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 1954.05, OMB Control Number 2060-0457

1(b) Short Characterization/Abstract

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

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

NNNN) were proposed on December 22, 2000, and promulgated on July 23, 2002. These 

regulations apply to both existing and new facilities that perform surface coating of large 

household and commercial appliances and related parts where the total Hazardous Air Pollutants 

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

HAPs emitted are greater than or equal to 25 tons per year of any combination of HAPs. New 

facilities include those that commenced construction or reconstruction after the date of the 

proposal. This information is being collected to assure compliance with 40 CFR part 63, 

subpart NNNN.

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

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

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

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

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

and are required of all affected facilities subject to NESHAP.

Any owner or 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.

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

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

owner/operator of the plant site).

Over the next three years, an average of 102 respondents per year will be subject to the 

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

three-year period of this ICR.
2

The active (previous) ICR had the following “Terms of Clearance:”

When this ICR is renewed, EPA should review the respondent

burden, universe, response number, labor rates, and capital

costs and ensure these estimates have been updated.

EPA addressed each item of concern in the TOC. The respondent burden, universe,

response number, and labor rates were updated and incorporated into the burden tables for both 

the “Affected Public” and the “Federal Government.” The capital costs were also updated to 

reflect changes in the respondent universe.

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

United States are owned and operated by the large household and commercial appliance 

manufacturing industry (the “Affected Public”). None of the facilities in the United States are 

owned by state, local, tribal or the Federal government. They are all privatelyowned, for-profit 

businesses. The burden to the “Affected Public” 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). The burden to the 

“Federal Government” is attributed entirely to work performed by Federal employees or 

government contractors. This burden may be found 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).

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 or 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 large household and commercial 
3

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

be anticipated to endanger public health or welfare. Therefore, NESHAP for this source 

category were promulgated at 40 CFR part 63, subpart NNNN.

2(b) Practical Utility/Users of the Data

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

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

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

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

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

ensure compliance with the standard at all times. 

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

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

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

installed and operated and/or leaks are being detected and repaired and the standard are 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. Non-duplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested is required under 40 CFR part 63, subpart 

NNNN.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent 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 their own similar standards to implement the 

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

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

3(b) Public Notice Required Prior to ICR Submission to Office of Management and 

Budget (OMB)

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

in the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the 

burden published in the Federal Register.
4

3(c) Consultations

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

number of effected 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 the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS 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 internal industry experts. 

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

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

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

purposes. In developing this ICR, we contacted: 1) the Association of Home Appliance 

Manufacturers (AHAM), at (202) 872-5955; 2) Whirlpool Corporation, at (269) 923-3614; 

and 3) the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) at (703) 524-8800. 

A comment was received from Whirlpool Corporation indicating that the annual O&M time 

varies from 24 to 80 hours at a technicians pay grade depending on the size of the facility, 

sophistication of management systems, and the amount of field verification checks. Based on this 

comment, the estimate annual Operations and Maintenance (O&M) costs were updated in 

Section 6(b)(iii).

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 required standards. Requirements for information gathering 

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

established by OMB at 5 CFR part 1320, section 1320.5.

These standards require affected facilities 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 
5

enforcement action. EPA has found that the most flagrant violators frequently have violations 

extending beyond the five years. EPA would be prevented from pursuing the worst 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.

4. The Respondents and the Information Requested 

4(a) Respondents, SIC and NAICS Codes

The respondents of the recordkeeping and reporting requirements are those that perform 

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

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

standards, which correspond to the North American Industry Classification System (NAICS) 

codes, are listed below for this source category.

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

Household Cooking Appliance Manufacturing 3631 335221

Household Refrigerator and Home Freezer Manufacturing 3632 335222

Household Laundry Equipment Manufacturing 3633 335224

Other Major Household Appliance Manufacturing 3639 335228

Commercial laundry, Drycleaning, and Pressing Machine

Manufacturing 3582 333312

Air-Conditioning and Warm Air Heating Equipment and 

Commercial and Industrial Refrigeration Equipment 

Manufacturing

3585 333415

Other Commercial and Service Industry Machinery

Manufacturing 3589 333319
6

4(b) Information Requested

(i) Data Items

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

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

NNNN).

