SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 

CFR Part 63, Subpart NNNN) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 

63, Subpart NNNN) (Renewal), EPA ICR Number 1954.06, OMB Control Number 2060-0457. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the 

NESHAP for the Surface Coating of Large Household and Commercial Appliances were 

proposed on December 22, 2000 and promulgated on July 23, 2002. These regulations apply to 

existing and new facilities that perform surface coating of large household and commercial 

appliances and related parts where the total Hazardous Air Pollutants (HAPs) emitted are greater 

than or equal to 10 tons per year of any one HAP, or where the total HAPs emitted are greater 

than or equal to 25 tons per year of any combination of HAPs. New facilities include those that 

commenced construction or reconstruction after the date of proposal. This information is being 

collected to assure compliance with 40 CFR Part 63, Subpart NNNN.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of one

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

All of the large household and commercial appliance surface coating facilities in the 

United States are owned and operated by the private industry (the “Affected Public”). None of 

the facilities in the United States are owned by state, local, tribal or the Federal government. 

They are all privately owned, for-profit businesses. The burden to the “Affected Public” may be 

found in Table 1: Annual Respondent Burden and Cost – NESHAP for the Surface Coating of 
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Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal). 

The burden to the “Federal Government” is attributed entirely to work performed by federal 

employees or government contractors and can be found in Table 2: Average Annual EPA Burden 

and Cost – NESHAP for the Surface Coating of Large Household and Commercial Appliances 

(40 CFR Part 63, Subpart NNNN) (Renewal).

Over the next three years, approximately 114 respondents per year will be subject to the 

standard, and four additional respondents per year will become subject to the standard. The 

estimate is based on the industry growth rate developed during previous renewals. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any Terms of Clearance.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from household and commercial 

appliance surface coating facilities cause or contribute to air pollution that may reasonably be 

anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for 

this source category at 40 CFR Part 63, Subpart NNNN.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the

applicable regulations which were promulgated in accordance with the Clean Air Act. The 
3

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. The 

performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

NNNN.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 
4

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted the Association of Home Appliance 

Manufacturers at (202) 872-5955 and the Air-Conditioning, Heating, and Refrigeration Institute

at (703) 524-8800.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

the Part 70 permit program and the five year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions
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The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities that 

perform surface coating of large household and commercial appliances and related parts. The 

United States Standard Industrial Classification (SIC) code for the respondents affected by the 

standard and the corresponding North American Industry Classification System (NAICS) codes

are listed below for this source category:

Standard (40 CFR Part 63, Subpart NNNN) SIC Codes NAICS Codes

Household Cooking Appliance Manufacturing 3631 335221

Household Refrigerator and Home Freezer Manufacturing 3632 335222

Household Laundry Equipment Manufacturing 3633 335224

Other Major Household Appliance Manufacturing 3639 335228

Commercial laundry, Drycleaning, and Pressing Machine

Manufacturing 3582 333312

Air-Conditioning and Warm Air Heating Equipment and 

Commercial and Industrial Refrigeration Equipment 

Manufacturing

3585 333415

Other Commercial and Service Industry Machinery

Manufacturing 3589 333319

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for the 

Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart 

NNNN).

A source must make the following reports:

Notifications

Initial notification 63.4110(a)(1), 

63.9(b)

Notification of compliance status 63.4110(a)(2), 

63.4110(b), 63.9(h)
6

Notifications

Notification of construction or reconstruction 63.5

Notification of actual startup 63.4110(a)

63.9(b)

Notification of performance test 63.4110(a)

63.7(b)

Reports

Semiannual report 63.4120

Excess emissions report 63.4120(c),(d),(e),

(f),(g)

Report of performance test 63.4120(h)

Startup, shutdown, malfunction report 63.4120(j)

A source must keep the following records:

Recordkeeping

Five year retention of records 63.4131(b), 63.10(b)

Material formulation data 63.4130(b)

Records of HAP content calculations 63.4130(c)

Copies of notifications and reports 63.4130(a)

Records of names of materials used 63.4130(d)

HAP fractions in each material used 63.4130(e)

Coating solids fraction in each material used 63.4130(f)

Density of materials used 63.4130(g)

Documentation of waste material shipped offsite 63.4130(h)

Start-up, shutdown, and malfunction plan/records 63.4130(j),(k),63.6(e

)

