1 PART A OF THE SUPPORTING STATEMENT 1. Identification of the Information Collection ( a) Title and Number of the Information Collection " Reporting and Recordkeeping Requirements for the National Emission Standards for Hazardous Air Pollutants ( NESHAP) from Miscellaneous Coating Manufacturing." This is a new information collection request ( ICR), and a U. S. Environmental Protection Agency ( EPA) tracking number for this ICR is 2115.01.

( b) Short Characterization ( i) Applicability. Respondents are owners or operators of new and existing facilities that manufacture a miscellaneous coating and are located at, or are part of, major sources of hazardous air pollutant ( HAP) emissions. " Major source" means that the process equipment used to manufacture the miscellaneous coatings and any other operations or equipment at the facility emit, or have the potential to emit, 10 tons per year or more of a single HAP or 25 tons per year or more of any combination of HAP. A process is subject to the miscellaneous coating manufacturing NESHAP under the following criteria:

1. It is used to manufacture coatings, including inks,

paints, or adhesives described by Standard Industrial Classification ( SIC) codes 285 or 289 or North American Industrial Classification System ( NAICS) codes 3255 or 3259;

2. It processes, uses, or produces HAP.

3. It is not part of an affected source under another subpart of 40 CFR part 63.

Approximately 127 of the miscellaneous coating manufacturing facilities nationwide are expected to meet the applicability criteria defined in the rule. Three facilities are expected to 2 be constructed in the next 3 years, based on a 2 percent growth rate over the 3 years. ( A 2 percent increase over the next 3 years is approximately 0.85 facilities per year; rather than assume 0.85 facilities, we assumed 1 facility per year for the first 3 years in calculating the burden estimates.)

( ii) Miscellaneous coating manufacturing facilities. Owners or operators of miscellaneous coating manufacturing facilities subject to this rule must choose one of the compliance options described in the rule or install and monitor a specific control system that reduces HAP emissions to the compliance level.

Owners or operators are required to install, operate, and maintain a continuous monitoring system ( CMS) to demonstrate compliance with the emission limitations in Tables 1 through 3 and 5 through 6 of the rule and the operating limits in Table 7 of the rule; they must also record the values of equipment operating parameters as specified in Table 7 of the rule.

Owners or operators are required to conduct equipment inspections and equipment leak monitoring to demonstrate compliance with the work practice standards in Tables 1 through 5 of the rule.

The respondents are subject to sections of subpart A of 40 CFR part 63 relating to NESHAP. These requirements include those associated with the applicability determinations;

notifications that the facilities are subject to the rule;

notifications of performance tests; notifications of compliance status, including the results of performance tests and design evaluations; and semi annual compliance reports. In addition to the requirements of subpart A, many respondents are required to submit a precompliance report and leak detection and repair ( LDAR) reports, and existing facilities that wish to implement emissions averaging provisions must submit an emissions averaging plan.

All reports are to be submitted to the respondent's State or local agency or to the EPA Regional Office, whichever has been 3 delegated enforcement authority by EPA. The information is used to determine whether or not all sources subject to the rule are achieving the emission limitations and work practice standards in the rule.

( iii) Deviations from the standard. If the owner or operator identifies any deviation resulting from a known cause for which no Federally approved or promulgated exemption from an emission limitation or work practice standard applies, the compliance report must also include all records that the source is required to maintain that pertain to the periods during which such deviation occurred, as well as the following: the magnitude of each deviation; the reason for each deviation; a description of the corrective action taken for each deviation, including action taken to minimize each deviation and action taken to prevent recurrence; and a copy of all quality assurance activities performed on any element of the monitoring protocol.

( iv) Record retention. Owners or operators of a miscellaneous coating manufacturing facility must maintain a copy of all monitored equipment operating parameter values that demonstrate compliance with the operating limits in the rule, as well as records of inspections and results of equipment leak monitoring that demonstrate compliance with the work practice standards in the rule. Owners or operators are also required to maintain records of the occurrence and duration of any startup,

shutdown, or malfunction in the operation of a source, or any period during which the monitoring system is inoperative. Those records must be maintained for a minimum of 5 years. At a minimum, the most recent 2 years of data must be retained onsite.

The remaining 3 years of data may be retained offsite. 4 2. Need For and Use of the Collection ( a) Need/ Authority for the Collection The EPA is charged under section 112( d) of the Clean Air Act ( CAA), as amended, to establish emission standards for each category or subcategory of major and area sources of HAP listed for regulation in section 112( b). These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction.

The predominant HAP emitted from miscellaneous coating manufacturing facilities include toluene and xylene. In the Administrator's judgment, the pollutants emitted from miscellaneous coating manufacturing facilities cause or contribute significantly to air pollution that may reasonably be anticipated to endanger public health. Therefore, this category is listed for regulation under section 112. ( Note: The original source category list included several source categories as surface coating processes. The miscellaneous coating manufacturing NESHAP groups these source categories into one category and changes the name of the source category to Miscellaneous Coating Manufacturing.)

Section 114( a) of the CAA states that the Administrator may require any owner or operator subject to any requirement of the 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, as 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. 5 The required notifications are used to inform the EPA or delegated authority when a source becomes subject to the miscellaneous coating manufacturing NESHAP. The reviewing authority may then inspect the source to determine if the pollution control devices are properly installed and operated,

leaks are being detected and repaired, and the emission limitations and work practice standards in the rule are being met. Performance test reports are needed because they are EPA's record of a source's initial capability to comply with the emission limitations and work practice standards, and they serve as a record of the operating conditions under which compliance was achieved. The precompliance reports and emissions averaging plans are necessary to ensure that the emission limitations,

which are based on maximum achievable control technology ( MACT)

for miscellaneous coating manufacturing facilities, will be achieved.

After their compliance date, all respondents must submit semi annual ( every 6 months) compliance reports that contain the information requested in § 63.8050 of the rule. In addition,

respondents that elect to use the emissions averaging provisions in the rule must submit an emissions averaging report ( as specified in § 63.8060) as part of the semi annual report. The semi annual compliance reports are used for problem identification, as a check on source operation and maintenance,

and for compliance determinations. These records and reports are required under the General Provisions of 40 CFR part 63, subpart A ( as authorized under sections 101, 112, 114, 116, and 301 of the CAA as amended by Pub. L 101 549 [ 42 U. S. C. 7401, 7412, 7414,

7416, 7601]). 6 ( b) Practical Utility/ Users of the Data The information will be used by EPA enforcement personnel to: ( 1) identify new, modified, reconstructed, and existing sources subject to the rule; ( 2) ensure that MACT is being properly applied; and ( 3) ensure that the emission control devices are being properly operated and maintained on a continuous basis.

In addition, records and reports are necessary to enable EPA to identify miscellaneous coating manufacturing facilities that are not in compliance with the emission limitations and work practice standards in the rule. Based on reported information,

EPA can decide which miscellaneous coating manufacturing facilities should be inspected and what records or processes should be inspected at these facilities. The records that facilities maintain will indicate to EPA whether the owners or operators are in compliance with the emission limitations and work practice standards.

Much of the information EPA needs to determine compliance will be recorded on a continuous or daily basis. Other information will be recorded on a monthly, quarterly, annual, or other basis. Such information will be reviewed by enforcement personnel during an inspection and will need to be reported on a semi annual basis.

3. Nonduplication, Consultations, and Other Collection Criteria ( a) Nonduplication Certain reports required by State or local agencies may duplicate information required by the rule ( such as, reports of performance tests). In such cases, a copy of the report submitted to the State or local agency can be provided to the Administrator in lieu of the report required by the rule. 7 A search of existing rules revealed some duplication of information gathering efforts in those cases where facilities are subject to other rules in addition to the miscellaneous coating manufacturing NESHAP. In each case that has been identified, an effort has been made to eliminate this duplication. Two examples of these efforts are provided below.

The miscellaneous coating manufacturing NESHAP allows facilities that are also subject to the provisions of 40 CFR parts 264 and/ or 265 to comply with those provisions ( which constitutes compliance with the requirements of this rule) or with the provisions of this rule. If facilities comply with the provisions of 40 CFR parts 264 and/ or 265, then they must report the information described in § 63.8070 of this rule and identify in the notification of compliance status required by § 63.8070 the recordkeeping and reporting authority under which they will comply.

Also noted in the miscellaneous coating manufacturing NESHAP, facilities with an affected wastewater stream that is also subject to the provisions of 40 CFR parts 260 through 272 may determine whether this rule or 40 CFR parts 260 through 272 contain the more stringent requirements. Compliance with provisions of 40 CFR parts 260 through 272 that are determined to be more stringent than the requirements of this rule constitutes compliance with this rule. In the notification of compliance status required by § 63.8045, the facilities must identify the more stringent provisions of 40 CFR parts 260 through 272 with which they will comply, as well as provide the information and procedures that they used to make any stringency determinations. 8 ( b) Public Notice Required Prior to ICR Submission to OMB A public review and comment period will occur after proposal of the miscellaneous coating manufacturing NESHAP in the Federal Register.

( c) Consultations The EPA published a list of categories of major and area sources of HAP on July 16, 1992 ( 57 FR 21592), under authority of section 112( c); this notice listed most of the various source categories comprising the Miscellaneous Coating Manufacturing source category as categories of major sources of HAP. ( As noted above, this rule groups several surface coating process source categories into one category and changes the name of the source category to Miscellaneous Coating Manufacturing.)

Representatives of the affected companies and industry trade associations, including the Chemical Manufacturers Association and Synthetic Organic Chemical Manufacturers Association, were consulted during the development of the rule, and several meetings have been held with them during this time. During these meetings, the representatives were given the opportunity to comment on the regulatory approach. The major topics of these discussions included the applicability, MACT floor approach,

regulatory strategies, and the national impacts of the rule. No specific information was provided to the representatives with respect to burden estimates. 9 ( d) Effects of Less Frequent Data Collection.

In the 3 years following the effective date of the rule,

existing sources will submit only one time notifications to EPA.

In this instance, less frequent reporting would not be practical because EPA needs the information provided in these one time notifications. In addition to these one time notifications, new and reconstructed sources will also submit semi annual compliance reports in the 3 years following the effective date of the rule.

If the relevant information was collected less frequently, EPA would not be reasonably assured that the facilities are applying good operation and maintenance practices and meeting the emission limitations and work practice standards in the rule. Less frequent collection could decrease the likelihood of detection poor operation and maintenance of control equipment and long term deviations from the applicable emission limitations and work practice standards.

In addition, EPA's authority to take administrative action would be significantly reduced. Section 113( d) of the CAA limits the assessment of administrative penalties to deviations which occur no more than 12 months before initiation of the administrative proceeding. Since administrative proceedings are less costly and require fewer resources than judicial proceedings, both EPA and the regulated community benefit from preservation of EPA's administrative powers.

Also, the reporting frequency in the rule is consistent with the requirements of Title V permit programs. Consequently, less frequent reports would not result in a reduced burden.

( e) General Guidelines The miscellaneous coating manufacturing NESHAP requires that facilities retain records for a period of 5 years, which exceeds the 3 year retention period specified in the general information 10 collection guidelines in 5 CFR 1320.6( f) of the Office of Management and Budget ( OMB) regulations implementing the Paperwork Reduction Act. However, the 5 year retention period is consistent with the retention requirement in the General Provisions in subpart A of 40 CFR part 63 and the retention requirement in the operating permit program under 40 CFR part 70.