A source must make the following reports:

Notifications

Initial notification 63.4110(a)(1), 63.9(b)

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

63.4110(b), 63.9(h)

Notification of construction or reconstruction 63.5

Notification of actual startup 63.9(b)

Notification of performance test 63.7(b)

Reports

Semiannual report 63.4120

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

Report of performance test 63.4120(h)

Startup, shutdown, malfunction report 63.4120(j)

A source must keep the following records:

Recordkeeping

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

Material formulation data 63.4130(b)

Records of HAP content calculations 63.4131(c)

Copies of notifications and reports 63.4131(a)

Records of names of materials used 63.4131(d)

HAP fractions in each material used 63.4131(e)

Coating solids fraction in each material used 63.4131(f)

Density of materials used 63.4131(g)

Documentation of waste material shipped offsite 63.4131(h)

Start-up, shutdown, and malfunction plan/records 63.4131(j),(k),63.6(e)

Documentation of control device performance tests 63.4131(k),63.10(b)

Values measured by continuous monitoring systems 63.4131(k)
7

Recordkeeping

Monitoring system calibrations, maintenance 63.4131(k)

Periods of monitoring system failure/shutdown 63.4131(j),(k)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

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

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

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

drop for oxidizer, carbon adsorber, condenser, concentrator, or capture system.

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

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

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

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter data in 

an automated way e.g., continuous parameter monitoring system. Although personnel at the 

source still need to evaluate the data, this type of monitoring equipment has significantly reduced 

the burden associated with monitoring and recordkeeping.
8

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, excess emissions reports, 

startup, shutdown, malfunction plan, and quality control plan for CMS required to be 

submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

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

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

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

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

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

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

determinations.

Information contained in the reports is entered into the AFS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

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

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

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

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

years.

5(c) Small Entity Flexibility

A majority of the respondents are 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 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, 
9

the overall burden will be reduced. In the Background Information for the Large Appliance 

Surface Coating Operations NESHAP1, 57 percent of the parent companies affected by proposed 

action were estimated to be small entities as defined by the Small Business Administration. The 

Agency assumes that 57 percent of the 102 facilities affected by this ICR, or 58 facilities, are 

small entities.

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 the Surface 

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

(Renewal).

6. Estimating the Burden and Cost of the Collection

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

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

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

the concept of burden under the Paperwork Reduction Act. Specific tasks and major 

assumptions have been identified were appropriate. 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 32,634 hours (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%)

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

 

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

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

006
10

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

September, 2011, “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 and Operations and Maintenance Costs

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

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

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

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

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

(iii) Capital/Startup vs. Operating 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 

Respondent1

(F)

Number of 

Respondents 

with O&M

(G)

Total 

O&M,

(E X F)

CEM $16,000 4 $64,000 $5,200 102 $530,400

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

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

assumed and multiplied by the technical labor rate of $99.14.

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

the above table. 

The total operating and maintenance (O&M) costs for this ICR are $530,400. This is the 

total of column G. 

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

industry over the next three years of the ICR is estimated to be $594,400. These are 

recordkeeping costs.

6(c) Estimating Agency Burden and Cost

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

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

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

emissions, and the publication and distribution of collected information.

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

$138,060. 
11

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

Managerial $62.27 (GS-13, Step 5, $38.92 x 1.6)

Technical $46.21 (GS-12, Step 1, $28.88 x 1.6)

Clerical $25.01 (GS-6, Step 3, $15.63 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” 

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

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

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

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

NNNN) (Renewal).

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

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

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

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

in the table below, is 102 per year. 

The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.

Number of Respondents

Year (A)

Number of 

New

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That 

Keep Records but Do 

Not Submit Reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 4 94 0 0 98

2 4 98 0 0 102

3 4 102 0 0 106

Average 4 98 0 0 102

1

New respondent 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 102.

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

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 4 1 0 4
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

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 1.2 0 4.8

Report of performance test 4 1.2 0 4.8

Semiannual report 102 2 0 204

Excess emissions report 102 0.5 0 51

Startup, shutdown, malfunction report 102 0.5 0 51

Total 332 (Rounded)

The number of Total Annual Responses is 332.

The total annual labor costs are $3,126,918. 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 both 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 32,634, at a cost of $3,126,918. 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). 

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

information is estimated to average 98 hours per response.

