SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, 

Subpart XXXXXX) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart 

XXXXXX) (Renewal), EPA ICR Number 2298.04, OMB Control Number 2060-0622.

1(b) Short Characterization/Abstract

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

Metal Fabrication and Finishing Area Sources were proposed on April 3, 2008, and promulgated 

on July 23, 2008. These regulations apply to both owners and operators of any existing or new 

metal fabrication and finishing facility that is an area source of hazardous air pollutant (HAP) 

emissions and uses or has the potential to emit metal fabrication or finishing metal HAP 

(MFHAP), defined to be the compounds of cadmium, chromium, lead, manganese, and nickel, or 

any of these metals in the elemental form with the exception of lead. The affected sources 

consist of several types of metal fabrication and finishing processes, including any abrasive 

blasting, metalworking (which includes machining, and dry grinding and dry polishing with 

machines), spray painting, and welding operations. 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 XXXXXX.

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 U.S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 5,800 respondents per year will be subject to 

these standards, and no additional respondents per year will become subject to the standard. 

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

without any “Terms of Clearance.” 
2

All of the nine metal fabrication and finishing facilities in the United States are owned 

and operated by the metal fabrication and finishing industry (the “Affected Public”). None of 

these 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 below in Table 1: Annual Respondent Burden and Cost – NESHAP for Nine Metal 

Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (Renewal). The 

Federal Government “burden” is attributed entirely to work performed by either Federal 

employees or government contractors and may be found below in Table 2: Average Annual EPA 

Burden and Cost – NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR 

Part 63, Subpart XXXXXX) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

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

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

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

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

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from metal fabrication or from finishing 

processes either cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this 

source category at 40 CFR Part 63, Subpart XXXXXX.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with 

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

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

Performance tests are required in order to determine an affected facility’s initial 
3

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

ensure compliance with these standards at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

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

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

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

installed and operated, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required annual certification compliance reports are used to determine periods of 

excess emissions, identify problems at the facility, verify operation/maintenance procedures, and 

for compliance determinations.

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

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

XXXXXX.

3(a) Non-duplication

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

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

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

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

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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

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

in the Federal Register (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 these standards, 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 these standards as they were being developed. In 

developing this ICR, we contacted both the Metal Powder Industries Federation, at (609) 452-

7700, and the National Electrical Manufacturers, at (703) 841-3237.

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

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

3(d) Effects of Less Frequent Collection

Less-frequent information collection would decrease the margin of assurance that 

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

recordkeeping are useful techniques to ensure that both 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 either the 

destruction or nonexistence of essential records.

3(f) Confidentiality

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

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

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

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of metal fabrication and finishing facilities. The United States Standard Industrial Classification 

(SIC) codes for the respondents affected by the standards and the corresponding North American 

Industry Classification System (NAICS) codes are listed in the table below. 

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

Iron and Steel Forging 3462 332111

Powder Metallurgy Part Manufacturing 3499 332117

Fabricated Structural Metal Manufacturing 3441, 3449 332312

Plate Work Manufacturing 3443 332313

Power Boiler and Heat Exchanger Manufacturing 3443, 3559 332410

Metal Tank (Heavy Gauge) Manufacturing 3443 332420

Other Fabricated Wire Product Manufacturing 3399 332618

Other Metal Valve and Pipe Fitting Manufacturing 3494 332919

All Other Miscellaneous Fabricated Metal Product 

Manufacturing

3494 332999

Construction Machinery Manufacturing 3531 333120

Oil and Gas Field Machinery and Equipment 

Manufacturing

3533 333132

Heating Equipment (except Warm Air Furnaces) 

Manufacturing

3433, 3569, 3634 333414

Pump and Pumping Equipment Manufacturing 3561, 3743 333911

Motor and Generator Manufacturing 3621, 7694 335312

All Other Miscellaneous Electrical Equipment and 

Component Manufacturing

3629, 3699 335999

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Nine 
6

Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX). 