All sources subject to this rule will be required to obtain operating permits either through the State approved permitting program or, if one does not exist, in accordance with the provisions of 40 CFR part 71. Thus, the 5 year record retention requirement of the rule adds no additional burden. At a minimum,

respondents will be required to retain onsite the most recent 2 years of data. The remaining 3 years of data could be retained at a readily accessible onsite or offsite storage facility. None of the other guidelines in 5 CFR 1320.6 are being exceeded.

( f) Confidentiality 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 part 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999,

September 8, 1978; 43 FR 42251, September 28, 1978; and 44 FR 17674, March 23, 1979.)

( g) Sensitive Questions.

The information to be reported consists of emissions data and other information that are not of a sensitive nature.

Therefore, this section is not applicable because this ICR does not involve matters of a sensitive nature. 11 4. The Respondents and the Information Requested ( a) Respondents/ SIC and NAICS Codes Respondents are owners or operators of any facilities that engage in the manufacture of miscellaneous coatings and are classified as major sources under section 112 of the CAA. The primary SIC codes for the respondents affected by the miscellaneous coating manufacturing NESHAP are 285 ( Paints,

Varnishes, Lacquers, Enamels, and Allied Products) and 289 ( Miscellaneous Chemical Products). The primary NAICS codes are 3255 ( Paint, Coating, and Adhesive Manufacturing) and 3259 ( Other Chemical Product and Preparation Manufacturing). Not all processes classified in the SIC and NAICS codes above will be regulated by the miscellaneous coating manufacturing NESHAP ( i. e., they will not be regulated if they are already subject to another NESHAP).

( b) Information Requested ( i) Data items. Attachment 1, Source Data and Information Requirements, summarizes the reporting and recordkeeping requirements.

( ii) Respondent activities. The respondent activities required by the rule in the first 3 years following the effective date of the rule are listed in the first columns of Tables 1a through 1d and are presented in section 6( a). The respondent activities are described in more detail in Attachment 2,

Description of Respondent Activities.

Tables 1a, 1b, and 1c present the one time activities for the first, second, and third years, respectively, after the effective date of the rule. Table 1d presents the recurrent activities required by the rule in the first 3 years after the 12 effective date of the rule; this table presents the average number of respondents over the 3 years. 13 TABLE 1a. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 128 128 6 13 147 $ 6,552 B. Required Activities ° Initial CMS performance evaluatione 10 1 10 0 0 0 0 0 $ 0 C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/ reconstruction 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of anticipated startup 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of actual startup 2 1 2 1 2 0.1 0.2 2 $ 102 14 TABLE 1a. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c ° Notification of applicability of standard Existing sources 2 1 2 127 254 13 25 292 $ 13,002 New sources 2 1 2 1 2 0.1 0.2 2 $ 102 ° Emissions averaging planf 40 1 40 0 0 0 0 0 $ 0 ° Precompliance reportg 40 1 40 1 40 2 4 46 $ 2,048 ° Notification of initial performance testh 2 1 2 0 0 0 0 0 $ 0 ° Notification of initial CMS performance evaluatione 2 1 2 0 0 0 0 0 $ 0 ° Notification of compliance status With performance testh 80 1 80 0 0 0 0 0 $ 0 Without performance testi 120 1 120 1 120 6 12 138 $ 6,143 15 TABLE 1a. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E * 0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemj 40 1 40 1 40 2 4 46 $ 2,048 E. Develop Startup,

Shutdown, Malfunction Plank 100 1 100 1 100 5 10 115 $ 5,119 F. Develop QA/ QC Plan for CMSl 40 1 40 0 0 0 0 0 $ 0 G. Time to Train Personnelm 40 1 40 1 40 2 4 46 $ 2,048 H. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDE: n 730 37 73 840 $ 37,369 Average first year cost per facilityo 128 $ 292 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

c Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

d This will occur only in the first year after a facility becomes subject to the rule. 16 TABLE 1a. ( continued)

e Person hours per occurrence are based on the performance specification costs to certify CMS ($ 500) divided by the composite hourly labor rate. No performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard,

which requires CEMS and performance evaluations.

f Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

g Assumes 50 percent of facilities will submit a precompliance report.

h Assumes one existing facility and no new facilities will be required to conduct a performance test( s). The notification of compliance status includes the report of the performance test( s).

i Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

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

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

l Assumes 40 hours to develop and review the QA/ QC plan for the CMS. No QA/ QC plan is required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and QA/ QC plans.

m Assumes 40 hours to train personnel.

n The one time burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

o The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 128) subject to the rule. 17 TABLE 1b. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 1 1 0.05 0.1 1 $ 51 B. Required Activities Initial CMS performance evaluatione 10 1 10 0 0 0 0 0 $ 0 C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/ reconstruction 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of anticipated startup 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of actual startup 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of applicability of standard Existing sources 2 1 2 0 0 0 0 0 $ 0 New sources 2 1 2 1 2 0.1 0.2 2 $ 102 18 TABLE 1b. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c ° Emissions averaging planf 40 1 40 13 520 26 52 598 $ 26,619 ° Precompliance reportg 40 1 40 64 2,560 128 256 2,944 $ 131,048 ° Notification of initial performance testh 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of initial CMS performance evaluatione 2 1 2 0 0 0 0 0 $ 0 ° Notification of compliance status With performance testh 80 1 80 0 0 0 0 0 $ 0 Without performance testi 120 1 120 1 120 6 12 138 $ 6,143 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record System j 40 1 40 1 40 2 4 46 $ 2,048 19 TABLE 1b. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c E. Develop Startup,

Shutdown, Malfunction Plank 100 1 100 1 100 5 10 115 $ 5,119 F. Develop QA/ QC Plan for CMSl 40 1 40 0 0 0 0 0 $ 0 G. Time to Train Personnel m 40 1 40 1 40 2 4 46 $ 2,048 H. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDE: n 3,391 170 339 3,900 $ 173,587 Average second year cost per facilityo 129 $ 1,346 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

c Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

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

e Person hours per occurrence are based on the performance specification costs to certify CMS ($ 500) divided by the composite hourly labor rate. No performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard,

which requires CEMS and performance evaluations.

f Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

g Assumes 50 percent of facilities will submit a precompliance report.

h Assumes one existing facility and no new facilities will be required to conduct a performance test( s). The notification of compliance status includes the report of the performance test( s).

i Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

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

k Assumes 80 hours to draft the startup, shutdown, and malfunction plan and another 20 hours of review/ revisions, for a total of 100 hours. 20 TABLE 1b. ( continued)

l Assumes 40 hours to develop and review the QA/ QC plan for the CMS. No QA/ QC plan is required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and QA/ QC plans.

m Assumes 40 hours to train personnel.

n The one time burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

o The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 129) subject to the rule. 21 TABLE 1c. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS THIRD YEAR FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical personhours per year ( G = E *

0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsd 1 1 1 1 1 0.05 0.1 1 $ 51 B. Required Activities ° Initial CMS performance evaluatione 10 1 10 0 0 0 0 0 $ 0 C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/ reconstruction 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of anticipated startup 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of actual startup 2 1 2 1 2 0.1 0.2 2 $ 102 ° Notification of applicability of standard Existing sources 2 1 2 0 0 0 0 0 $ 0 New sources 2 1 2 1 2 0.1 0.2 2 $ 102 ° Emissions averaging planf 40 1 40 0 0 0 0 0 $ 0 ° Precompliance reportg 40 1 40 1 40 2 4 46 $ 2,048 ° Notification of initial performance testh 2 1 2 0 0 0 0 0 $ 0 22 TABLE 1c. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical personhours per year ( G = E *

0.1) H Respondent person hours per year ( H = E + F + G) I Labor cost,

$ c ° Notification of initial CMS performance evaluatione 2 1 2 0 0 0 0 0 $ 0 ° Notification of compliance status With performance testh 80 1 80 1 80 4 8 92 $ 4,095 Without performance testi 120 1 120 128 15,360 768 1,536 17,664 $ 786,286 4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemj 40 1 40 1 40 2 4 46 $ 2,048 E. Develop Startup, Shutdown,

Malfunction Plank 100 1 100 1 100 5 10 115 $ 5,119 F. Develop QA/ QC Plan for CMSl 40 1 40 0 0 0 0 0 $ 0 G. Time to Train Personnelm 40 1 40 1 40 2 4 46 $ 2,048 H. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDE: n 15,669 783 1,567 18,019 $ 802,104 Average third year cost per facilityo 130 $ 6,170 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

c Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

d This will occur only in the first year after a facility becomes subject to the rule. 23 TABLE 1c. ( continued)

e Person hours per occurrence are based on the performance specification costs to certify CMS ($ 500) divided by the composite hourly labor rate. No performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard,

which requires CEMS and performance evaluations.

f Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

g Assumes 50 percent of facilities will submit a precompliance report.

h Assumes one existing facility and no new facilities will be required to conduct a performance test( s). The notification of compliance status includes the report of the performance test( s).

i Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

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

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

l Assumes 40 hours to develop and review the QA/ QC plan for the CMS. No QA/ QC plan is required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and QA/ QC plans.

m Assumes 40 hours to train personnel.

n The one time burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

o The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 130) subject to the rule. 24 TABLE 1d. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS AVERAGE OF FIRST, SECOND, AND THIRD YEARS FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent personhours per year ( H = E + F + G) I Labor cost,

$ c 1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructions N/ A B. Required Activities N/ A C. Create Information N/ A D. Gather Existing Information N/ A E. Write Report ° Notification of process changed 8 1 8 0 0 0 0 0 $ 0 ° Semi annual compliance report No deviationse 8 2 16 2 32 2 3 37 $ 1,638 Deviationse 24 2 48 0 0 0 0 0 $ 0 Startup, shutdown, and malfunction reportf 8 2 16 2 32 2 3 37 $ 1,638 LDAR reportg 404 2 808 2 342 17 34 393 $ 17,499 Emissions averaging reporth 20 2 40 0 0 0 0 0 $ 0 4. Recordkeeping Requirements A. Read Instructions N/ A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record System N/ A 25 TABLE 1d. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) D Respondents per yearb E Technical person hours per year ( E = C * D) F Management person hours per year ( F = E *

0.05) G Clerical person hours per year ( G = E * 0.1) H Respondent personhours per year ( H = E + F + G) I Labor cost,

$ c E. Time to Enter Information ° Records of startup,

shutdown, and malfunction 1.5 52 78 2 156 8 16 179 $ 7,986 ° Records of CMS data Record continuously monitored parametersi 1 365 365 2 730 37 73 840 $ 37,369 Compile datai 24 2 48 2 96 5 10 110 $ 4,914 Enter/ verify information for semi annual reportsi 16 2 32 2 64 3 6 74 $ 3,276 LDAR recordkeeping Included in 3E F. Calibration of CMSj 376 1 376 2 752 38 75 865 $ 38,495 G. Time to Train Personnel N/ A H. Time for Refresher Training for Personnelk 16 1 16 2 16 1 2 18 $ 819 I. Time for Audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: l 2,220 111 222 2,553 $ 113,635 Average cost per facilitym 2 $ 56,817 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

c Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

d Assumes 10 percent of facilities will implement process changes.

e Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations. 26 TABLE 1d. ( continued)

f Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the startup, shutdown, and malfunction plan.

g According to EPA guidance, annual recordkeeping and reporting coasts for the LDAR program are estimated to be 40 percent of monitoring and repair labor, which averages $ 10,937 per facility ( 40% * $ 10,937 = $ 4,375 per facility). Person hours per occurrence are based on this cost divided by the composite hourly labor rate.

h Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

i Includes process vessel, storage tank, transfer operation, and wastewater monitoring and inspections.

j Assumes calibration of the CMS will require 8 hours per year for each monitor. Assuming 1 CMS for each process vessel and 47 process vessels per facility, a total of 376 hours per year per facility is required.

k Assumes 2 days ( 16 hours) to provide refresher training for personnel.

l The recurrent burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

m The average facility cost is calculated by dividing the total facility burden by the number of facilities ( 2) complying with the rule. 27 5. The Information Collected Agency Activities, Collection Methodology, and Information Management ( a) Agency Activities The Agency activities in the first 3 years following the effective date of the rule are listed in the first columns of Tables 2a through 2c and are presented in section 6( c).