Documentation of control device performance tests 63.4130(k),63.10(b)

Values measured by continuous monitoring systems 63.4130(k)

Monitoring system calibrations, maintenance 63.4130(k)

Periods of monitoring system failure/shutdown 63.4130(j),(k)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

(ii) Respondent Activities
7

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for temperature, gas flow, or pressure drop for 

oxidizer, carbon adsorber, condense, concentrator, or capture system.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 

4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E, 204F, 311, or ASTM Method D1475-98, 

D2697-86, D6093-97 test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.
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Agency Activities

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard. Data and records maintained by the respondents are tabulated and published 

for use in compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

A majority of the respondents are small businesses. The impact on small entities (i.e., 

small businesses) was taken into consideration during the development of the regulation. Due to 

technical considerations involving the process operations and the types of control equipment 

employed, the recordkeeping and reporting requirements are the same for both small and large 

entities. The Agency considers these requirements the minimum needed to ensure compliance 

and, therefore, cannot reduce them further for small entities. To the extent that larger businesses 

can use economies of scale to reduce their burden, the overall burden will be reduced. 

In the Background Information for the Large Appliance Surface Coating Operations 

NESHAP1, 57 percent of the parent companies affected by proposed action were estimated to be 

small entities as defined by the Small Business Administration. The Agency assumes that 57 

percent of the 114 facilities affected by this ICR, or 65 facilities, are small entities.

5(d) Collection Schedule

 

1 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Category: Large Appliances 

Surface Coating Operations – Background Information for Proposed Standards, September 2000, EPA-453/R-00-

006
9

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for the Surface 

Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN)

(Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 36,500 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 
10

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitors and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

CEM $16,000 4 $64,000 $5,400 114 $615,600

Total 

(rounded) $64,000 $616,000

1Comments received from Whirlpool Corporation during industry consultation suggested that annual O&M cost can 

vary from 24 to 80 hours at a technicians pay grade. To calculate annual O&M costs, an average of 52 hours was 

assumed and multiplied by the technical labor rate of $103.97.

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

The total capital/startup costs for this ICR are $64,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $616,000. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $680,000. These are 

recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$154,000. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)
11

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for the 

Surface Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart 

NNNN) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

110 existing respondents will be subject to the standard. It is estimated that an additional four

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 114 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 4 106 0 0 110

2 4 110 0 0 114

3 4 114 0 0 118

Average 4 110 0 0 114

1

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 114. 

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

Total Annual Responses

(A) (B) (C) (D) (E)
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Total Annual Responses

Information Collection 

Activity

Number of 

Respondents

Number of 

Responses

Number of Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

Total Annual 

Responses

E=(BxC)+D

Notification of compliance 

status 4 1 0 4

Notification of 

construction/reconstruction 4 1 0 4

Notification of actual startup 4 1 0 4

Notification of performance 

test 4 1 0 4

Report of performance test 4 1.2 0 4.8

Semiannual report 114 2 0 228

Excess emissions report 114 0.5 0 57

Startup, shutdown, 

malfunction report 114 0.5 0 57

Total 363 (Rounded)

Note: We assume initial performance test will fail 20% of the time and that a repeat test will be required. In addition, 

we assume 50% of respondents will have to submit an excess emission report or a SSM report. 

The number of Total Annual Responses is 363.

The total annual labor costs are $3,670,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for the Surface 

Coating of Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN)

(Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 36,500. Details regarding these estimates may be found 

in Table 1. Annual Respondent Burden and Cost – NESHAP for the Surface Coating of Large 

Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.
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Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 101 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $680,000. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

3,390 labor hours at a cost of $154,000. See Table 2: Average Annual EPA Burden and Cost –

NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 CFR Part 

63, Subpart NNNN) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in the total estimated burden as currently identified in the OMB 

Inventory of Approved Burdens. This increase is not due to any program changes. The change 

in the burden and cost estimates occurred because the total number of respondents has increased, 

after accounting for anticipated industry growth over three years. In addition, there is an 

adjustment increase in the labor rates. These changes result in an increase in the labor hours, 

labor costs, O&M costs, and number of responses. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 101 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.
14

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2014-0076. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0076 and OMB Control Number 2060-0457 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for the Surface Coating of Large Household and Commercial 

Appliances (40 CFR Part 63, Subpart NNNN) (Renewal)

Burden Item

(A) (B) (C) (D) (E) (F) (G) (H)