A source must make the following reports:

Notifications

Initial notification and notification of applicability 63.9(a)(2), 

63.11519(a)(1)

Notification of construction/reconstruction 63.9(b)(5)

Notification of special compliance requirements 63.9(d)

Notification of performance test 63.9(e)

Notification of opacity/VE observations 63.9(f)

Additional CMS notifications 63.9(g)

Notification of compliance status 63.9(h), 

63.11519(a)(2)

Notification of changes in information 63.9(j)

Reports

Annual certification of compliance 63.11519(b)(1)

Exceedence report for opacity 63.11519(b)(8), 

63.11516(f)(7)(i)

Site-specific welding emissions management plan 63.11519(b)(9), 

63.11516(f)(7)(ii)

Startup, shutdown, or malfunction (SSM) plan 63.6(e)(3)

Performance test plan 63.7(c)(2)

CMS quality control plan 63.8(d)

CMS performance evaluation test plan 63.8(e)(3)

A source must keep the following records:

Recordkeeping

Records of notifications 63.10, 

63.11519(c)(1)(i)

Records that demonstrate continuous compliance 63.10, 

63.11519(c)(1)&(4-

15)
7

Recordkeeping

Monitoring/inspection information 63.10, 

63.11519(c)(2-3)

Reports of exceedences N/A

Semiannual monitoring reports N/A

Initial/repeat performance tests 63.7(e)(1), 

63.6(h)(7)

Quality assurance test plan 63.7(c)

CMS performance evaluation/report 63.8(e)(5)

SSM reports 63.6(e)(3)

Excess emissions reports 63.10(e)(3)

Annual compliance certifications N/A

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

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Method 22 or 9 tests, and repeat performance tests 

if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.
8

Respondent Activities

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

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in 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 and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. 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.
9

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 large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Nine Metal 

Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (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 35,700 (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: 
10

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 only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. There are neither capital/startup nor operation 

and maintenance costs.

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

The only type of industry costs associated with the information collection activity in the 

regulations is labor cost. There are no capital/startup or operation and maintenance 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 

$637,501. 

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%)

These rates are from the Office of Personnel Management (OPM), 2015 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 Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) 

(Renewal).

(d) Estimating the Respondent Universe and Total Burden and Costs
11

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

5,800 existing respondents will be subject to these standards. It is estimated that additional 

respondents per year will not become subject. The overall average number of respondents, as 

shown in the table below, is 5,800 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 0 5,800 0 0 5,800

2 0 5,800 0 0 5,800

3 0 5,800 0 0 5,800

Average 0 5,800 0 0 5,800

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 5,800. 

The total number of annual responses per year is calculated using the following table: 
12

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Initial Notification10 1 0 0

Notification of Compliance 

Status1

0 1 0 0

Annual Certification/ 

Compliance Report2

5,800 1 0 5,800

Exceedence Reports 290 1 0 290

Total 6,090

1 One-time notification

2 Covers the semiannual reporting period from January 1 to December 31

The number of Total Annual Responses is 6,090. 

The total annual labor costs are $3,600,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Nine Metal 

Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 35,700. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost – NESHAP for Nine Metal Fabrication and 

Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (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. 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 6 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. The cost 

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

(O&M) Costs.
13

(ii) The Agency Tally

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

14,000 labor hours at a cost of $640,000. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, 

Subpart XXXXXX) (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 adjustment increase in the estimated burden as currently identified in the 

OMB Inventory of Approved Burdens. The previous ICR incorrectly carried over burdens and 

costs from initial activities and divided the total number of respondents by three. This ICR is 

corrected to reflect the annual, on-going burden and costs for existing facilities. In addition, the 

use of more updated labor rates results in an increase in total labor costs. The overall result is an 

increase in burden hours and costs.

6(g) Burden Statement

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

is estimated to average 6 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 neither conduct nor sponsor, and a person is not required to respond to, a 

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

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

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

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

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

Docket ID Number EPA-HQ-OECA-2014-0098. 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 
14

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

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

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

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

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

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

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA-HQ-OECA-2014-0098 and OMB Control Number 2060-0622 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR 

Part 63, Subpart XXXXXX) (Renewal)

Burden Item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Personhours per 

respondent

per year

(C=AxB)

(D)

Respondent

s per year a

(E)

Technical 

personhours

per year

(E=CxD)

(F)

Managerial 

personhours

per year

(E x 0.05)

(G)