Tables 2a, 2b, and 2c present the Agency activities for the first, second, and third years, respectively, after the effective date of the rule.

( b) Collection Methodology and Management Information contained in the initial, one time only notifications will be entered in the Aerometric Information Retrieval System ( AIRS) Facility Subsystem operated and maintained by EPA's Office of Air Quality Planning and Standards ( OAQPS). AIRS is EPA's database for the collection, maintenance,

and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government owned facilities. The EPA uses AIRS for tracking air pollution compliance and enforcement by State and local agencies and EPA Regional Offices and Headquarters. The EPA and its delegated authorities can edit, store, retrieve, and analyze the data. The AIRS database can be publicly accessed via the Internet at http:// www. epa. gov/ enviro/ index_ java. html or through a Freedom of Information Act request to EPA. Data obtained during periodic visits by EPA personnel, from records maintained by the respondents, and from information provided in semi annual reports will be tabulated and published for internal EPA use in compliance and enforcement programs.

The rule does not require the use of automated, electronic,

mechanical, or other technology data collection techniques or 28 TABLE 2a. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FIRST YEAR FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b 1. Attend Initial Performance Testc 40 0 0 0 0 0 $ 0 2. Attend Repeat Performance Testd 40 0 0 0 0 0 $ 0 3. Attend Initial CMS Performance Evaluatione 2 0 0 0 0 0 $ 0 4. Litigation N/ A 5. Report Review A. Review Notification of Construction/ Reconstruction 2 1 2 0.1 0.2 2 $ 102 B. Review Notification of Anticipated Startup 2 1 2 0.1 0.2 2 $ 102 C. Review Notification of Actual Startup 2 1 2 0.1 0.2 2 $ 102 D. Review Notification of Applicability of Standard 2 128 256 13 26 294 $ 13,105 E. Review Emissions Averaging Planf 20 0 0 0 0 0 $ 0 F. Review Precompliance Reportg 4 1 4 0.2 0.4 5 $ 205 G. Review Notification of Initial Performance Test 2 0 0 0 0 0 $ 0 H. Review Notification of Initial CMS Performance Evaluatione 2 0 0 0 0 0 $ 0 I. Review Notification of Compliance Status ° With performance testh 40 0 0 0 0 0 $ 0 ° Without performance testi 40 1 40 2 4 46 $ 2,048 J. Review Notification of Process Changej 8 0 0 0 0 0 $ 0 29 TABLE 2a. ( continued)

Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b K. Review Semi Annual Compliance Report ° No deviationsk 2 2 4 0.2 0.4 5 $ 205 ° Deviationsk 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportl 2 2 4 0.2 0.4 5 $ 205 ° LDAR reportm 8 2 16 0.8 2 18 $ 819 ° Emissions averaging reportf 8 0 0 0 0 0 $ 0 TOTAL BURDEN AND COST ( SALARY): n 330 17 33 380 $ 16,893 TRAVEL EXPENSES FOR TEST ATTENDEDo = ( 1 person * 0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 0 round trip/ yr): $ 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: $ 16,893 a Operations per year are equal to the number of operations ( e. g., performance tests, notifications, reports) per facility times the number of facilities. There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

c Assumes one existing facility and no new facilities will conduct initial performance tests, and EPA personnel will attend 10 percent of the initial tests ( approximately 0 tests).

d Assumes no repeat performance tests.

e Assumes no performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and performance evaluations.

f Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

g Assumes 50 percent of facilities will submit a precompliance report.

h Assumes one existing facility and no new facilities will conduct initial performance tests. The notification of compliance status includes the report of the performance tests.

i Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations. 30 TABLE 2a. ( continued)

j Assumes 10 percent of facilities will implement process changes.

k Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations. 90 percent of 1 facility with no deviations reporting twice per year is 2 operations. 10 percent of 1 facility with deviations reporting twice per year is 0 operations.

l Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the startup, shutdown, and malfunction plan.

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

n The burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

o Tests attended include no initial performance tests, no repeat performance tests, for a total of 0 tests attended. 31 TABLE 2b. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS SECOND YEAR FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b 1. Attend Initial Performance Testc 40 0 0 0 0 0 $ 0 2. Attend Repeat Performance Testd 40 0 0 0 0 0 $ 0 3. Attend Initial CMS Performance Evaluatione 2 0 0 0 0 0 $ 0 4. Litigation N/ A 5. Report Review A. Review Notification of Construction/ Reconstruction 2 1 2 0.1 0.2 2 $ 102 B. Review Notification of Anticipated Startup 2 1 2 0.1 0.2 2 $ 102 C. Review Notification of Actual Startup 2 1 2 0.1 0.2 2 $ 102 D. Review Notification of Applicability of Standard 2 1 2 0.1 0.2 2 $ 102 E. Review Emissions Averaging Planf 20 13 260 13 26 299 $ 13,310 F. Review Precompliance Reportg 4 64 256 13 26 294 $ 13,105 G. Review Notification of Initial Performance Test 2 1 2 0.1 0.2 2 $ 102 H. Review Notification of Initial CMS Performance Evaluatione 2 0 0 0 0 0 $ 0 I. Review Notification of Compliance Status ° With performance testh 40 0 0 0 0 0 $ 0 ° Without performance testi 40 1 40 2 4 46 $ 2,048 J. Review Notification of Process Changej 8 0 0 0 0 0 $ 0 32 TABLE 2b. ( continued)

Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b K. Review Semi Annual Compliance Report ° No deviationsk 2 4 8 0.4 0.8 9 $ 410 ° Deviationsk 8 0 0 0 0 0 $ 0 ° Startup, shutdown, and malfunction reportl 2 4 8 0.4 0.8 9 $ 410 ° LDAR reportm 8 4 32 2 3 37 $ 1,638 ° Emissions averaging reportf 8 0 0 0 0 0 $ 0 TOTAL BURDEN AND COST ( SALARY): n 614 31 61 706 $ 31,431 TRAVEL EXPENSES FOR TEST ATTENDEDo = ( 1 person * 0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 0 round trip/ yr): $ 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: $ 31,431 a Operations per year are equal to the number of operations ( e. g., performance tests, notifications, reports) per facility times the number of facilities. There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

c Assumes one existing facility and no new facilities will conduct initial performance tests, and EPA personnel will attend 10 percent of the initial tests ( approximately 0 tests).

d Assumes no repeat performance tests.

e Assumes no performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and performance evaluations.

f Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

g Assumes 50 percent of facilities will submit a precompliance report.

h Assumes one existing facility and no new facilities will conduct initial performance tests. The notification of compliance status includes the report of the performance tests. 33 TABLE 2b. ( continued)

i Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

j Assumes 10 percent of facilities will implement process changes.

k Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations. 90 percent of 1 facility with no deviations reporting twice per year is 2 operations. 10 percent of 1 facility with deviations reporting twice per year is 0 operations.

l Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the startup, shutdown, and malfunction plan.

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

n The burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

o Tests attended include no initial performance tests, no repeat performance tests, for a total of 0 tests attended. 34 TABLE 2c. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS THIRD YEAR FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b 1. Attend Initial Performance Testc 40 0 0 0 0 0 $ 0 2. Attend Repeat Performance Testd 40 0 0 0 0 0 $ 0 3. Attend Initial CMS Performance Evaluatione 2 0 0 0 0 0 $ 0 4. Litigation N/ A 5. Report Review A. Review Notification of Construction/ Reconstruction 2 1 2 0.1 0.2 2 $ 102 B. Review Notification of Anticipated Startup 2 1 2 0.1 0.2 2 $ 102 C. Review Notification of Actual Startup 2 1 2 0.1 0.2 2 $ 102 D. Review Notification of Applicability of Standard 2 1 2 0.1 0.2 2 $ 102 E. Review Emissions Averaging Planf 20 0 0 0 0 0 $ 0 F. Review Precompliance Reportg 4 1 4 0.2 0.4 5 $ 205 G. Review Notification of Initial Performance Test 2 0 0 0 0 0 $ 0 H. Review Notification of Initial CMS Performance Evaluatione 2 0 0 0 0 0 $ 0 I. Review Notification of Compliance Status ° With performance testh 40 1 40 2 4 46 $ 2,048 ° Without performance testi 40 128 5,120 256 512 5,888 $ 262,095 J. Review Notification of Process Changej 8 0 0 0 0 0 $ 0 K. Review Semi Annual Compliance Report ° No deviationsk 2 5 10 0.5 1 12 $ 512 ° Deviationsk 8 1 8 0.4 0.8 9 $ 410 35 TABLE 2c. ( continued)

Activity A EPA hours per operation B Operations per yeara C Technical person hours per year ( C = A * B) D Management person hours per year ( D = C * 0.05) E Clerical person hours per year ( E = C * 0.1) F Total person hours per year ( F = C + D + E) G Labor cost,

$ b ° Startup, shutdown, and malfunction reportl 2 6 12 0.6 1 14 $ 614 ° LDAR reportm 8 6 48 2 5 55 $ 2,457 ° Emissions averaging reportf 8 0 0 0 0 0 $ 0 TOTAL BURDEN AND COST ( SALARY): n 5,250 263 525 6,038 $ 268,750 TRAVEL EXPENSES FOR TEST ATTENDEDo = ( 1 person * 0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip * 0 round trips/ yr): $ 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: $ 268,750 a Operations per year are equal to the number of operations ( e. g., performance tests, notifications, reports) per facility times the number of facilities. There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b Labor cost assumes a rate of $ 45.04/ hour for technical labor, $ 66.73/ hour for management labor, and $ 28.14/ hour for clerical labor.

c Assumes one existing facility and no new facilities will conduct initial performance tests, and EPA personnel will attend 10 percent of the initial tests ( approximately 0 tests).

d Assumes no repeat performance tests.

e Assumes no performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and performance evaluations.

f Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

g Assumes 50 percent of facilities will submit a precompliance report.

h Assumes one existing facility and no new facilities will conduct initial performance tests. The notification of compliance status includes the report of the performance tests.

i Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

j Assumes 10 percent of facilities will implement process changes.

k Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations. 90 percent of 1 facility with no deviations reporting twice per year is 2 operations. 10 percent of 1 facility with deviations reporting twice per year is 0 operations. 36 TABLE 2c. ( continued)

l Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the startup, shutdown, and malfunction plan.

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

n The burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

o Tests attended include no initial performance tests, no repeat performance tests, for a total of 0 tests attended. 37 other forms of information technology. Although many of the large companies have elaborate collection methods, automated systems are not expected to reduce the burden.

( c) Small Entity Flexibility Minimizing the information collection burden for all sizes of organizations is a continuing effort by EPA. The EPA has reduced the reporting and recordkeeping burden for respondents to include only the information that EPA needs to determine compliance with the rule. Few of the 127 existing facilities subject to the miscellaneous coating manufacturing NESHAP are expected to meet the applicability criteria for small businesses.

