**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 Emissi on 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 appl y 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 greate r 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 N NNN

. 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 sy stem 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 report s 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 ind ustry 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 b y the private industry (the “Affected Public”). None of the facilities in the United States are owned by state, local, tribal or th e Federal government. They are all privatel y 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 of2

Large Household and Commercial Appliances (40 CFR Part 63, Subpart NNNN) (Renewal). The burden to the “Federal Government” is attributed entirel y 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 ye ars, approximately 114 respondents per ye ar 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 currentl y active I CR 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. Inaddition, 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 suc h 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 reasonabl y 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 w as 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 w ere promulgated in accordance with the Clean Air Act. The3

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 time s. 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 properl y 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or lo cal agency has adopted its own similar standards to implement the Federal standards, a cop y 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 duplic ation exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR 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 association s 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 I CR, 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 f irst Federal Register n otice. 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 ye ar records retention re quirement is consistent with the Part 70 permit program and the five ye ar statute of limitations on which the permit program is based. The retention of records for five years allow s EPA to establish the compliance history of a source , any pattern of non - c ompliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. 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

- Confi dentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**5

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 ( SI C ) code for the respondents affected b y the standard and the corresponding North American Industry Classi fication S ystem (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 b y 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:

**Notification s**  Initial notification 63.4110(a)(1), 63.9(b) Notification of compliance status 63.4110(a)(2), 63.4110(b), 63.9(h)6
**Notification s**  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 ye ar retention of records 63.4131(b), 63.10(b) Material formulation data 63.4130(b) Records of HAP content calculations 63.413 0 (c) Copies of notifications and reports 63.413 0 (a) Records of names of materials used 63.413 0 (d) HAP fractions in each material used 63.413 0 (e) Coating solids fraction in each material used 63.413 0 (f) Density of materials used 63.413 0 (g) Documentation of waste material shipped offsite 63.413 0 (h) Start

- up, shutdown, and malfunction plan/records 63.413 0 (j),(k),63.6(e ) Documentation of control device performance tests 63.413 0 (k),63.10(b) Values measured b y continuous monitoring systems 63.413 0 (k) Monitoring s ys tem calibrations, maintenance 63.413 0 (k) Periods of monitoring s ystem failure/shutdown 63.413 0 (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 recordke eping 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 sy stem

. 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 rep eat 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpos e 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.8 **Agency Activities** Input, anal yz e, and maintain data in Integrated Compliance Information System (I CI S) 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 properl y in stalled and operated. Performance test reports are used b y 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 enforc ement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is reported b y state and local governments in the IC IS Air database which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **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 NESHAP 1 , 57 percent of the parent companies affected b y proposed action were estimated to be small entities as defined by the Small Business Administration. The Agency assumes that 57 percent of the 1 14 facilities affected b y 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

- 0069

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 I CR. 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 collecti on 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 ind ustry over the next three years from these recordkeeping and reporting requirement s is estimated to be 36,5 00 ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agenc y 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 I CR uses the following labor rates: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 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 b y 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 ty pe 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 costs10

associated with continuous monitoring. Th e 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, 4 00 114 $ 615 , 6 00 **Total (rounded)**  **$64,000 $616,000** 

1 Comments 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 I CR are $ 64,000 . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 61 6 , 0 00

. 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 IC R is estimated to be $ 6 80 , 0 00

. These are recordkeeping costs

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained 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 hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )11

These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 I CR, on average over the next three ye ars, approximately 110 existing respondents will be subject to the standard. It is estimated that an additional four respondents per ye ar 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 ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 114

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) (B) (C) (D) (E)12 **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 36**  **3 (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 36 3

. The total annual labor costs are $3,67 0 , 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 36,5 00

. 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 ty

pical 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 ty pical duties of clerical staff are to proofread the reports, make copies and maintain records.13

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 10 1 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $6 80 , 0 00

. 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 3,3 90 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 ty

pical tasks for managers are to review and approve reports. Clerical burdens are assum ed to take 10% of the time required for technical tasks because the ty pical 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 respond ents 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 response s. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 10 1 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; devel op, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 I CR und er Docket ID Number EPA

- HQ

- OECA

- 201 4

- 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 sy stem , select “search,” then key in the docket ID number identified in thi s 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1927

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 20 1 4

- 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 c 4 1 4 114 456 22.8 45.6 $52,734.35 2 Plan activities d 8 1 8 114 912 45.6 91.2 $105,468.70 3 Training d 8 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 e 12 12 144 114 16416 820.8 1641.6 $1,898,436.53 6 Process/compile and review f 8 12 96 114 10944 547.2 1094.4 $1,265,624.35 7 Complete reports g 8 2 16 114 1824 91.2 182.4 $210,937.39 **Subtotal for Reporting Requirements 36,184**  **$3,638,670.01** 8 Record/disclose h 1 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, 0 00 **TOTAL COST: $4,3**  **5 0**  **, 000**  **Note:** Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.
**Assu mptions:** 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 l abor 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 20 14, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total Compensation.” The rates have been increa sed 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

occurr ences 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 ($/yr) b
1 Initial performance test c 24 1 24 4 96 4.8 9.6 $5,024.64 2 Repeat performance test d 24 0.2 4.8 4 19.2 0.96 1.92 $1,004.93 3 Report review a) Initial notification e 8 1 8 4 32 1.6 3.2 $1,674.88 b) Notification of performance test e 8 1 8 4 32 1.6 3.2 $1,674.88 c) Notification of compliance status e 8 1 8 4 32 1.6 3.2 $1,674.88 d) Semiannual reports f 12 2 24 114 2736 136.8 273.6 $143,202.24 **TOTAL ANNUAL BURDEN AND COST (rounded)**  **3,3 90**  **$154, 000**  **Note:** Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. **Assu mptions:**  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 c om plete 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.