Clerical 

personhours

per year

(E x 0.10)

(H)

Total

Cost, $ b

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and 

Utilization of Technology and 

Systems

N/A

4. Reporting Requirements

A. Read instructions c, d 4 1 4 0 0 0 0 $0 

B. Required activities

 Initial notification c

2 1 2 0 0 0 0 $0

 Notification of compliance status 

c, e 4 1 4 0 0 0 0 $0 

 Annual compliance certification f

2 1 2 5,800 11,600 580 1,160 $1,341,487.8

0 

 Report of exceedencess g

2 1 2 290 580 29 58 $67,074.39 

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

Subtotal for Reporting 

Requirements 14,007 $1,408,562.19

5. Recordkeeping Requirements 
16

Burden Item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Personhours per 

respondent

per year

(C=AxB)

(D)

Respondent

s per year a

(E)

Technical 

personhours

per year

(E=CxD)

(F)

Managerial 

personhours

per year

(E x 0.05)

(G)

Clerical 

personhours

per year

(E x 0.10)

(H)

Total

Cost, $ b

A. Read instructions See 4A

B. Plan activities See 5E

C. Implement activities See 5E

D. Develop record system See 5E

E. Time to enter information

 Records of all information 

required by standards h 0.25 12 3 5,800 17,400 870 1740 $2,012,231.70 

F. Time to train personnel N/A

G. Time to adjust existing ways to 

comply with previously applicable 

requirements

N/A

H. Time to transmit or disclose 

information i 0.25 1 0.25 5,800 1,450 72.5 145 $167,685.98 

I. Time for audits N/A

Subtotal for Recordkeeping 

Requirement 21,678

$2,179,917.6

8

TOTAL LABOR BURDEN AND 

COST 35,684.50 $3,588,479.8

7

(Rounded) 35,685 $3,588,480 

Capital and O&M Cost (see 

Section 6(b)(iii)): $0 

TOTAL COST: $3,588,480 

Assumptions:
17

a There are an estimated 5,800 existing metal fabrication and finishing facilities subject to the rule with no new facilities expected

b

 This ICR uses the following labor rates: $129.93 for managerial labor, $103.97 for technical labor, and $51.79 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 have been increased by 110 percent to 

account for the benefit packages available to those employed by private industry. 

c

 One-time notification.

d

 We have assumed that each respondent will each take four hours to read instructions.

e

 We have assumed that each respondent will take four hours to complete the notification of compliance status task.

f

 We have assumed that each respondent will take two hours once per year to complete the task.

g

 Percentage of respondents with exceedances is assumed to be 5%. This item includes preparing the exceedence report and revising the site-specific welding emissions 

management plan as a result of the exceedence. 

h We have assumed that each respondent will take 0.25 hours once per month to record information that are required by the standards.

i We have assumed that each respondent will take 0.25 hours once per month to transmit or disclose information.

 j Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. 
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR 

Part 63, Subpart XXXXXX) (Renewal)

Activity

(A)

Personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Personhours per 

respondent

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours

(E=CxD)

(F)

Managerial 

personhours

(Ex0.05)

(G)

Clerical 

personhours

(Ex0.1)

(H)

Cost, $b

Report Review:

 Initial Notification c1 1 1 0 0 0 0 $0 

 Notification of compliance status c2 1 2 0 0 0 0 $0 

 Annual Certification/ Compliance Report d2 1 2 5,800 11,600 580 1,160 $607,144.00 

 Report of exceedence d,e 2 1 2 290 580 29 58 $30,357.20 

TOTAL ANNUAL BURDEN AND COST 

(rounded) 14,007 $637,501 

Assumptions:

a

 There are an estimated 5,800 existing metal fabrication and finishing facilities subject to the rule with no new facilities expected.

b This ICR uses the following average hourly labor rates: For managerial $62.90 (GS-13, Step 5, $39.31 + 60%), $46.67 (GS-12, Step 1, $29.17 x 1.6) for technical, and $25.25 

(GS-6, Step 3, $15.78 x 1.6) for clerical. 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

 One-time notification.

d

 We have assumed two hours once per year to review reports.

e

 Percentage of respondents with exceedances is assumed to be 5%.

f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.