The EPA does not expect that small coating manufacturing businesses will experience adverse impacts related to the cost of the required reporting and recordkeeping.

( d) Collection Schedule Collection of data will begin after the effective date of the miscellaneous coating manufacturing NESHAP. The schedule for notifications and reports required by the rule is summarized below.

For all existing miscellaneous coating manufacturing facilities, the initial notification report stating that the facility is subject to the rule must be submitted no later than 4 months ( 120 days) after the effective date of the rule. New or reconstructed miscellaneous coating manufacturing facilities for which startup occurs on or after the effective date must submit the initial notification no later than 120 days after the source becomes subject to the rule. New or reconstructed facilities must comply immediately upon the effective date of the final rule if their date is before the effective date or upon startup if the startup date is on or after the effective date. 38 Facilities required to conduct a performance test must submit a notification of intent to conduct a performance test at least 60 days before the performance test is scheduled to begin.

For each initial compliance demonstration that does not include a performance test, facilities must submit an initial notification of compliance status no later than 30 days following the completion of the initial compliance demonstration. For each initial compliance demonstration that includes a performance test, facilities must submit an initial notification of compliance status no later than 60 days following the completion of the performance test. If averaging emissions, existing facilities must also submit an emissions averaging plan at least 18 months before their compliance date.

Records necessary to determine compliance will be compiled on a daily basis, and compliance reports must be submitted to the Administrator on a semi annual basis, as discussed in section 1( b).

6. Estimating The Burden and Cost of the Collection ( a) Estimating Respondent Burden The annual burden estimates for reporting and recordkeeping activities are presented in Tables 1a through 1d. Tables 1a, 1b,

and 1c present the estimated one time burden to the industry for reporting and recordkeeping activities during the first, second,

and third years, respectively, after the effective date of the rule. Table 1d presents the average recurrent burden to the industry during each of the 3 years following the effective date of the rule. The burden estimates in each table were derived from estimates based on EPA's experience with similar information collection requirements in other standards development efforts. 39 ( b) Estimating Respondent Costs ( i) Estimating labor costs. The annual labor costs for reporting and recordkeeping activities are also presented in Tables 1a through 1d. The costs of these activities were estimated based on data from the U. S. Bureau of Labor Statistics.

Labor costs are divided into the following three categories:

( 1) technical, ( 2) management, and ( 3) clerical. The cost of technical labor was estimated at $ 45.04 per hour ($ 45.04/ hr), the cost of management labor at $ 66.73/ hr, and the cost of clerical labor at $ 28.14/ hr. These estimates include fringe benefits,

overhead, and profit rate.

( ii) Estimating capital and O& M costs. There are two types of non labor related costs associated with information collection activities: capital costs and operation and maintenance ( O& M)

costs. The methods used to estimate the capital and O& M costs for this Supporting Statement are presented in Attachment 3,

Methods Used in Cost Estimates.

One time capital costs usually include any produced physical good, such as computers, machinery, or equipment, that must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital costs are usually incurred only once, at the beginning of an information collection period. A one time capital cost can be estimated over multiple years by annualizing the cost using an OMB approved interest rate. For this Supporting Statement, capital costs were annualized over 10 years for transfer operations and 15 years for process vessels and wastewater operations, assuming an interest rate of 7 percent. In most cases, administrative charges,

insurance, and property taxes were also included with the annualized capital costs, at 4 percent of the capital cost.

The capital costs associated with monitoring equipment include the monitoring equipment, installation, ancillary costs 40 ( planning and selection), and a data acquisition system ( DAS)

( data logger, computer, logging and reporting software, and printer). The capital costs for the monitoring equipment were estimated based on the following assumptions: ( 1) the monitoring equipment cost per facility is $ 29,986 for process vessels, which includes the cost for thermocouple, wire, and DAS; ( 2) one new facility will purchase this equipment for process vessels in each of the first 3 years after the effective date of the rule; ( 3) no new facilities will purchase monitoring equipment for transfer operations or wastewater systems; and ( 4) no monitoring equipment are required for storage tanks.

The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility ( assume $ 235 per file cabinet). An estimated one new facility will purchase this equipment in each of the first 3 years after the effective date of the rule.

Costs for performance testing are also considered capital costs because it is expected that facilities will hire a contractor to conduct the test. The capital costs associated with performance testing include the costs for performance tests for transfer operations at existing facilities. Performance test costs were estimated based on the following assumptions:

( 1) capital costs per test are $ 24,420; ( 2) one existing facility with transfer operations will conduct a performance test in the third year after the effective date; ( 3) no new facilities will conduct a performance test; ( 4) no performance tests are required for process vessels, storage tanks, or wastewater systems; and ( 5) no facilities will repeat the performance test. Because no equipment is purchased, no administrative charges, insurance, or property taxes were estimated for performance testing.

Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as 41 monitoring equipment. Those costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. The monitoring labor costs for process vessels were estimated based on 8,760 operating hours per year,

0.5 hour of labor per 8 hr shift, and a wage rate of $ 17.21/ hr.

Maintenance materials and supplies were estimated at $ 500.

Overhead was estimated at 60 percent of labor costs plus maintenance materials and supplies costs. The O& M cost per facility associated with the monitoring equipment is $ 15,875 for process vessels. Because no new facilities are expected to purchase monitoring equipment for transfer operations or wastewater systems and no monitoring equipment are required for storage tanks, there are no O& M costs associated with the monitoring equipment for these emission points for the first 3 years after the effective date of the rule.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. For example, the O& M costs for rules that require respondents to submit reports to EPA and maintain records should be estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 28.14/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Photocopying and postage costs will be applied to the 135 responses submitted during the first year, the 87 responses submitted during the second year, and the 140 responses submitted during the third year. ( The number of responses was determined by adding the number of reports submitted to EPA by respondents, as shown in Tables 1a through 1d.) 42 ( c) Estimating Agency Burden and Costs Because the information collection requirements were developed as an incidental part of the standards development, no costs can be attributed to the development of these requirements.

In addition, no operational costs will be incurred by the Federal Government because reporting and recordkeeping requirements on the part of the respondents are required under section 112 of the CAA. Publication and distribution of the information are part of the AIRS Facility Subsystem, with the result that no Federal costs can be attributed to the ICR.

Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of facilities. Periodic inspections are part of EPA's overall compliance and enforcement program. Therefore, this examination is not attributable to the ICR.

The only costs that the Federal Government will incur are user costs associated with the analysis of the information reported by the facilities in one time notifications and semiannual compliance reports ( unless the compliance report indicates a deviation, thereby triggering an enforcement action). Tables 2a, 2b, and 2c present the estimated annual burden to the Federal Government during the first, second, and third years,

respectively, after the effective date of the rule. Labor costs were estimated based on estimated wage rates of $ 45.04/ hr for technical labor, $ 66.73/ hr for management labor, and $ 28.14/ hr for clerical labor.

( d) Estimating the Respondent Universe and Total Burden and Costs Once the burden and costs per activity have been established on a per respondent basis, the total burden and cost must be calculated for all respondents and for EPA. To calculate the 43 total burden and costs, the number of respondents needed to complete each information collection activity must be estimated.

The total number of respondents is also referred to as the " respondent universe." The respondent universe varies among the activities listed because not all respondents must complete each activity.

The respondent universe for this ICR is based on data collected from nearly 130 sources in SIC Codes 285 and 289. The burden and costs were estimated for an existing respondent universe of 127 miscellaneous coating manufacturing facilities and a projected new respondent universe of 3 miscellaneous coating manufacturing facilities over the first 3 years after the effective date.

To determine the burden for each activity for technical staff, the number of hours per respondent was multiplied by the number of respondents. Management and clerical labor hours were calculated at 5 percent and 10 percent of technical labor hours,

respectively. The total burden was determined by summing the technical, management, and clerical burden estimates. To determine the total labor cost, the burden estimates for technical, management, and clerical labor were multiplied by their respective wage rates and then summed.

( e) Bottom Line Burden Hours and Cost Tables ( i) Respondent tally. The bottom line annual respondent burden hours and costs were calculated by adding the total person hours and costs from Tables 1a, 1b, and 1c, dividing the sums by the 3 year review period, and then adding the average recurrent burden and costs from Table 1d. The total annual respondent burden hours and costs are summarized as follows: 44 Total burden, hours Total costs, $

Table 1a ( one time activities in first year) 840 $ 37,369 Table 1b ( one time activities in second year) 3,900 $ 173,587 Table 1c ( one time activities in third year) 18,019 $ 802,104 Table 1d * 3 ( recurrent activities in all 3 years) 7,658 $ 340,905 Total 30,417 $ 1,353,965 Bottom line annual burden 10,139 $ 451,322 The bottom line annual burden, averaged over the first 3 years after the effective date, is 10,139 labor hours, at a cost of $ 451,322. The average annual burden per respondent,

based on an average 129 respondents over the 3 year review period, is 79 labor hours, at a cost of $ 3,499.

There are an estimated 121 total annual responses for the first 3 years after the effective date. The total annual responses are based on an estimated 135 one time and recurrent notifications and reports submitted during the first year, 87 during the second year, and 140 during the third year. Of these 121 total annual responses, approximately 20 percent are assumed to be collected electronically.

The total nationwide capital cost associated with monitoring equipment was estimated to be $ 29,986 in each of the first 3 years after the effective date of the rule. The average annualized capital cost for the monitoring equipment is $ 8,984 for the 3 years following the effective date.

The total nationwide capital cost associated with file cabinets for storing collected data and reports was estimated to be $ 235 in each of the first 3 years after the effective date of 45 the rule. The average annualized capital cost for file cabinets is $ 70 for the 3 years following the effective date.

The total nationwide capital cost for performance tests was estimated to be $ 0 for the first 2 years after the effective date of the rule and $ 24,420 for the third year after the effective date. The average annualized capital cost for the performance tests is $ 1,159 for the 3 years following the effective date.

Annual O& M costs, which include monitoring labor,

maintenance materials and supplies, and overhead for the monitoring equipment, as well as photocopying and postage for the reports, average $ 34,369 for the 3 years following the effective date of the rule.

Combining the annualized capital costs for the monitoring equipment, file cabinets, and performance tests results in a total annualized capital cost of $ 10,213 for the 3 years following the effective date. Summing this total annualized capital cost with the annual O& M cost gives a total annualized cost of $ 44,582 for the 3 years following the effective date. A discussion of the respondent burden and costs in later years is provided in Attachment 4, Burden and Cost of Reporting and Recordkeeping Requirements for the Fourth, Fifth, and Sixth Years Following the Effective Date.

( ii) Agency tally. The bottom line annual Agency burden hours and costs were calculated by adding the total person hours and costs from Tables 2a, 2b, and 2c and then dividing by the 3 year review period. The total annual Agency burden hours and costs are summarized as follows: 46 Total burden, hours Total costs, $

Table 2a ( first year) 380 $ 16,893 Table 2b ( second year) 706 $ 31,431 Table 2c ( third year) 6,038 $ 268,750 Total 7,123 $ 317,074 Bottom line annual burden 2,374 $ 105,691 The bottom line annual burden, averaged over the first 3 years after the effective date, is 2,374 labor hours, at a cost of $ 105,691. A discussion of the Agency burden and costs in later years is provided in Attachment 4, Burden and Cost of Reporting and Recordkeeping Requirements for the Fourth, Fifth,

and Sixth Years Following the Effective Date.

