affected facilities.  In this standard, existing respondents
submit initial notifications. 

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.

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 (rounded)	8



The number of Total Annual Responses is eight.

The total annual labor costs are $122,373.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost:
NESHAP – Reporting and Recordkeeping Requirements for the Friction
Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal),
below.

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 annual labor costs are $122,373.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NESHAP – Reporting and Recordkeeping Requirements for the Friction
Materials Manufacturing (40 CFR Part 63, Subpart QQQQQ) (Renewal),
below.  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 $1,100.

(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 $2,653.  See Table 2: Annual
Agency Burden and Cost: NESHAP – Reporting and Recordkeeping
Requirements for the Friction Materials Manufacturing (40 CFR Part 63,
Subpart QQQQQ) (Renewal), below.

6(f)  Reasons for Change in Burden

	There is no change in the labor hours in this ICR as compared to the
previous ICR.  This situation 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 the industry is very low, negative, or non-existent, so there is no
significant change in the overall burden.  There is, however, an
increase in the estimated burden cost as currently identified in the OMB
Inventory of Approved Burdens.  The increase is not due to any program
changes.  The change in burden cost is due to the use of the most
updated labor rates.

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
EPA-HQ-OECA-2011-0204.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/"
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 content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than 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, 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 Docket 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, DC 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2011-0204 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 – Reporting and
Recordkeeping Requirements for the Friction Materials Manufacturing (40
CFR Part 63, Subpart QQQQQ) (Renewal).

Burden item	(A)

Person hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

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)

Cost, $  a

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Acquisition, installation and utilization of

     technology and systems	54	1	51	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	 See 4B







	    D.  Gather existing information	 See 4E 







	    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	$521.28

          Semiannual report of no deviation d	8	2	16	3.4	54.4	2.72	5.44
$5,907.94

          Startup, shutdown, malfunction report e	8	2	16	0.4	6.4	0.32
0.64	$695.05

Subtotal  for Reporting  Requirements





75.44



5.  Recordkeeping requirements









    A.  Read instructions 	4	1	4	0	0	0	0	$0

    B.  Plan activities	See 5E







	    C.  Implement activities	See 5E







	    D.  Develop record system	See 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
$37,272.21

          Records of block average solvent 

          weight g	2	52	104	4	416	20.8	41.6	$45,178.44

          Records of startup, shutdown,

          malfunction g	1	52	52	4	208	10.4	20.8	$22,589.22

          Copies of notifications/reports h	0.25	7	1.75	4	7	0.35	0.7
$670.21

    F.  Time to train personnel i	20	1	20	4	80	4	8	$8,688.16

    G.  Time to transmit or disclose

          information h	0.25	7	1.75	4	7	0.35	0.7	$760.21

    H.  Time to audit	N/A







	Subtotals for Recordkeeping Requirements  





1,220,38







	1,126.8	56.34	112.68	$122,372.72

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	1,295.82

1,296

(rounded)	$122,373



Assumptions:

a  This ICR uses the following labor rates:  $118.92 per hour for
Executive, Administrative, and Managerial labor; $97.78 per hour for
Technical labor, and $48.76 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December 2010, 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.

b  We have assumed that there are 4 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 the 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  We have 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 – Reporting and
Recordkeeping Requirements for the Friction Materials Manufacturing (40
CFR Part 63, Subpart QQQQQ) (Renewal).

Activity	(A)

EPA person- hours per occurrence	(B)

No. of occurrences per plant per year	(C)

EPA person- hours per plant per year

(C=AxB)	(D)

Plants 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)

Cost, $ a

1.  Excess emissions enforcement activities c	48	1	48	0.2	9.6	0.48	0.96
$497.52

2.  Report review









     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	$622.00

     Semiannual report of no deviation e	2	2	4	3.4	13.6	0.68	1.36
$704.81

     Startup, shutdown, malfunction report f	20	2	40	0.4	16	0.8	1.6
$829.20

Subtotals Labor Burden and cost



	51.2	2.56	5.12	$2,653.53

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	58.88

59 (rounded)	$2,653



 	Assumptions:

a  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses: $62.27 Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21
Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate
(GS-6, Step 3, $15.63 x 1.6).  These rates are from the Office of
Personnel Management (OPM) 2011 General Schedule which excludes locality
rates of pay.

 b  We have assumed that there are 4 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 the 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
regulations.

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