**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for**  **Nine Metal Fabrication and Finishing Area Sources (40 CFR**  **P art 63,**  **S ubpart**  **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 I CR 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 appl y to both owners and operators of any exist ing 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 ty

pes 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 co mpliance 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 oc currence 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, an d 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. O ver the next three ye ars, an average of 5,800 respondents per ye ar will be subject to the se standard s , and no additional respondent s per year will become subject to the standard. The Office of Management and Budget (OMB) approved the currentl y active I C R without any

“Terms of Clearance.”2

All of the nine metal fabrication and finishing facilities in the United States are owned and operated b y the metal fabrication and finishing industry (the “Affected Public”). None of these facilities in the United S tates are owned b y s tate, local, tribal or the federal government. They are all privatel y- 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 Fabri cation and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (Renewal). The Federal Government “burden ” is attributed entirely to work performed by either F ederal 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 Cle an 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 reasonabl y 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 anticipat ed 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 the se standard s ens ure compliance with the applicable regulations which w ere 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 d etermine an affected facility ’ s initial3

capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the se standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the se standard s are used to inf orm 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 s 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 rec ordkeeping 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 directl y to the appropriate EPA regional office. Otherwise, the information is s ent directl y 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 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, 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 I CR was published in the Federal Regi ster ( 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 i ndustry

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 se standard s , 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

Ind ustry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the se standard s 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 b y 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** T hese 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 requirement 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 allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determi ne 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 either the destruction or nonexistence of e ssential 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 Bus iness 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** T he 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 ( SI C ) code s for the respondents affected b y the standards and the corresponding North American Industry Classification Sy stem (NAICS ) codes are listed in the table below

. **Standard ( 40 CFR**  **Pa rt 63, Subpart XXXXXX** **) SIC**  **Codes NAICS Codes**  Iron and Steel Forging 3462 332 111 Powder Metallurgy

Part Manufacturing 3499 3 32117 Fabricated Structural Metal Manufacturing 3441, 3449 332 312 Plate Work Manufacturing 3443 332 313 Power Boiler and Heat Exchanger Manufacturing 3443, 3559 332 410 Metal Tank (Heav y Gauge) Manufacturing 3443 332 420 Other Fabricated Wire Product Manufacturing 3399 332 618 Other Metal Valve and Pipe Fitting Manufacturing 3494 332 9 19 All Other Miscellaneous Fabricated Metal Product Manufacturing 3494 332999 Construction Machinery

Manufacturing 3531 33 3120 Oil and Gas Field Machinery and Equipment Manufacturing 3533 33 3132 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 33 59 99

**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 Nine6

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

. A source must make the following reports:

**Notification s**  Initial notification and n otification 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) S tartup, s hutdown, or m alfunction ( 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 test s , and repeat performance tests if necessary

. Write the noti fications 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.8 **Respondent Activities** Develop, acquire, install, and utilize technology and sy stems 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, analy sis, 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, 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 p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to comp ly 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

. 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.9

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 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 ty pes 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 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 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 requirement s 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 I CR uses the following labor rates:10 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 only costs to the regulated industry resulting from information collection activities required b y the subject standard s are labor costs. There are n either capital/startup n or operation and maintenance costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only ty

pe 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 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 th e 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 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% ) These rates are from the Office of Personnel Management (OPM) , 20 1 5 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 I CR, on average over the next three ye ars, approximately 5,800 existing respondents w ill be subject to the se standard s . It is estimated that additional respondents per ye ar 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 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 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. 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 5,800

. The total number of annual responses per ye ar 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 Notification 1 0 1 0 0 Notification of Compliance Status 1 0 1 0 0

Annual Certification/ Compliance Report2 5,800 1 0 5,800

Exceed e nce 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, respectivel y, and summarized be low. **(i) Respondent Tally** The total annual labor hours are 3 5 , 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 ty pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for te chnical tasks because the ty pical 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 $6 40,000 . 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 req uired 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 adjustment increase in the estimated burden as currentl y identified in the OMB Inventory

of Approved Burdens. The previous I CR incorrectl y 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 cost s. **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 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; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifyin g 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 n either conduct n or sponsor, and a person is not required to respond to, a collection of information unless i t 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 t his I CR 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 available14

electronically

. When in the sy stem , 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 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

- 17 52

. 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 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.15

**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)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respond**  **ent per year**  **(C)**

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondent s per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managerial person**  **** **hours per year**  **(E x 0.05) (G)** 

**Clerical person**  **** **hours 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 Sy stems 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 $1,408,562.1**  **9** 5. Recordkeeping Requirements16

**Burden Item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respond**  **ent per year**  **(C)**

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondent s per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managerial person**  **** **hours per year**  **(E x 0.05) (G)** 

**Clerical person**  **** **hours 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 $2,012,231.7 0 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**  **21,67 8**  **$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 P ercentage 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)**

**Acti vity**  **(A) Person** 
**** **hours per occurrence**  **(B)**

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours (E=CxD)**  **(F)**

**Managerial person**  **** **hours (Ex0.05)**  **(G)**

**Clerical person**  **** **hours (Ex0.1)**  **(H)**

**Cost, $ b** 

Report Review: Initial Notification c 1 1 1 0 0 0 0 $0 Notification of compliance status c 2 1 2 0 0 0 0 $0 Annual Certification/ Compliance Report d 2 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 Pers onnel 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 hour s 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.