( iii) The complex collection. This section does not apply because this collection is a simple collection.

( iv) Variations in the annual bottom line. The annual burden hours and costs associated with one time activities vary over the course of the 3 year review period because existing sources are subject to different requirements in each year as follows: ( 1) determining applicability and notifying EPA that the facility is subject to the rule in the first year; ( 2) developing and submitting an emissions averaging plan ( if appropriate) and a precompliance report and notifying EPA of upcoming performance tests in the second year; and ( 3) conducting performance tests and submitting the initial notification of compliance status in the third year. Increasing numbers of sources installed after the effective date will also be subject to ongoing requirements,

such as submitting semi annual compliance reports, over the 3 year review period.

The Agency burden hours and costs will also vary over the 3 year review period because they will be reviewing the following 47 notifications and reports from existing sources: ( 1) the notifications of applicability of the standard in the first year,

( 2) the emissions averaging plans ( if appropriate), precompliance reports, and notifications of performance tests in the second year, and ( 3) the notifications of compliance status in the third year. The EPA will also review notifications and semi annual compliance reports for new sources over the 3 years as they are constructed and as startup begins.

( f) Reasons for Change In Burden This section does not apply because this collection is a new collection.

( g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 79 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 48 number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

The total annual reporting and recordkeeping burden and cost for this collection averaged over the first 3 years after the effective date of the rule were estimated to be 10,139 labor hours, at a cost of $ 451,322. The average burden and cost, per respondent, are 79 labor hours and $ 3,499.

During these 3 years, the rule requires several initial onetime notifications and reports from all facilities. In addition,

new facilities are required to submit an initial one time notification of compliance status and subsequent compliance reports semi annually to indicate their ongoing compliance status. Each respondent also must keep necessary records of data to determine compliance with the rule.

In the first year, the collection requirements will be applicable to an estimated 128 respondents ( 127 existing facilities and 1 new facility), and an estimated 1 additional facility will be subject to the rule in each subsequent year.

The total capital cost in each of the first 2 years after the effective date of the rule is $ 30,221; this cost includes $ 29,986 for monitoring equipment and $ 235 for file cabinets. The total capital cost in the third year after the effective date is $ 54,641, which includes $ 29,986 for monitoring equipment, $ 235 for file cabinets, and $ 24,420 for performance tests. The annualized capital cost for the monitoring equipment, file cabinets, and performance tests is $ 10,213 for the 3 years after the effective date. The average annual O& M cost, which includes monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment, as well as photocopying and postage for the reports, is $ 34,369 for the 3 years after the effective date. Combining the annualized capital costs with the annual O& M cost gives a total annualized cost of $ 44,582 for the 3 years after the effective date. 49 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 No. OAR 2003 0178, which is available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center ( EPA/ DC), EPA West,

Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8: 30 a. m. to 4: 30 p. m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is ( 202) 566 1744, and the telephone number for the Air Docket is ( 202) 566 1742). An electronic version of the public docket is available through EPA Dockets ( EDOCKET) at http:// www. epa. gov/ edocket. Use EDOCKET to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Once 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. ( OAR

2003 0178). 50 PART B OF THE SUPPORTING STATEMENT This section is not applicable because statistical methods are not used in the data collection associated with this rule.

4 attachments ATTACHMENT 1 Source Data and Information Requirements Attachment 1 SUMMARY OF RECORDKEEPING REQUIREMENTS Requirements Regulation Reference Record retention 63.10( b)( 1) and 63.8085 Documentation supporting initial notifications and notifications of compliance status 63.10( b)( 2)( xiv) and 63.8080( a)( 1)

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

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

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

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

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

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

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

Maintenance wastewater plan 63.8080( a)( 8)

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

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

Records for emissions averaging 63.1250 63.1260, 63.8060 Records for each CMS 63.8( d)( 3), 63.8( f)( 6)( i), 63.10( b)( 2)( vi) ( xi), and 63.8080( b)

SUMMARY OF REPORTING REQUIREMENTS Requirements Regulation Reference Initial notifications ( including construction/ reconstruction) 63.5, 63.9( b), and 63.8070( a)( c)

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

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

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

Notification of process change 63.8070( f)

Emissions averaging plan 63.1250 63.1260, 63.8060 Precompliance report 63.8075( c) SUMMARY OF REPORTING REQUIREMENTS ( continued) Attachment 1 Requirements Regulation Reference Semi annual compliance report ° Startup, shutdown, and malfunction reports ° Deviations/ no deviations/ out of control CMS ° No out of control CMS ° Heat exchange system reports ( delay of repair) ° Maintenance and inspection reports for storage tank control devices ° Operating scenario reports ° Equipment leak reports ° Emissions averaging reports 63.10( e)( 3) and 63.8075( b),( d) 63.10( d)( 5) and 63.8075( d)( 4) 63.8075( d)( 5) 63.8( c)( 7), 63.8075( d)( 6) 63.104( e), ( f)( 2)( i)( iv), 63.8075( d)( 7) 63.1063( c)( 2)( iv)( B) or ( e)( 2), 63.8075( d)( 8) 63.8075( d)( 9) 63.1039( b)( 1)( 8) and 63.8075( d)( 10) 63.1250 63.1260, 63.8060 ATTACHMENT 2 Description of Respondent Activities Attachment 2 DESCRIPTION OF RESPONDENT ACTIVITIES ( 1) Read Instructions represents the activities, less training, which involve comprehending the provisions in the rule and understanding how they apply to the respective emission points at a facility.

( 2) Plan Activities represents such burdens as design, redesign, scheduling, and selecting methods of compliance. The costs for planning and selection are included in the capital costs for the performance test, as explained in item ( 4) below.

( 3) Train Personnel represents activities involved in communicating specific definitions, compliance options, and other requirements, such as recordkeeping, monitoring, and reporting. An average facility may elect to provide classroom instructions for all workers directly impacted by the requirements. However, the rule does not require specific training itself.

( 4) Create Information represents the activities involving testing, retesting, establishing operating parameter limits, and analyzing point by point applicability. Because respondents are expected to hire outside contractors to conduct the performance tests, these costs are not included in the burden tables. Instead, the costs associated with the performance test are included as capital costs and are discussed in the text.

( 5) Gather Existing Information represents the activities involving physical inspections of equipment, collection of monitored data and other related activities. This estimate does not include the monitoring of equipment leak components. The cost for monitoring equipment leak components is included as part of the cost of the leak detection and repair program.

( 6) Write Reports represents the activities normally associated with filling out forms. Since the rule requires no standard forms, these activities relate to the preparation of formal reports and cover letters, as appropriate.

( 7) Enter Information represent the activities that involve analysis of the information collected for accuracy, compliance, and appropriate records required as a result; software translation, duplication, or archival processes normally associated with data management and storage; and the management life cycle of records, from the time they are filed and boxed up to the time at which they are disposed. ATTACHMENT 3 Methods Used in Cost Estimates Attachment 3 METHODS USED IN COST ESTIMATES ( a) Costs for Monitoring Equipment The capital cost for the monitoring equipment was estimated based on the following assumptions:

1. The monitoring equipment cost per facility for process vessels is $ 29,986, which includes the cost for thermocouple, wire, and data acquisition system.

2. The monitoring equipment cost per facility for wastewater systems is $ 20,120, which includes the cost for steam flow meter, liquid flow meter, thermocouple, wire, and data acquisition system.

3. The monitoring equipment cost per facility for transfer operations is $ 3,000, which includes the cost for a data logger.

To determine the total capital cost for monitoring equipment for existing and new facilities, the unit costs were applied to process vessels, wastewater systems, and transfer operations at the 127 existing facilities as follows:

Emission point Number of facilities Unit capital cost Capital cost Annualized capital cost Process vessels Existing 127 $ 29,986 $ 3,808,209 $ 570,470 New ( each year) 1 $ 29,986 $ 29,986 $ 4,492 Existing wastewater systems 2 $ 20,120 $ 40,240 $ 6,028 Existing transfer operations 1 $ 3,000 $ 3,000 $ 547 The annualized capital cost for monitoring equipment was calculated as a sum of the capital recovery cost, administrative charges, insurance, and property taxes. The capital recovery cost was determined as a product of a capital recovery factor and the total capital cost. The capital recovery factor for monitoring equipment for process vessels and wastewater systems was estimated to be 0.1098, based on a 15 year equipment life and 7 percent interest rate. The capital recovery factor for Attachment 3 monitoring equipment for transfer operations was estimated to be 0.1424, based on a 10 year equipment life and 7 percent interest rate. The administrative charges, insurance, and property taxes were calculated as 4 percent of the capital cost. Using these estimated costs, the capital and annualized capital costs for monitoring equipment for the first 6 years after the effective date were estimated as follows:

New process vessels Existing process vessels Existing wastewater systems Existing transfer operations Total CAPITAL COSTS Year 1 $ 29,986 $ 0 $ 0 $ 0 $ 29,986 Year 2 $ 29,986 $ 0 $ 0 $ 0 $ 29,986 Year 3 $ 29,986 $ 0 $ 0 $ 0 $ 29,986 AVERAGE ( Years 1 3) $ 29,986 $ 0 $ 0 $ 0 $ 29,986 Year 4 $ 29,986 $ 3,808,209 $ 40,240 $ 3,000 $ 3,881,435 Year 5 $ 29,986 $ 0 $ 0 $ 0 $ 29,986 Year 6 $ 29,986 $ 0 $ 0 $ 0 $ 29,986 AVERAGE ( Years 4 6) $ 29,986 $ 1,269,403 $ 13,413 $ 1,000 $ 1,313,802 ANNUALIZED CAPITAL COSTSa Year 1 $ 4,492 $ 0 $ 0 $ 0 $ 4,492 Year 2 $ 8,984 $ 0 $ 0 $ 0 $ 8,984 Year 3 $ 13,476 $ 0 $ 0 $ 0 $ 13,476 AVERAGE ( Years 1 3) $ 8,984 $ 0 $ 0 $ 0 $ 8,984 Year 4 $ 17,968 $ 570,470 $ 6,028 $ 547 $ 595,012 Year 5 $ 22,459 $ 570,470 $ 6,028 $ 547 $ 599,504 Year 6 $ 26,951 $ 570,470 $ 6,028 $ 547 $ 603,996 AVERAGE ( Years 4 6) $ 22,459 $ 570,470 $ 6,028 $ 547 $ 599,504 aWith one new facility being added each year, the increase in annualized capital costs each year is equal to the amount of annualized capital cost for one facility. For example, the annualized capital cost for Year 1 would be $ 4,492, while the annualized capital cost for Year 2 would be 2 times $ 4,492, or $ 8,984. Attachment 3 ( b) Costs for File Cabinets The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility. We assumed $ 235 per file cabinet. Using a capital recovery factor of 0.1098 and estimating administrative charges, insurance, and property taxes at 4 percent of total capital cost, the average annualized capital cost per facility for file cabinets was estimated to be $ 35. Using these estimated costs, the capital and annualized capital costs for file cabinets for the first 6 years after the effective date were estimated as follows:

Capital cost/ respondent Annualized capital cost/ respondent Capital cost respondents/ yr Annual cost respondents/ yr Capital cost Annualized capital cost Year 1 $ 235 $ 35 1 1 $ 235 $ 35 Year 2 $ 235 $ 35 1 2 $ 235 $ 70 Year 3 $ 235 $ 35 1 3 $ 235 $ 105 AVERAGE ( Years 1 3) $ 470 $ 70 Year 4 $ 235 $ 35 128 131 $ 30,080 $ 4,585 Year 5 $ 235 $ 35 1 132 $ 235 $ 4,620 Year 6 $ 235 $ 35 1 133 $ 235 $ 4,655 AVERAGE ( Years 4 6) $ 10,183 $, 4620 ( c) Costs for Performance Tests The capital costs associated with performance testing include the costs for performance tests for transfer operations at existing facilities. Performance test costs were estimated based on the following assumptions:

1. Capital costs per facility are $ 24,420;

2. One existing facility with transfer operations will conduct a performance test in the third year after the effective date;

3. No new facilities will conduct a performance test; Attachment 3 4. No performance tests are required for process vessels,

storage tanks, or wastewater systems; and 5. No facilities will repeat the performance test.