The total annual capital and O&M costs to the regulated entity are $594,400. These costs 

are detailed above 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 

3,064 labor hours at a cost of $138,060. See below Table 2: Average Annual EPA Burden and 

Cost - NESHAP for the Surface Coating of Large Household and Commercial Appliances (40 
13

CFR Part 63, Subpart NNNN) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated burden hours and costs for both the 

respondents and the Agency as currently identified in the OMB Inventory of Approved Burdens. 

This increase is not due to any program changes. This change is due to an increase in the average 

number of respondents subject to the standard, and an increase in labor rates. This ICR uses 

updated labor rates for each of the three labor categories.

There is also an increase in the O&M costs to the respondents. The costs were updated to 

reflect comments received during consultation. 

6(g) Burden Statement

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

is estimated to average 98 hours per response. Burden means the total time, effort, or financial 

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

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

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

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

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

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

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

the information.

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

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

Numbers for EPA’s 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-2011-0259. An electronic version of the public docket is 

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

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

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

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

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

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

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

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

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

number for the Enforcement and Compliance Docket and Information Center Docket is (202) 

566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, 
14

Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: 

Desk Office for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0259

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.
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) 

PersonHours per 

occurrence

(B)

Number of 

occurrences 

per year

(C) 

PersonHours per 

respondent 

per year

(C=A*B)

(D) 

Respondents 

per year a 

(E) 

Technical 

person-hours 

per year 

(E=C*D)

(F) 

Management 

person-hours 

per year

(F=E*0.05)

(G) 

Clerical 

person-hours 

per year 

(G=E*0.1)

(H)

Annual costs 

($) b

1 Read rule and instructions c4 1 4 102 408 20.4 40.8 $44,958.34

2 Plan activities d8 1 8 102 816 40.8 81.6 $89,916.67

3 Training d8 1 8 102 816 40.8 81.6 $89,916.67

4 Create, test, and research and 

development 1 0 0 0 0 0 0 $0

5 Gather information, monitor, and 

inspect e12 12 144 102 14,688 734.4 1,468.8 $1,618,500.10

6 Process/compile and review f8 12 96 102 9,792 489.6 979.2 $1,079,000.06

7 Complete reports g8 2 16 102 1,632 81.6 163.2 $179,833.34

Subtotal for Reporting Requirements 32,374.8

8 Record/disclose h1 2 2 102 180 9 18 $19,834.56

9 Store/file 0.25 2 0.5 102 45 2.25 4.5 $4,958.64

10 LDAR reporting and recordkeeping 0 0 0 0 0 0 0 $0

Subtotal for Recordkeeping Requirements 258.8

28,377 1,418.9 2,837.7

TOTAL ANNUAL BURDEN AND 

COST (rounded) 32,634 $3,126,918

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 102. There will be four additional new sources that will become 

subject to the rule over the three-year period of this ICR. 
16

b

 This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per 

hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “Table 2. Civilian Workers, by 

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

available to those employed by private industry.

c

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

d

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

e

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

f

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

g

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

h

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

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

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

Activity

(A)

Personhours per 

activity

(B)

Number of 

activities 

per year

(C)

Technical 

personhours per 

year

(C=A*B) a

(D)

Management 

personhours per 

year

(D=C*0.05)

(E)

Clerical 

personhours per 

year

(E=C*0.1)

(F)

Annual

Costs ($/yr) b

1 Initial performance and test c24 4 96 4.8 9.6 $4,975.15 

2 Repeat performance test d24 1 24 1.2 2.4 $1,243.79 

3 Report review

 a) Initial notification e8 4 32 1.6 3.2 $1,658.38 

 b) Notification of performance test e8 4 32 1.6 3.2 $1,658.38 

 c) Notification of compliance status e8 4 32 1.6 3.2 $1,658.38 

 d) Semiannual reports f12 204 2,448 122.4 244.8 $126,866.38 

Subtotal Labor Burden and Cost 2,664 133 266 $138,060.47 

TOTAL ANNUAL BURDEN AND COST (rounded) 3,064 $138,060 

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be 102. 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 which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

Managerial rate of $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step3, $15.63 

x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c

 We have assumed that each respondent will take 24 hours four times per year to complete task.

d

 We have assumed that each respondent will take 24 hours once per year to repeat performance test because of failure.

e

 We have assumed that each respondent will take eight hour four times per year to review notification reports.

f

 We have assumed that each respondent will take 12 hours to review semiannual reports.