1

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) 

(Renewal)

1.0 Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW)

(Renewal), EPA ICR number 2294.03, OMB Control Number 2060-0623. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous air Pollutants (NESHAP) for Plating and 

Polishing Area Sources (40 CFR Part 63 Subpart WWWWWW), were proposed on March 14, 

2008 (73 FR 14126), promulgated on July 1, 2008 (73 FR 37728), and amended on June 20, 

2011 (76 FR 32005) and September 19, 2011 (76 FR 57913). These regulations apply to owners 

or operators of any existing or new plating and polishing facility that is an area source of 

hazardous air pollutants (HAP) emissions and uses one or more of the following metal HAP: 

cadmium, chromium, lead, manganese, or nickel (hereafter referred to as the plating and 

polishing metal HAP). This information is being collected to assure compliance with 40 CFR 

part 63, subpart WWWWWW. 

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

periodic reports. Owners or operators 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 onsite for at least five years following the date of such 

measurements, maintenance reports, and records. All reports are sent to the delegated state or 

local authority. In the event that there is no such delegated authority, the reports are sent directly 

to the United States Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 2,900 respondents per year will be subject to the 

standard, and no additional respondent per year will become subject to the standard. The affected 

sources at plating and polishing facilities includes all plating and polishing tanks that contain one 

or more of the plating and polishing metal HAP; thermal spraying operations that use one or 

more of the plating and polishing metal HAP; and dry mechanical polishing operations that emit 

one or more of the plating and polishing metal HAP. 
2

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

Collection Request (ICR) without any “Terms of Clearance.”

The burden to the “Affected Public” may be found in Table 1: Annual Respondent 

Burden and Cost - NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart 

WWWWWW) (Renewal). The burden to the “Federal Government” is attributed entirely to 

work performed by federal employees or government contractors; this burden may be found in 

Table 2: Average Annual EPA Burden and Cost - NESHAP for Plating and Polishing Operations 

(40 CFR Part 63, Subpart WWWWWW) (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 (CAA), 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 plating and polishing operations

cause or contribute to air pollution that may reasonably be anticipated to endanger public health 

or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 

63, subpart WWWWWW.

2(b) Practical Utility/Users of the Data
3

The recordkeeping and reporting requirements in the standard(s) ensure compliance with 

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

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

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 leaks are being detected and repaired and 

the standard is being met. 

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

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

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

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

WWWWWW. 

3(a) Nonduplication

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

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

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

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

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

duplication exists.

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

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

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

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. 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 the EPA 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’s internal industry experts. 
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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 

purpose. In developing this ICR, we contacted the Wisconsin Department of Natural Resources

at (608) 264-6153 and the National Association for Surface Finishing at (202) 457-0630. In this 

case, one comment was received indicating that the respondent universe might be 

underestimated, however, no alternative estimates were provided. In response to this comment, 

EPA reviewed the respondent universe in OTIS. The respondent universe obtained from OTIS 

was not greater than the number of respondents estimated in this ICR; therefore, no changes were 

made. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5. 

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

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

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

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

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

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

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

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

nonexistence of essential records. 

3(f) Confidentiality

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

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

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

1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979).
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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 Codes

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

of plating and polishing operations. The United States Standard Industrial Classification (SIC) 

codes for the respondents affected by the standard, which corresponds to the North American 

Industry Classification System (NAICS) codes, are listed below for plating and polishing 

operations. 