The annualized capital cost for performance tests was estimated as a capital recovery cost, which was calculated as a product of a capital recovery factor and the total capital cost.

The capital recovery factor was estimated to be 0.1424, based on a 10 year annualization and 7 percent interest rate. Because no equipment is purchased, no administrative charges, insurance, or property taxes were estimated for performance tests. The annualized capital cost was estimated to be $ 3,477. Using these test costs, the capital and annualized capital costs for performance testing for the first 6 years after the effective date were estimated as follows:

Capital cost Annualized capital cost Year 1 $ 0 $ 0 Year 2 $ 0 $ 0 Year 3 $ 24,420 $ 3,477 AVERAGE ( Years 1 3) $ 8,140 $ 1,159 Year 4 $ 0 $ 3,477 Year 5 $ 0 $ 3,477 Year 6 $ 0 $ 3,477 AVERAGE ( Years 4 6) $ 0 $ 3,477 ( d) Costs for Operation and Maintenance Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. The monitoring labor costs for process vessels were estimated based on 8,760 operating hours per year,

0.5 hour of labor per 8 hr shift, and a wage rate of $ 17.21/ hr. Attachment 3 The monitoring labor costs for wastewater systems were estimated based on 834 operating hours per year, 0.5 hour of labor per 8 hr shift, and a wage rate of $ 22.50/ hr. The monitoring labor costs for transfer operations were estimated based on 300 operating days per year, 0.5 hour of labor per 24 hour day, and a wage rate of $ 17.21/ hr. Maintenance materials and supplies were estimated at $ 500 for process vessels and transfer operations and $ 50 for wastewater operations. Overhead for process vessels was estimated at 60 percent of labor costs plus maintenance materials and supplies costs; no overhead costs were estimated for wastewater systems or transfer operations. Based on these estimates, the O& M cost associated with the monitoring equipment is $ 15,875 for process vessels, $ 1,957 for wastewater systems,

and $ 3,082 for storage tanks. To determine the total O& M cost for existing and new facilities, the unit costs were applied to process vessels, wastewater systems, and transfer operations at the 127 existing facilities as follows:

Emission point Number of facilities Unit O& M cost O& M cost Process vessels Existing 127 $ 15,875 $ 2,016,150 New ( each year) 1 $ 15,875 $ 15,875 Wastewater systems 2 $ 1,957 $ 3,914 Transfer operations 1 $ 3,082 $ 3,082 Using these estimated O& M costs, the O& M costs for the first 6 years after the effective date were estimated as follows:

New process vessels Existing process vessels Existing wastewater systems Existing transfer operations Totala Year 1 $ 15,875 $ 0 $ 0 $ 0 $ 15,875 Year 2 $ 31,750 $ 0 $ 0 $ 0 $ 31,750 Year 3 $ 47,625 $ 0 $ 0 $ 0 $ 47,625 AVERAGE ( Years 1 3) $ 31,750 $ 0 $ 0 $ 0 $ 31,750 Attachment 3 New process vessels Existing process vessels Existing wastewater systems Existing transfer operations Totala Year 4 $ 63,500 $ 2,016,150 $ 3,914 $ 3,082 $ 2,086,647 Year 5 $ 79,375 $ 2,016,150 $ 3,914 $ 3,082 $ 2,102,522 Year 6 $ 95,250 $ 2,016,150 $ 3,914 $ 3,082 $ 2,118,397 AVERAGE ( Years 4 6) $ 79,375 $ 2,016,150 $ 3,914 $ 3,082 $ 2,102,522 aWith one new facility being added each year, the increase in O& M costs each year is equal to the amount of O& M cost for one facility. For example, the O& M cost for Year 1 would be $ 15,875, while the O& M cost for Year 2 would be 2 times $ 15,875, or $ 31,750.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. For example, the O& M costs for rules that require respondents to submit reports to EPA and maintain records should be estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 28.14/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Using the estimated costs per response, the O& M costs for photocopying and postage for the first 6 years after the effective date were estimated as follows:

Cost item Photocopy cost/ report Postage cost/ report Reports/

respondent Respondents yr Reports/ yr Photocopy cost Postage cost Notification of construction/ reconstruction ( Years 1 6) $ 14.07 $ 7.63 1 1 1 $ 14 $ 7 Notification of anticipated startup ( Years 1 6) $ 14.07 $ 7.63 1 1 1 $ 14 $ 7 Notification of actual start up ( Years 1 6) $ 14.07 $ 7.63 1 1 1 $ 14 $ 7 Notification of initial CMS performance evaluation $ 14.07 $ 7.63 1 0 0 $ 0 $ 0 Attachment 3 Cost item Photocopy cost/ report Postage cost/ report Reports/

respondent Respondents yr Reports/ yr Photocopy cost Postage cost Notification of applicability of standard Year 1 $ 14.07 $ 7.63 1 128 128 $ 1,801 $ 977 Years 2 6 $ 14.07 $ 7.63 1 1 1 $ 14 $ 8 Emissions averaging plan Years 1, 3 6 $ 14.07 $ 7.63 1 0 0 0 0 Year 2 $ 14.07 $ 7.63 1 13 13 $ 183 $ 99 Precompliance report Years 1, 3 6 $ 14.07 $ 7.63 1 1 1 $ 14 $ 8 Year 2 $ 14.07 $ 7.63 1 64 64 $ 900 $ 488 Notification of initial performance test Years 1, 3 6 $ 14.07 $ 7.63 1 0 0 $ 0 $ 0 Year 2 $ 14.07 $ 7.63 1 1 1 $ 14 $ 8 Notification of compliance status Years 1 2, 4 6 $ 14.07 $ 7.63 1 1 1 $ 14 $ 7 Year 3 $ 14.07 $ 7.63 1 129 129 $ 1,815 $ 984 Notification of process change Years 1 3 $ 14.07 $ 7.63 1 0 0 $ 0 $ 0 Years 4 6 $ 14.07 $ 7.63 1 13 13 $ 183 $ 99 Semi annual compliance report Year 1 $ 14.07 $ 7.63 2 1 2 $ 28 $ 15 Year 2 $ 14.07 $ 7.63 2 2 4 $ 56 $ 31 Year 3 $ 14.07 $ 7.63 2 3 6 $ 84 $ 46 Year 4 $ 14.07 $ 7.63 2 131 262 $ 3,686 $ 1,999 Attachment 3 Cost item Photocopy cost/ report Postage cost/ report Reports/

respondent Respondents yr Reports/ yr Photocopy cost Postage cost Year 5 $ 14.07 $ 7.63 2 132 264 $ 3,714 $ 2,014 Year 6 $ 14.07 $ 7.63 2 133 266 $ 3,743 $ 2,030 TOTAL ( Year 1) $ 1,899 $ 1,030 TOTAL ( Year 2) $ 1,224 $ 664 TOTAL ( Year 3) $ 1,970 $ 1,068 AVERAGE ( Years 1 3) $ 1,704 $ 2,762 TOTAL ( Year 4) $ 3,954 $ 2,144 TOTAL ( Year 5) $ 3,982 $ 2,159 TOTAL ( Year 6) $ 4,010 $ 2,175 AVERAGE ( Years 4 6) $ 3,982 $ 2,159 ATTACHMENT 4 Burden and Cost of Reporting and Recordkeeping Requirements For the Fourth, Fifth, and Sixth Years Following the Effective Date Attachment 4 1 BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR THE FOURTH, FIFTH, AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE 1. The Information Collected    Respondent Activities and Agency Activities ( a) Respondent Activities As shown in the Supporting Statement, there are several onetime notifications and reports that both existing and new sources must complete in the 3 years between the effective date of the miscellaneous coating manufacturing NESHAP and the compliance date for existing sources. These reports include:

( 1) determining applicability and notifying EPA that the facility is subject to the rule, ( 2) developing and submitting an emissions averaging plan ( if appropriate), ( 3) developing and submitting a precompliance report, ( 4) notifying EPA of upcoming performance tests, and ( 5) conducting performance tests and submitting the initial notification of compliance status. New sources are also required to submit notifications of construction/ reconstruction, notifications of anticipated and actual startup, and semi annual compliance reports during the 3 years between the effective date of the NESHAP and the compliance date for existing sources.

In the 3 years following the compliance date for existing sources, existing sources must submit other reports, and ongoing recordkeeping and reporting begins. In the first year following the compliance date for existing sources ( or the fourth year following the effective date of the rule), existing facilities develop their startup, shutdown, and malfunction plans and begin ongoing monitoring and recordkeeping for various operating parameters, equipment leaks, emissions averaging ( if appropriate), etc. The existing facilities also begin to submit Attachment 4 2 semi annual reports that include information on deviations,

periods of startup, shutdown, or malfunction, equipment leaks,

emissions averaging ( if appropriate), etc.

The respondent activities required in the fourth, fifth, and sixth years following the effective date of the rule are listed in the first columns of Tables 1a and 1b of this attachment.

Table 1a presents the one time respondent activities, and Table 1b presents the recurrent respondent activities.

( b) Agency Activities As shown in the Supporting Statement, in the 3 years between the effective date of the NESHAP and the compliance date for existing sources, EPA will review the notifications of applicability, emissions averaging plans ( if appropriate),

precompliance reports, notifications of performance tests, and notifications of compliance status submitted by existing and new sources. The EPA will also review the notifications of construction/ reconstruction, notifications of actual and anticipated startup, and semi annual compliance reports submitted by new sources over the 3 years between the effective date of the NESHAP and the compliance date for existing sources.