Person-Hours 

per 

occurrence

Number of 

occurrences 

per year

Person-Hours 

per 

respondent 

per year

(C=A*B)

Respondents 

per year a

Technical 

person-hours 

per year 

(E=C*D)

Management 

person-hours 

per year

(F=E*0.05)

Clerical 

person-hours 

per year 

(G=E*0.1)

Annual costs 

($) b

1 Familiarization with rule 

requirements c4 1 4 114 456 22.8 45.6 $52,734.35 

2 Plan activities d8 1 8 114 912 45.6 91.2 $105,468.70 

3 Training d8 1 8 114 912 45.6 91.2 $105,468.70 

4 Create, test, and research and 

development 1 0 0 0 0 0 0 $0

5 Gather information, monitor, 

and inspect e12 12 144 114 16416 820.8 1641.6 $1,898,436.53

6 Process/compile and review f8 12 96 114 10944 547.2 1094.4 $1,265,624.35

7 Complete reports g8 2 16 114 1824 91.2 182.4 $210,937.39 

Subtotal for Reporting Requirements 36,184 $3,638,670.01

8 Record/disclose h1 2 2 114 228 11.4 22.8 $26,367.17 

9 Store/file 0.25 2 0.5 114 57 2.85 5.7 $6,591.79 

10 LDAR reporting and 

recordkeeping 0 0 0 0 0 0 0 $0

Subtotal for Recordkeeping Requirements 328 $32,958.97 

TOTAL ANNUAL BURDEN AND COST (rounded) 36,500 $3,670,000

Capital and O&M Cost (see Section 6(b)(iii)): $680,000

TOTAL COST: $4,350,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

Assumptions:
16

a

 We have assumed that the average number of respondents that will be subject to the rule will be 114. There will be four additional new sources that will become 

subject to the rule over the three-year period of this ICR. 

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian 

Workers, by occupational and industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the 

benefit packages available to those employed by private industry.

c

 We have assumed that each respondent will take 4 hours to read the rule and instructions.

d

 We have assumed that it will take eight hours for each respondent to plan activities and eight hours for training.

e

 We have assumed that each respondent will take twelve hours twelve times per year to complete task.

f

 We have assumed that each respondent will take eight hours twelve times per year to complete task.

g

 We have assumed that each respondent will take eight hours twice per year to complete reports.

h

 We have assumed that each respondent will take one hour two times per week to record and disclose information.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for the Surface Coating of Large Household and Commercial 

Appliances (40 CFR Part 63, Subpart NNNN) (Renewal)

Activity

(A) (B) (C) (D) (E) (F) (G) (H)

Person-hours 

per activity

Number of 

occurrences 

per year

Person 

hours per 

respondent 

per year 

(C = A*B)

Respondents 

per yeara

Technical 

person-hours 

per year

(E=C*D)

Management 

person-hours 

per year

(F=E*0.05)

Clerical 

person-hours 

per year

(G=E*0.1)

Annual

Costs ($/yr)

b

1 Initial performance test c24 1 24 4 96 4.8 9.6 $5,024.64 

2 Repeat performance test d24 0.2 4.8 4 19.2 0.96 1.92 $1,004.93 

3 Report review

 a) Initial notification e8 1 8 4 32 1.6 3.2 $1,674.88 

 b) Notification of performance test e8 1 8 4 32 1.6 3.2 $1,674.88 

 c) Notification of compliance status e8 1 8 4 32 1.6 3.2 $1,674.88 

 d) Semiannual reports f12 2 24 114 2736 136.8 273.6 $143,202.24

TOTAL ANNUAL BURDEN AND 

COST (rounded) 3,390 $154,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be 114. There will be four additional sources that will become 

subject to the rule over the three-year period of this ICR

b This cost is based on the following labor rates: Managerial rate of $62.90 (GS-13, Step 5, $39.31 + 60%), Technical rate of $46.67 (GS-12, Step 1, $29.17 + 

60%), and Clerical rate of $25.25 (GS-6, Step3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which 

excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.

c

 We have assumed that it will take 24 hours to complete the task for each respondent. 

d

 We have assumed that tests will fail 20% of the time and that it will take 24 hours to complete the task.

e

 We have assumed that it will take 8 hours to complete the task for each respondent. 

f

 We have assumed that it will take 12 hours to complete the task for each respondent.