Standard (40 CFR Part 63, Subpart 

WWWWWW)

SIC Codes NAICS Codes

Hardware Manufacturing 3429/3499 33251

Commercial Gravure Printing 2754/2771 323111

Metal Stamping 3469 332116

Bolt, Nut, Screw, Rivet, and Washer 

Manufacturing

3429/3452 332722

Metal Heat Treating 3398 332811

Metal Coating, Engraving (except jewelry

and silverware), and Allied Services to 

Manufacturers

3479 332812

Plumbing Fixture Fitting and Trim 

Manufacturing

3432 332913

Other Metal Valve and Pipe Fitting 

Manufacturing

3429/3432/3494/3499 332919

All Other Miscellaneous Fabricated Metal 

Product Manufacturing

3291/3429/3432/3494/

3497/3499/3537/3599/

3914/3999

332999

Bare Printed Circuit Board Manufacturing 3672 334412

Aircraft Engine and Engine Parts 

Manufacturing

3724 336412

Jewelry (except costume) Manufacturing 3479/3911 339911

4(b) Information Requested

(i) Data Items
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In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW).

A source must make the following reports:

Notifications

Notification of applicability 40 CFR 63.9(a)(2)

Notification of construction/reconstruction 40 CFR 63.9(b)(5)

Notification of special compliance requirements 40 CFR 63.9(d)

Notification of performance test 40 CFR 63.9(e)

Notification of opacity/VE observations 40 CFR 63.9(f)

Additional CMS notifications 40 CFR 63.9(g)

Notification of compliance status 40 CFR 63.9(h)

Notification of changes in information 40 CFR 63.9(j)

Reports

Startup, shutdown, or malfunction (SSM) plan 40 CFR 63.6(e)(3)

Performance test plan 40 CFR 63.7(c)(2)

CMS quality control plan 40 CFR 63.8(d)

CMS performance evaluation test plan 40 CFR 63.8(e)(3)

A source must keep the following records:

Recordkeeping

Records of notifications 40 CFR 63.10

Records that demonstrate continuous compliance 40 CFR 63.10

Monitoring/inspection information 40 CFR 63.10

Reports of deviations N/A

Semiannual monitoring reports N/A

Initial/repeat performance tests 40 CFR 63.7(e)(1)/ 

40 CFR 63.6(h)(7)

Quality assurance test plan 40 CFR 63.7(c)

CMS performance evaluation/report 40 CFR 63.8(e)(5)

SSM reports 40 CFR 63.6(e)(3)

Excess emissions reports 40 CFR 63.10(e)(3)

Annual compliance certifications N/A
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Electronic Reporting

Some of the respondents to CAA standards are using monitoring equipment that 

automatically records parameter data. Although personnel at the affected facility must evaluate 

the data, internal automation has significantly reduced the burden associated with monitoring and 

recordkeeping at the 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.

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.

Adjust the existing ways to comply with any previously applicable instruction and 

requirements.

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. 

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

Information Management

5(a) Agency Activities
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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 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, 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 entered into OTIS, 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 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

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

shown in Table 1: Annual Respondent Burden and Cost - NESHAP for Plating and Polishing 

Operations (40 CFR Part 63, Subpart WWWWWW) (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. Wherever 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 33,108 ( Total Labor Hours from Table 1). These 

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

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

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs 

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

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/Startup and Operation and Maintenance (O&M) 

Costs 

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

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

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

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

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

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

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

(A)

Recordkeeping 

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

Respondents 

a

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Standard 4-

drawer File 

Cabinet

$25.80 322.22 $8,314 b$0 322 $0

a Assumes one standard four-drawer file cabinet for one-third of the 2,900 facilities, or an average of 2,900/3/3=322 file cabinets 

per year required to maintain records at a cost of $235 per cabinet. The annualized cost per cabinet is $25.80. 

b Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)(1+i)^t/((1+i)^t1) where i = interest rate (%) and t = equipment life (years). CRF = 0.1098. Cabinets are assumed to have a 15-year life, 7% 

interest. The total capital/startup costs for the 15-year period is $75,722. 

The total capital/startup costs for this ICR are $8,314. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs consists of photocopying, and postage 

are $0. This is the total of column G. 

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

industry over the next three years of the ICR is estimated to be $8,314.

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 

$160,287. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)
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Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

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 Plating and 

Polishing Operations (40 CFR Part 63, Subpart WWWWWW) (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

2,900 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject to the standard. 