In the 3 years following the compliance date for existing sources, EPA will continue to review the notifications and semiannual compliance reports submitted by new sources. In the first year following the compliance date for existing sources ( or the fourth year following the effective date of the rule), EPA will also begin reviewing the semi annual compliance reports submitted by existing sources. The Agency activities for the fourth,

fifth, and sixth years following the effective date of the rule are listed in the first columns of Table 2 of this attachment. 3 Attachment 4 TABLE 1a. ONE TIME RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH, FIFTH, AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A *

B) Fourth year after effective date Fifth year after effective date Sixth year after effective date D Respondentsb E Respondent personhours F Labor cost,

$ G Respondentsb H Respondent personhours I Labor cost,

$ J Respondentsb K Respondent personhours L Labor cost,

$

1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructionsc 1 1 1 1 1 51 1 1 51 1 1 51 B. Required Activities ° Initial CMS performance evaluationd 10 1 10 0 0 0 0 0 0 0 0 0 C. Create Information Included in 3E D. Gather Existing Information Included in 3E E. Write Report ° Notification of construction/ reconstruction 2 1 2 1 2 102 1 2 102 1 2 102 ° Notification of anticipated startup 2 1 2 1 2 102 1 2 102 1 2 102 ° Notification of actual startup 2 1 2 1 2 102 1 2 102 1 2 102 4 Attachment 4 TABLE 1a. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A *

B) Fourth year after effective date Fifth year after effective date Sixth year after effective date D Respondentsb E Respondent personhours F Labor cost,

$ G Respondentsb H Respondent personhours I Labor cost,

$ J Respondentsb K Respondent personhours L Labor cost,

$

° Notification of applicability of standard Existing sources 2 1 2 0 0 0 0 0 0 0 0 0 New sources 2 1 2 1 2 102 1 2 102 1 2 102 ° Emissions averaging plane 40 1 40 0 0 0 0 0 0 0 0 0 ° Precompliance reportf 40 1 40 1 46 2,048 1 46 2,048 1 46 2,048 ° Notification of initial performance testg 2 1 2 0 0 0 0 0 0 0 0 0 ° Notification of initial CMS performance evaluation 2 1 2 0 0 0 0 0 0 0 0 0 ° Notification of compliance status With performance testg 80 1 80 0 0 0 0 0 0 0 0 0 Without performance testh 120 1 120 1 138 6,143 1 138 6,143 1 138 6,143 5 Attachment 4 TABLE 1a. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A *

B) Fourth year after effective date Fifth year after effective date Sixth year after effective date D Respondentsb E Respondent personhours F Labor cost,

$ G Respondentsb H Respondent personhours I Labor cost,

$ J Respondentsb K Respondent personhours L Labor cost,

$

4. Recordkeeping Requirements A. Read Instructions Included in 3A B. Plan Activities N/ A C. Implement Activities N/ A D. Develop Record Systemi 40 1 40 128 5,888 262,095 1 46 2,048 1 46 2,048 E. Develop Startup,

Shutdown, Malfunction Planj 100 1 100 128 14,720 655,238 1 115 5,119 1 115 5,119 F. Develop QA/ QC Plan for CMSk 40 1 40 0 0 0 0 0 0 0 0 0 G. Time to Train Personnell 40 1 40 128 5,888 262,095 1 46 2,048 1 46 2,048 H. Time for Audits N/ A ONE TIME BURDEN AND COST ( SALARY) NATIONWIDE: m 26,690 1,188,080 401 17,865 401 17,865 Average cost per facilityn 131 9,069 132 135 133 134 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

c This will occur only in the first year after a facility becomes subject to the rule. 6 Attachment 4 TABLE 1a. ( continued)

d Person hours per occurrence are based on the performance specification costs to certify CMS ($ 500) divided by the composite hourly labor rate. No performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard,

which requires CEMS and performance evaluations.

e Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

f Assumes 50 percent of facilities will submit a precompliance report.

g Assumes one existing facility and no new facilities will be required to conduct a performance test( s). The notification of compliance status includes the report of the performance test( s).

h Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

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

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

k Assumes 40 hours to develop and review the QA/ QC plan for the CMS. No QA/ QC plan is required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and QA/ QC plans.

l Assumes 40 hours to train personnel.

m The one time burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

n The average facility cost is calculated by dividing the total facility burden by the number of facilities subject to the rule. 7 Attachment 4 TABLE 1b. RECURRENT RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH, FIFTH, AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) Fourth year after effective date Fifth year after effective date Sixth year after effective date D Respondentsb E Respondent personhours F Labor cost,

$ G Respondentsb H Respondent personhours I Labor cost,

$ J Respondentsb K Respondent personhours L Labor cost,

$

1. Applications N/ A 2. Surveys and Studies N/ A 3. Reporting Requirements A. Read Instructions N/ A B. Required Activities N/ A C. Create Information N/ A D. Gather Existing Information N/ A E. Write Report ° Notification of process changec 8 1 8 13 120 5,324 13 120 5,324 13 120 5,324 ° Semi annual compliance report No deviationsd 8 2 16 118 2,171 96,648 119 2,190 97,467 120 2,208 98,286 Deviationsd 24 2 48 13 718 31,943 13 718 31,943 13 718 31,943 Startup, shutdown, and malfunction reporte 8 2 16 131 2,410 107,295 132 2,429 108,114 133 2,447 108,933 LDAR reportf 404 2 808 131 25,749 1,146,198 132 25,946 1,154,947 133 26,143 1,163,697 Emissions averaging reportg 20 2 40 13 598 26,619 13 598 26,619 13 598 26,619 4. Recordkeeping Requirements A. Read Instructions N/ A B. Plan Activities N/ A C. Implement Activities N/ A 8 Attachment 4 TABLE 1b. ( continued)

Burden itema A Personhours per occurrence B Number of occurrences per year C Technical personhours per respondent per year ( C = A * B) Fourth year after effective date Fifth year after effective date Sixth year after effective date D Respondentsb E Respondent personhours F Labor cost,

$ G Respondentsb H Respondent personhours I Labor cost,

$ J Respondentsb K Respondent personhours L Labor cost,

$

D. Develop Record System N/ A E. Time to Enter Information ° Records of startup,

shutdown, and malfunction 1.5 52 78 131 11,751 523,065 132 11,840 527,057 133 11,930 531,050 ° Records of CMS data Record continuously monitored parametersh 1 365 365 131 54,987 2,447,674 132 55,407 2,466,358 133 55,827 2,485,043 Compile datah 24 2 48 131 7,231 321,886 132 7,286 324,343 133 7,342 326,800 Enter/ verify information for semi annual reportsh 16 2 32 131 4,821 214,591 132 4,858 216,229 133 4,894 217,867 LDAR recordkeeping Included in 3E F. Calibration of CMSi 376 1 376 131 56,644 2,521,439 132 57,077 2,540,687 133 57,509 2,559,935 G. Time to Train Personnel N/ A H. Time for Refresher Training for Personnelj 16 1 16 3 55 2,457 131 2,410 107,295 132 2,429 108,114 I. Time for Audits N/ A RECURRENT BURDEN AND COST ( SALARY) NATIONWIDE: k 167,256 7,445,137 170,878 7,606,384 172,164 7,663,611 Average cost per facilityl 131 56,833 132 57,624 133 57,621 a See Attachment 2 for further explanation of respondent activities.

b There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year. 9 Attachment 4 TABLE 1b. ( continued)

c Assumes 10 percent of facilities will implement process changes.

d Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations.

e Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the startup, shutdown, and malfunction plan.

f According to EPA guidance, annual recordkeeping and reporting coasts for the LDAR program are estimated to be 40 percent of monitoring and repair labor, which averages $ 10,937 per facility ( 40% * $ 10,937 = $ 4,375 per facility). Person hours per occurrence are based on this cost divided by the composite hourly labor rate.

g Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.

h Includes process vessel, storage tank, transfer operation, and wastewater monitoring and inspections.

i Assumes calibration of the CMS will require 8 hours per year for each monitor. Assuming 1 CMS for each process vessel and 47 process vessels per facility, a total of 376 hours per year per facility is required.

j Assumes 2 days ( 16 hours) to provide refresher training for personnel.

k The recurrent burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

l The average facility cost is calculated by dividing the total facility burden by the number of facilities complying with the rule. 10 Attachment 4 TABLE 2. AGENCY BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOURTH,

FIFTH, AND SIXTH YEARS FOLLOWING THE EFFECTIVE DATE Activity A EPA hours per operation Fourth year after effective date Fifth year after effective date Sixth year after effective date B Operationsa C Personhours D Labor cost, $ E Operationsa F Personhours G Labor cost, $ H Operationsa I Personhours J Labor cost, $

1. Attend Initial Performance Testb 40 0 0 0 0 0 0 0 0 0 2. Attend Repeat Performance Testc 40 0 0 0 0 0 0 0 0 0 3. Attend Initial CMS Performance Evaluationd 2 0 0 0 0 0 0 0 0 0 4. Litigation N/ A 5. Report Review A. Review Notification of Construction/ Reconstruction 2 1 2 102 1 2 102 1 2 102 B. Review Notification of Anticipated Startup 2 1 2 102 1 2 102 1 2 102 C. Review Notification of Actual Startup 2 1 2 102 1 2 102 1 2 102 D. Review Notification of Applicability of Standard 2 1 2 102 1 2 102 1 2 102 E. Review Emissions Averaging Plane 20 0 0 0 0 0 0 0 0 0 F. Review Precompliance Reportf 4 1 5 205 1 5 205 1 5 205 G. Review Notification of Initial Performance Test 2 0 0 0 0 0 0 0 0 0 H. Review Notification of Initial CMS Performance Evaluation 2 0 0 0 0 0 0 0 0 0 I. Review Notification of Compliance Status ° With performance testg 40 0 0 0 0 0 0 0 0 0 11 Attachment 4 TABLE 2. ( continued)

Activity A EPA hours per operation Fourth year after effective date Fifth year after effective date Sixth year after effective date B Operationsa C Personhours D Labor cost, $ E Operationsa F Personhours G Labor cost, $ H Operationsa I Personhours J Labor cost, $

° Without performance testh 40 1 46 2,048 1 46 2,048 1 46 2,048 J. Review Notification of Process Changei 8 13 120 5,324 13 120 5,324 13 120 5,324 K. Review Semi Annual Compliance Report ° No deviationsj 2 236 543 24,162 238 547 24,367 239 550 24,469 ° Deviationsj 8 26 239 10,648 26 239 10,648 27 248 11,057 ° Startup, shutdown, and malfunction reportk 2 262 603 26,824 264 607 27,029 266 612 27,233 ° LDAR reportl 8 262 2,410 107,295 264 2,429 108,114 266 2,447 108,933 ° Emissions averaging reporte 8 25 230 10,238 25 230 10,238 25 230 10,238 TOTAL BURDEN AND COST ( SALARY): m 961 42,795 966 43,000 978 43,512 TRAVEL EXPENSES FOR TEST ATTENDEDn = ( 1 person *

0 facility/ yr * 2 days/ facility * $ 50 per diem) + ($ 400/ round trip *

0 round trip/ yr): 0 0 0 TOTAL COST = TOTAL COST ( SALARY) + TRAVEL EXPENSES: 42,795 43,000 43,512 a Operations per year are equal to the number of operations ( e. g., performance tests, notifications, reports) per facility times the number of facilities. There are an estimated 127 existing major source facilities subject to the NESHAP. Assuming 2 percent growth over 3 years, 1 new facility will be built each year.

b Assumes one existing facility and no new facilities will conduct initial performance tests, and EPA personnel will attend 10 percent of the initial tests ( approximately 0 tests).

c Assumes no repeat performance tests.

d Assumes no performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which requires CEMS and performance evaluations.

e Assumes 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging. 12 Attachment 4 TABLE 2. ( continued)

f Assumes 50 percent of facilities will submit a precompliance report.

g Assumes one existing facility and no new facilities will conduct initial performance tests, and the notification of compliance status includes the report of the performance tests.

h Assumes all facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.

i Assumes 10 percent of facilities will implement process changes.

j Assumes 90 percent of facilities will have no deviations, and 10 percent will have deviations. The number of operations for reviewing a semi annual report with no deviations is equal to 90 percent of the facilities times two reports per year. The number of operations for reviewing a semi annual report with deviations is equal to 10 percent of the facilities times two reports per year.

k Assumes all facilities will report actions taken during a startup, shutdown, or malfunction that are consistent with the startup, shutdown, and malfunction plan.

