2045ss05

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal), EPA ICR Number 2045.05, OMB Control Number 2060-0550

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Automobile and Light-duty Truck Surface Coating were proposed on December 24, 2002, and promulgated on April 26, 2004. The rule was amended on both December 22, 2006 and on April 24, 2007, to further clarify what types of coating operations are subject to the NESHAP. These amendments neither affected nor altered the existing reporting, monitoring, or recordkeeping requirements previously published in the April 26, 2004 final rule. These regulations apply to new, reconstructed, or existing facilities that perform surface coating operations on automobiles and light-duty trucks. New facilities include those that commenced construction after December 24, 2002. This information is being collected to assure compliance with 40 CFR part 63, subpart IIII.

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 NEHSAP.

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

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

Over the next three years, an average of 65 respondents per year will be subject to these standards, and no additional respondents per year will become subject to the standard.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

The “Affected Public” are owners or operators of automobile and light-duty truck surface coating facilities. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors, and may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (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, hazards air pollutant (HAP) emissions from automobile and light-duty truck surface coating operations cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63, subpart IIII.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensures 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 test, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

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

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

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

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

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, duplication does not exist.

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 (77 FR 63813) on October 17, 2012. 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.

Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standards to make it easier to comply. In developing this ICR, EPA contacted: 1) the Alliance of Automobile Manufacturers, at (202) 326-5500, and 2) the American Coatings Association (ACA), at (202) 462-6272. EPA did not receive any comments from the consultations.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as to 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 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 or 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, 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 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 or 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 automobile and light-duty truck surface coating operations. The United States Standard Industrial Classification (SIC) codes and corresponding North American Industry Classification System (NAICS) codes for automobile and light-duty truck surface coating operations are provided in the following table.

Standard (40 CFR Part 63, Subpart IIII)	SIC Codes	NAICS Codes
Automobile Manufacturing	3711	336111
Light Truck and Utility Vehicle Manufacturing	3711	336112
Motor Vehicle Body Manufacturing	3711	336211

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII).

A source must make the following reports:

Notifications
Initial notification	63.3110(b), 63.5, 63.9(b)
Notification of compliance status	63.3110(c), 63.9(h)
Notification of construction/reconstruction	63.9(b), 63.5
Notification of actual startup	63.3110(a), 63.9(b)
Notification of performance test	63.3110(a), 63.7(b), 63.8(e), 63.9(e)

Reports
Semiannual compliance report	63.3120(a)
Excess emissions report	63.3120(a)(4-8)
Performance test report	63.3120(b), 63.10(d)(2)
Startup, shutdown, malfunction report	63.3120(c), 63.10(d)(5)

A source must keep the following records:

Recordkeeping
Copies of notifications and reports	63.3130(a)
Material formulation data	63.3130(b)
Records of HAP content calculations	63.3130(c)
Records of names of materials used	63.3130(d)
HAP fractions in each material used	63.3130(e)
Density of materials used	63.3130(f)
Documentation of deviations	63.3130(g)
Startup, shutdown, and malfunction plan/records	63.3130(h), 63.6(e)
Documentation of capture system efficiency determination	63.3130(i), 63.3130(j)
Documentation of add-on control device destruction or removal efficiency determination	63.3130(k)
Documentation of control device performance test	63.3130(k), 63.10(b)
Determination of capture system and add-on control operating limits and compliance	63.3130(l)
Determination of transfer efficiency	63.3130(m)
Work practice plan/records	63.3130(n)
Operating instructions for add-on control devices and CMS	63.3130(o)
Records should be retained for 5 years	63.3131(b), 63.10(b)

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.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for temperature, gas flow, or pressure drop for installed oxidizer, carbon adsorber, condenser, concentrator, or capture system.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 24, 25, 25A, 204, 204A to F, 311, or ASTM Method D1475-98, D2697-86, D5066-91, D5087-02, D5965-02, D6093-97, D6266-00a tests, 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.

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 and reporting equipment that provide 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

Observe initial performance tests and repeat performance tests if necessary.

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 could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and to note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in both compliance and enforcement programs.

Information contained in the reports is entered into OTIS, which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the OTIS 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

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 Agency 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 below in Table 1: Annual Respondent Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. 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 26,685 hours (Total Labor Hours from Table 1 below). 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 $122.49 ($58.33+ 110%)

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “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 (O&M) costs are the ongoing costs to maintain the monitor 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)
CEM	$16,000	0	$0	$1,200	65	$78,000
Total			$0			$78,000

The total capital/startup costs for this ICR are zero. This is the total of column D in the above table.

The total O&M costs for this ICR are $78,000. 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 $78,000. These are the costs of recordkeeping.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $114,428.

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), 2012 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 below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (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 65 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below, is 65 per year.

The number of respondents is calculated using the following table that 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	65	0	0	65
2	0	65	0	0	65
3	0	65	0	0	65
Average	0	65	0	0	65

¹ New respondent 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 65.

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
Initial notification	0	1	0	0
Notification of compliance status	0	1	0	0
Notification of construction/ reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of performance test 1	0	1.2	0	0
Report of performance test 1	0	1.2	0	0
Semiannual report	65	2	0	130
Excess emission report	65	2	0	130
Startup, shutdown, malfunction report 2	16	1	0	16
			Total	276

¹ This ICR assumes 20 percent of respondents will need to repeat the performance test.

² This ICR assumes 25 percent of respondents (25%* 65 = 16.25) will complete startup, shutdown, malfunction report.

The number of Total Annual Responses is 276.

The total annual labor costs are $2,610,147. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal).