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

One-time initial notification 967 1 N/A 967

One-time notification of 

compliance status

967 1 N/A 967

Annual compliance certification 48 1 N/A 48

Report of deviation 48 1 N/A 48

Total 2,030

The number of total annual responses is 2,030 per year.

The total annual labor costs are $3,172,379. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Plating and 

Polishing Operations (40 CFR Part 63, Subpart WWWWWW) (Renewal).
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6(e) Bottom Line Burden Hours and Cost Tables

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

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

(i) Respondent tally 

The total annual labor hours are 33,108. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost - NESHAP for Plating and Polishing 

Operations (40 CFR Part 63, Subpart WWWWWW) (Renewal). 

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

information is estimated to average 16 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $8,314.

(ii) The Agency tally 

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

3,557 labor hours at a cost of $160,287. See Table 2: Average Annual EPA Burden and Cost -

NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart WWWWWW) 

(Renewal). 

6(f) Reasons for Change in Burden

There is a decrease in the total hours as currently identified in the OMB Inventory of 

Approved Burdens due to a mathematical error in determining the person hours per respondent in 

the previous ICR. There is an increase in labor costs. This is not due to any program changes. 

The change in the cost estimates occurred due to adjustments in labor rates for both respondents 

and the Agency.

6 (g) Burden Statement

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

is estimated to average 16 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.
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An agency may not conduct or sponsor, and a person is not required to respond to, a 

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

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

burden estimates, and any suggestions for minimizing respondent burden, including through the 

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

Docket ID No. EPA-HQ-OECA-2011-0233, which is available for online viewing at 

http://www.regulations.gov, or in person 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 is (202) 566-1752. An electronic version of the public 

docket is available at http://www.regulations.gov. This site can be used to submit or view public 

comments, access the index listing of the contents of the public docket, and to access those 

documents in the public docket that are available electronically. When in the system, select 

“search,” then key in one of the Docket ID Numbers identified above. 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 relevant Docket ID Number EPA-HQ-OECA-2011-0233 and OMB Control Number 

2060-0623 in any correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection 

associated with the final rule.
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Table 1: Annual Respondent Burden and Cost - NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart 

WWWWWW) (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

(A)

Personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent

(A) x (B)

(D)

Respondents 

per year

(E)

Technical 

personhours

(C) x (D)

(F)

Managerial 

personhours

(E) x 0.05

(G)

Clerical 

personhours

(E) x 0.10

(H)

Cost, $

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 b4 1 4 967 3,868 193.4 386.8 $426,227.68

B. Required activities

 Initial Notification of applicability c2 1 2 967 1,934 96.7 193.4 $213,113.84

 Notification of Compliance Status d4 1 4 967 3,868 193.4 386.8 $426,227.68

 Annual Compliance Certification e2 1 2 967 1,934 96.7 193.4 $213,113.84

 Annual Report of Deviations f2 1 2 48 96 4.8 9.6 $10,578.56

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

Reporting Subtotal 13,455 $1,289,262

5. Recordkeeping Requirements 

A. Read instructions See 4A

B. Plan activities See 5E

C. Implement activities See 5E
15

D. Develop record system See 5E

E. Time to enter information N/A

 Records of all information required 

by standards g

0.33 52 17.16 967 16,593.72 829.69 1,659.37 $1,828,517.00

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 h

0.25 1 0.25 1,982 495.5 24.78 49.55 $54,601.00

I. Time for audits N/A

Recordkeeping Subtotal 19,653 $1,883,118.00

GRAND TOTAL 33,108 $3,172,379

TOTAL NUMBER OF ANNUAL 

RESPONSES i 2,030

CAPITAL COSTS

 File cabinets j$75,722.22

ANNUALIZED CAPITAL COSTS k

 File cabinets (15 year life, 7% 

interest -> CRF=0.1098)

$8,314

TOTAL ANNUALIZED COSTS $8,314

N/A = not applicable.