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

m The burden and cost are equal to the person hours added down each column for technical, management, clerical, and total respondent labor and the sum of the cost column.

n Tests attended include no initial performance tests, no repeat performance tests, for a total of 0 tests attended. Attachment 4 13 2. Estimating the Burden and Cost of the Collection ( a) Estimating Respondent Burden and Costs ( i) Estimating respondent burden and labor costs. Tables 1a and 1b of this attachment present the annual respondent burden estimates and labor costs for reporting and recordkeeping activities for the fourth, fifth, and sixth years following the effective date of the rule. Table 1a presents the one time burden and costs, and Table 1b presents the recurrent burden and costs. The burden estimates in each table were derived from estimates based on EPA's experience with similar information collection requirements in other standards development efforts.

The costs of the reporting and recordkeeping activities in each table were estimated based on data from the U. S. Bureau of Labor Statistics. Labor costs are divided into the following three categories: ( 1) technical, ( 2) management, and ( 3) clerical. The cost of technical labor was estimated at $ 45.04/ hr, the cost of management labor at $ 66.73/ hr, and the cost of clerical labor at $ 28.14/ hr. These estimates include fringe benefits, overhead, and profit rate.

( ii) Estimating capital and O& M costs. There are two types of non labor related costs associated with information collection activities   capital costs and O& M costs. The methods used to estimate the capital and O& M costs for this attachment to the Supporting Statement are presented in Attachment 3, Methods Used in Cost Estimates.

One time capital costs usually include any produced physical good, such as computers, machinery, or equipment, that must be purchased for the specific purpose of satisfying EPA's reporting or recordkeeping requirements. Capital costs are usually incurred only once, at the beginning of an information collection period. A one time capital cost can be estimated over multiple years by annualizing the cost using an OMB approved interest Attachment 4 14 rate. For this attachment to the Supporting Statement, capital costs were annualized over 10 years for transfer operations and 15 years for process vessels and wastewater systems, assuming an interest rate of 7 percent. Administrative charges, insurance,

and property taxes were also included with the annualized capital costs, at 4 percent of the capital cost.

The capital costs associated with monitoring equipment include the monitoring equipment, installation, ancillary costs ( planning and selection), and a DAS ( data logger, computer,

logging and reporting software, and printer). The capital costs for the monitoring equipment were estimated based on the following assumptions: ( 1) the monitoring equipment cost per facility for process vessels is $ 29,286, which includes the cost for thermocouple, wire, and DAS; ( 2) the monitoring equipment cost per facility for wastewater systems is $ 20,120, which includes the cost for steam flow meter, liquid flow meter,

thermocouple, wire, and DAS; ( 3) the monitoring equipment cost per facility for transfer operations is $ 3,000, which includes the cost for a data logger; ( 4) there is no monitoring equipment cost for storage tanks because no monitoring equipment are required ( all tanks use floating roofs); ( 5) in the fourth year after the effective date, 127 existing facilities will purchase monitoring equipment for process vessels, 2 existing facilities will purchase monitoring equipment for wastewater systems, and one existing facility will purchase monitoring equipment for transfer operations; and ( 6) in each of the fourth, fifth, and sixth years after the effective date, one new facility will purchase monitoring equipment for process vessels; no new facilities will purchase monitoring equipment for wastewater systems or transfer operations.

The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four drawer file cabinet for each facility ( assume $ 235 per file Attachment 4 15 cabinet).

Costs for performance testing are also considered capital costs because it is expected that facilities will hire a contractor to conduct the test. The capital costs associated with performance testing include the costs for performance tests for transfer operations at existing facilities. One existing facility with transfer operations is expected to conduct a performance test, but the test will be conducted in the third year following the effective date of the rule. No other facilities are expected to conduct a performance test.

Therefore, there are no performance test costs for the fourth,

fifth, and sixth years following the effective date of the rule.

Operation and maintenance costs include those costs associated with the general upkeep of capital equipment, such as monitoring equipment. These costs would include monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment. The monitoring labor costs for process vessels were estimated based on 8,760 operating hours per year,

0.5 hour of labor per 8 hr shift, and a wage rate of $ 17.21/ hr.

The monitoring labor costs for wastewater systems were estimated based on 834 operating hours per year, 0.5 hour of labor per 8 hr shift, and a wage rate of $ 22.50/ hr. The monitoring labor costs for transfer operations were estimated based on 300 operating days per year, 0.5 hour of labor per day, and a wage rate of $ 17.21/ hr. Maintenance materials and supplies were estimated at $ 500 for process vessels and transfer operations and $ 50 for wastewater systems. Overhead was estimated at 60 percent of labor costs plus maintenance materials and supplies costs for process vessels; no overhead costs were estimated for wastewater systems or transfer operations. The O& M cost associated with the monitoring equipment is $ 15,875 for process vessels, $ 1,957 for wastewater systems, and $ 3,082 for transfer operations. The O& M costs will be applied to all existing and new facilities for Attachment 4 16 process vessels, two existing facilities for wastewater systems,

and one existing facility for transfer operations for the fourth,

fifth, and sixth years following the effective date of the rule.

Operation and maintenance costs also include the costs associated with the paperwork requirement incurred continuously over the life of the ICR. For example, the O& M costs for rules that require respondents to submit reports to EPA and maintain records should be estimated as costs for photocopying and postage. Photocopying costs per response were estimated at 0.5 hour of clerical labor at a wage rate of $ 28.14/ hr. First class postage was estimated at $ 7.63 per response for mailing to regulatory agencies. Photocopying and postage costs will be applied to the 281 responses submitted during the fourth year,

the 283 responses submitted during the fifth year, and the 285 responses submitted during the sixth year. ( The number of responses was determined by adding the number of reports submitted to EPA by respondents, as shown in Tables 1a and 1b of this attachment.)

( b) Estimating Agency Burden and Costs Table 2 of this attachment presents the estimated annual Agency burden estimates and costs for the fourth, fifth, and sixth years following the effective date of the rule. The only burden and costs that the Federal Government will incur as a result of the information collection requirements are associated with the analysis of the information reported by facilities in one time notifications and semi annual compliance reports ( unless the compliance report indicates a deviation, thereby triggering an enforcement action). Labor costs were estimated based on estimated wage rates of $ 45.04/ hr for technical labor, $ 66.73/ hr for management labor, and $ 28.14/ hr for clerical labor. Attachment 4 17 ( c) Bottom Line Burden Hours and Cost Tables ( i) Respondent tally. The bottom line annual respondent burden hours and costs were calculated by adding the total person hours and costs from Tables 1a and 1b and dividing the sums by the 3 year period ( i. e., fourth, fifth, and sixth years after the effective date). The total annual respondent burden hours and costs are summarized as follows:

Total burden, hours Total costs, $

Table 1a ( one time activities in first year) 26,690 $ 1,188,080 Table 1a ( one time activities in second year) 401 $ 17,865 Table 1a ( one time activities in third year) 401 $ 17,865 Table 1b ( recurrent activities in first year) 167,256 $ 7,445,137 Table 1b ( recurrent activities in second year) 170,878 $ 7,606,384 Table 1b ( recurrent activities in third year) 172,164 $ 7,663,611 Total 537,791 $ 23,938,943 Bottom line annual burden 179,264 $ 7,979,648 The bottom line annual burden, averaged over the 3 year period, is 179,264 labor hours, at a cost of $ 7,979,648. The average annual burden per respondent, based on an average 132 respondents over the 3 year period, is 1,358 labor hours, at a cost of $ 60,452.

There are an estimated 283 total annual responses for the fourth, fifth, and sixth years after the effective date. The total annual responses are based on an estimated 281 one time and recurrent notifications and reports submitted during the fourth year, 283 during the fifth year, and 285 during the sixth year. Attachment 4 18 Of these 283 total annual responses, approximately 20 percent are assumed to be collected electronically.

The total nationwide capital costs associated with monitoring equipment were estimated to be $ 3,911,515 the fourth year after the effective date of the rule, and $ 30,221 in each of the fifth and sixth years. The average annualized capital cost for the monitoring equipment is $ 599,504 for the fourth, fifth,

and sixth years following the effective date.

The total nationwide capital costs associated with file cabinets for storing collected data and reports were estimated to be $ 30,080 in the fourth year after the effective date of the rule, and $ 235 in each of the fifth and sixth years. The average annualized capital cost for file cabinets is $ 4,620 for the fourth, fifth, and sixth years following the effective date.

The total nationwide capital costs for performance tests were estimated to be $ 0 for each of the fourth, fifth, and sixth years after the effective date of the rule. The average annualized capital cost for the performance tests is $ 3,477 for the fourth, fifth, and sixth years following the effective date.

Annual O& M costs, which include monitoring labor,

maintenance materials and supplies, and overhead for the monitoring equipment, as well as photocopying and postage for the reports, average $ 2,108,663 for the fourth, fifth, and sixth years following the effective date of the rule.

Combining the annualized capital costs for the monitoring equipment, file cabinets, and performance tests results in a total annualized capital cost of $ 607,602 for the fourth, fifth,

and sixth years following the effective date of the rule.

Summing this total annualized capital cost with the annual O& M cost gives a total annualized cost of $ 2,716,265 for the fourth,

fifth, and sixth years following the effective date.

( ii) Agency tally. The bottom line annual Agency burden hours and costs were calculated by adding the total person hours Attachment 4 19 and costs from Table 2 and then dividing by the 3 year period ( i. e., fourth, fifth, and sixth years after the effective date).

The total annual Agency burden hours and costs are summarized as follows:

Total burden, hours Total costs, $

Table 2 ( fourth year) 961 $ 42,795 Table 2 ( fifth year) 966 $ 43,000 Table 2 ( sixth year) 978 $ 43,512 Total 2,905 $ 129,307 Bottom line annual burden 968 $ 43,102 The bottom line annual burden, averaged over the 3 year period, is 968 labor hours, at a cost of $ 43,102.

( d) Burden Statement ( i) The total annual reporting and recordkeeping burden and cost for this collection averaged over the fourth, fifth, and sixth years after the effective date of the rule were estimated to be 179,264 labor hours and $ 7,979,648. The average burden and cost, per respondent, are 1,358 labor hours and $ 60,452.

During these 3 years, new facilities are required to submit notifications of construction/ reconstruction, notifications of anticipated and actual startup, and notifications of compliance status. Both existing and new facilities are required to submit semi annual compliance reports to indicate their ongoing compliance status. Each respondent also must keep necessary records of data to determine compliance with the rule.

In the fourth year after the effective date, the collection requirements will be applicable to an estimated 131 respondents ( 127 existing facilities as of the effective date, 4 facilities constructed as of the fourth year after the effective date). An Attachment 4 20 estimated 1 additional facility will be subject to the rule in each subsequent year.

( ii) The total capital cost in the fourth year after the effective date of the rule is $ 3,911,545; this cost includes $ 3,881,435 for monitoring equipment and $ 30,080 for file cabinets. The total capital cost in each of the fifth and sixth years after the effective date is $ 30,221, which includes $ 29,986 for monitoring equipment and $ 235 for file cabinets. The annualized capital cost for the monitoring equipment, file cabinets, and performance tests is $ 607,602 for the fourth,

fifth, and sixth years after the effective date. The average annual O& M cost, which includes monitoring labor, maintenance materials and supplies, and overhead for the monitoring equipment, as well as photocopying and postage for the reports,

is $ 2,108,663 for the fourth, fifth, and sixth years after the effective date. Combining the annualized capital cost with the annual O& M cost gives a total annualized cost of $ 2,716,265 for the fourth, fifth, and sixth years after the effective date.