6(e) Bottom Line 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 (below), respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 26,685 hours at a cost of $2,610,147. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 97 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $78,000. 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 2,539 labor hours at a cost of $114,428. See Table 2 below: Average Annual EPA Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR Part 63, Subpart IIII) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in respondent labor hours from the previous ICR. This is not due to any program changes. The increase is due to a mathematical correction in the per-respondent technical labor hours associated with burden item 4(d) in Table 1. Additionally, there is also an increase in the respondent and Agency costs due to use of updated labor rates. This ICR references recent labor rates from the Bureau of Labor Statistics to calculate respondent burden costs, and references recent labor rates from OPM to calculate Agency burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 97 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-2012-0690. 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 Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 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, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2012-0690 and OMB Control Number 2060-0550 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 Automobile and Light-duty Truck Surface Coating (40 CFR

Part 63, Subpart IIII) (Renewal)

Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year b ($)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
a. Read rule and instructions	4	1	4	65	260	13	26	$29,245.97
b. Required activities
i. Initial performance test c	24	1	24	0	0	0	0	$0
ii. Repeat performance test d	24	0.2	4.8	0	0	0	0	$0
iii. Compile and process data e	4	4	16	65	1,040	52	104	$116,983.88
c. Write reports
i. Initial notification	2	1	2	0	0	0	0	$0
ii. Notification of compliance status	2	1	2	0	0	0	0	$0
iii. Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
iv. Notification of actual startup	2	1	2	0	0	0	0	$0
v. Notification of performance test d	2	1	2	0	0	0	0	$0
vi. Report of performance test d	10	1	10	0	0	0	0	$0
vii. Semiannual report f	6	2	12	65	780	39	78	$87,737.91
viii. Excess emissions report g	2	2	4	65	260	13	26	$29,245.97
ix. Startup, shutdown, malfunction report h	2	1	2	16	32	1.6	3.2	$3,599.50
Subtotal for Reporting Requirements					2,727.8			$266,813.23
4. Recordkeeping Requirements
a. Read rule and instructions	4	1	4	65	260	13	26	$29,245.97
b. Plan activities	12	1	12	65	780	39	78	$87,737.91
c. Implement activities	12	1	12	65	780	39	78	$87,737.91
d. Maintain record system for material used i	20	2	40	65	2,600	130	260	$292,459.70
e. Time to enter information
i. Material usage j	0.5	365	182.5	65	11,862.5	593.13	1,186.25	$1,334,347.38
ii. Compliance calculation	2	12	24	65	1,560	78	156	$175,475.82
f. Time to train personnel	10	1	10	65	650	32.5	65	$73,114.90
g. Store, file and maintain records k	2	12	24	65	1,560	78	156	$175,475.82
h. Retrieve records/reports l	1	12	12	65	780	39	78	$87,737.91
Subtotal for Recordkeeping Requirements					23,957.38			$2,343,333.32
TOTAL ANNUAL BURDEN AND COST (rounded)					26,685			$2,610,147

Assumptions:

^a. We estimate that an average of 65 existing sources will be subject to the rule over the three-year period of this ICR, and no new sources will become subject.

^b. This ICR uses the following labor rates: $101.28 for technical, $122.49 for managerial, and $50.80 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “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.

^c. We assume it will take 24 hours to complete the initial performance test.

^d. We assume 20 percent of respondents will need to repeat the performance test.

^e. We assume each respondent will take four hours to compile and process data. This will occur four times per year.

^f. We assume each respondent will take six hours to complete each semiannual report.

^g. We assume each respondent will take two hours to complete excess emissions reports. This will occur two times per year.

^h. We assume 25 percent of respondents (25%*65 = 16.25) will use add-on controls, and that each will take two hours per year to complete the startup, shutdown, malfunction report.

^i. We assume it will take each respondent twenty hours to maintain the record system for materials used. This will occur two times per year.

^j. We assume each respondent will take 30 minutes to enter information on material usage. This will occur 365 times per year.

^k. We assume it will take each respondent two hours to store, file, and maintain records. This will occur twelve times per year.

^l. We assume it will take each respondent one hour to retrieve records or reports. This will occur twelve times per year.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Automobile and Light-duty Truck Surface Coating (40 CFR

Part 63, Subpart IIII) (Renewal)

Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year b ($)
1. Initial performance test c	24	1	24	0	0	0	0	$0
2. Repeat performance test d	24	0.2	4.8	0	0	0	0	$0
3. Report review
a. Initial notification	8	1	8	0	0	0	0	$0
b. Notification of compliance status	8	1	8	0	0	0	0	$0
c. Notification of construction/ reconstruction	8	1	8	0	0	0	0	$0
d. Notification of actual startup	8	1	8	0	0	0	0	$0
e. Notification of performance test d	8	1	8	0	0	0	0	$0
f. Report of performance test d	8	1	8	0	0	0	0	$0
g. Semiannual report e	12	2	24	65	1,560	78	156	$80,846.22
h. Excess emissions report f	4	2	8	65	520	26	52	$26,948.74
i. Startup, shutdown, malfunction report g	8	1	8	16	128	6.4	12.8	$6,633.54
TOTAL ANNUAL BURDEN AND COST (rounded)					2,539			$114,428

Assumptions:

^a. We estimate that 65 existing sources will be subject to the rule over the three-year period of this ICR, and that no new sources will become subject to the standard.

^b. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2012 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.

^c. We assume it will take 24 hours to complete the initial performance test review.

^d. We assume 20 percent of respondents will need to repeat the performance test.

^e. We assume it will take twelve hours to review semiannual reports.

^f. We assume it will take four hours to review excess emissions reports. This will occur twice per year.

^g. We assume 25 percent of respondents (25%*65 = 16.25) will use add-on controls, and that each report will take eight hours to review.