1 **SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for**  **Plating and Polishing Area Sources (40 CFR**  **P art**  **63, S**  **ubpart 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 P art 63, Sub part WWWWWW) (Renewal) , EPA IC R number 2294.0 3 , 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 P art 63 S ubpart 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any o wner 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 directl y to the United States Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 2,900 respondents per ye ar 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 currentl y active Information Collection Request (I CR) 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 an d Polishing Operatio ns (40 CFR P art 63, Sub part WWWWWW) (Renewal) . The burden to the “Federal Government” is attributed entirely to work performed b y federal employees or government contractors; this burden may be found in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Plating an d Polishing Operations (40 CFR Part 63, Subp art 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 C lean Air Act (C AA) , 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, us e, 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 Administrat or 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) provid e such other information as the Administrator may reasonabl y 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 6 3 , 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 d elegated 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 recordke eping 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 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, 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 I CR 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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) 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.4

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 comp liance purpose . In developing this I CR, 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 I CR; 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 frequentl y, the proper op eration 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 fiv e ye ar records retention requirements 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 determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violator s 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 b y 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).5

**3 (g) Sensitive Questions**  Th e 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 (SI C ) code s for the respondents affect ed b y the standard , which corresponds to the North American Industry Classification Sy stem (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** 6

In this ICR, all the data that is recorded or reported is required b y 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** S tartup, s hutdown, or m alfunction ( 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/A7

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 significantl y reduced the burden associated with monitoring and recordkeeping at the plant site. Also regulatory

agencies , in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems are still not widely

used. At this time, it is estimated that approximate ly 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 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 maintaini ng information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s 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 s ys tem. 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**8

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 the Online Tracking Information Sy stem (OTI S).
**5 (b)**  **Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to dis cern a source’s initial capability to compl y 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 OTI S , which is operated and maintained by

EPA ’s Office of Compliance. OT IS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses OTI S 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 anal yz e the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5 (c)**  **Sm all 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. D ue to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the s ame for both small and large entities. The Agency considers these to be the minimum requirem ents 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**9

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 P art 63, Sub part 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 applicabl e to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized h eadings 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 c onduct 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 deve lopment 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: Managerial $ 121.42 ($5 7.82 + 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 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 (O&M)**  **Costs** The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs , which are addressed elsewhere in this ICR , and the costs10

associated with continuous moni toring

. 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.

**(ii i** **) 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 Assume s 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)^t

1) 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 f o r the 15

- year period is $75, 722. The total capital/startup costs for this I CR 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 averag e annual cost for capital/startup and operation and maintenance costs to the industry over the next three years of the IC R is estimated to be $8,314

. **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 maintained by the respondents , periodic inspection o f 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 hourl y labor rate as follows:
Man agerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%)11 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 P art 63, Sub part WWWWWW) (Renewal )

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, approximately 2,900 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will be come subject to the standard

. The total number of annual responses per ye ar 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 $3,1 72 , 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 P art 63, Subp art WWWWWW) ( Renewal ).12

**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), respectivel y, 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 P art 63, Sub part WWWWWW) ( Renewal ). Furthermore, the annual publ ic 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 3,5 5 7 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 P art 63, Sub part 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 . Th ere is an increase in labor costs. Thi s 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 b y persons to generate, maintain, retain, or disclo se 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 verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.13

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 I CR under Docket ID No . EPA

- HQ

- OECA

- 2011

- 0 233 , 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 Frid ay , excluding legal holiday s. 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 e lectronic version of the public docket is available at http://www.regulations.gov. Th is 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 sy stem, select “search,” then key

in one of the Docket ID Number s identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number EPA

- HQ

- OECA

- 2011

- 0 233 and OMB Control Number 2060

- 0623 in any c orrespondence. **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 P**  **art 63, Subp**  **art WWWWWW)**  **(Renewal)**

REPORTING/RECORDKEEPING REQUIREMENT (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C)

Person

hours per respondent (A) x (B) (D)

Respondents per year (E)

Technical person hours (C) x (D) (F)

Managerial person hours (E) x 0.05 (G)

Clerical person hours (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 b 4 1 4 967 3,868 193.4 386.8 $4 2 6, 227

. 68 B. Required activities Initial Notification of applicability c 2 1 2 967 1,934 96.7 193.4 $213,113.84 Notification of Compliance Status d 4 1 4 967 3,868 193.4 386.8 $426,227.68 Annual Compliance Certification e 2 1 2 967 1,934 96.7 193.4 $213,113.84 Annual Report of Deviations f 2 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 $1,2 89 , 262 5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities See 5E C. Implement activities See 5E15

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, 59 3.72 829.69 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 49 5.5 24.78 49.55 $ 54,601 .00
I. Time for audits N/A Recordkeeping Subtotal 19 , 65 3 $1, 883,118 .00 **GRAND TOTAL** 33,108 $3,1 72 , 379 TO TAL 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 availa ble 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 exp ected 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 i nitial n otification. d Each of the 2,900 existing plants noted above would be required to submit a n otification of c ompliance s tatus. e The 2,900 existing plants would be required to prepare an a nnual c ompliance c ertification 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 c ompliance c ertifications submitted will be (2,900  0.05) /3 = 48

.16

f Assumes that 5% of existing facilities would have to submit a report of d eviation s 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 n otifications for 2,900 plants, notifications of c ompliance s tatus for 2,900 plants, annual c ompliance c ertifications for 5 % of one - third of 2,900 plants , and annual reports of d eviations 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 c apital 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 P**  **art 63, Subp**  **art WWWWWW) (Renewal)** 

REPORTING/RECORDKEEPING REQUIREMENT (A) (B) (C) (D) (E) (F) (G) (H)

Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent Respondents

per year Technical

person hours Managerial

person hours Clerical

person hours Cost, $ (A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10 Report Review: Initial Notification of applicability b 1 1 1 967 967 .00 48.35 96.7 $50,112 .26 Notification of Compliance Status c 2 1 2 967 1 , 934 000 96.7 193.4 $100,22 4.52 Annual Compliance Certification d 2 1 2 48 96 .00 4.8 9.6 $4,97 4.95 Annual Report of Deviations e 2 1 2 48 96 .00 4.8 9.6 $4,97 4.95 **SUBTOTAL ANNUAL BURDEN 3**  **, 093**  **1 55**  **309 $160,287**  **GRAND TOTAL (Rounded)**  **3,557**

a This ICR uses the followin g 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 (G S

6, Step 3, $ 15.63 x 1.6) for c lerical. These rates are from the Office of Personnel Management (OPM) 20 11 General Schedule , which excludes locality rates of pay

. b Assumes 2,900 existing and no new plants will complete i nitial 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 n otification of c ompliance s tatus. d The 2,900 existing plants would be required to p repare an a nnual c ompliance c ertification at the end of Year 3 of the ICR clearance period ; any plant that experiences a deviation will have to submit the c ompliance c ertificati on; 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 d eviation s starting in Year 3 of the ICR clearance period, or (2,900  0.05)/3 = 48.