a

 This ICR uses the following labor rates: $121.42 for managerial labor, $99.14 for technical labor, and $49.81 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, December 2010, “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. 

b There are an estimated 2,900 existing plating and polishing plants and no new facilities are expected; the average number expected to read the rule during the 3-yr clearance 

period is 2,900/3 = 967.

c

 Each of the 2,900 existing plants noted above would be required to submit an initial notification.

d

 Each of the 2,900 existing plants noted above would be required to submit a notification of compliance status.

e

 The 2,900 existing plants would be required to prepare an annual compliance certification at the end of Year 3 of the ICR clearance period and submit the certifications if a 

deviation occurred; assuming that 5 percent of the plants experience a deviation, the number of compliance certifications submitted will be (2,900  0.05)/3 = 48.
16

f

 Assumes that 5% of existing facilities would have to submit a report of deviations starting in Year 3 of the ICR clearance period, or (2,900  0.05)/3 = 48.

g

 Recordkeeping requirements begin in Year 3 of ICR clearance period for all existing plants, or 2,900/3 = 967; it is assumed that 0.33 hr (20 minutes) per week will be required 

per facility for recordkeeping.

h Transmittals would include initial notifications for 2,900 plants, notifications of compliance status for 2,900 plants, annual compliance certifications for 5% of one-third of 2,900

plants, and annual reports of deviations for 5% of one-third of 2,900 facilities in Year 3 , for an average of (2,900 + 2,900 + 2,900/3  0.05 + 2,900/3  0.05)/3 = 2,030 for each 

year of the 3-yr ICR clearance period.

i

 The total annual number of responses is calculated by summing up the product of columns B and D for each of the reports listed in 4B.

j

 Assumes one standard four-drawer file cabinet for one-third of the 2,900 facilities, or an average of 2,900/3/3=322 file cabinets per year required to maintain records at a cost of 

$235 per cabinet.

k

 Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = equipment 

life (years).
17

Table 2: Average Annual EPA Burden and Cost - NESHAP for Plating and Polishing Operations (40 CFR Part 63, 

Subpart WWWWWW) (Renewal)

REPORTING/RECORDKEEPING 

REQUIREMENT

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

Personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent

Respondents 

per year

Technical 

personhours

Managerial 

personhours

Clerical 

personhours

Cost, $

(A) x (B) (C) x (D) (E) x 0.05 (E) x 

0.10

Report Review:

 Initial Notification of applicability b1 1 1 967 967.00 48.35 96.7 $50,112.26

 Notification of Compliance Status c2 1 2 967 1,934000 96.7 193.4 $100,224.52

 Annual Compliance Certification d2 1 2 48 96.00 4.8 9.6 $4,974.95

 Annual Report of Deviations e2 1 2 48 96.00 4.8 9.6 $4,974.95

SUBTOTAL ANNUAL BURDEN 3,093 155 309

$160,287 GRAND TOTAL (Rounded) 3,557

a

 This ICR uses the following average hourly labor rates: $62.27 for managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 (GS-12, Step 1, $28.88 x 1.6) for technical and $25.01 (GS6, Step 3, $15.63 x 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) 2011 General Schedule, which excludes locality rates of pay.

b

 Assumes 2,900 existing and no new plants will complete initial notifications for an average of (2,900)/3 = 967 per year during each year of the 3-yr ICR clearance period.

c

 Each of the 2,900 existing plants noted above would be required to submit a notification of compliance status.

d

 The 2,900 existing plants would be required to prepare an annual compliance certification at the end of Year 3 of the ICR clearance period; any plant that experiences a deviation 

will have to submit the compliance certification; assuming 5 percent of the plants experience a deviation, the number of submittals would be (2,900  0.05)/3 =48.

e

 Assumes that 5% of existing facilities would have to submit a report of deviations starting in Year 3 of the ICR clearance period, or (2,900  0.05)/3 = 48.