**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal), EPA I CR Number 2056.05, OMB Control Number 2060

- 0486. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP ) for Miscellaneous Metal Parts and Products were proposed on August 134, 2002 , and promulgated on January

2, 2004 . These regulations appl y to existing and new facilities with miscellaneous metal parts and products surface coating operations, and associate d equipment or containers used for mixing, conveying, storage, or waste. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart MMMM

. 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected f acilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. Al l reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Respondents to this I CR are owners and operators of facilities that conduct miscellaneous metal parts and products surface coating operations

. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP fo r Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal)

. T he burden to the “Federal Government” is attributed entirel y to work performed b y federal employees or government contractors and can be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart2

MMMM) (Renewal)

. Over the next three ye ars, approximately 4,992 respondents per ye ar will be subject to the se standard s , and no additional respondents per year will become subject to the standard. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance ”

.

**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, durin g such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, hazardous air pollutant (HAP) emissions (predominantl y xylene, toluene, methyl ethyl ketone, phenol , and cresols/cresylic acid) from miscellaneous metal parts and products surface coating operations cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart MMMM

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial3

capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the 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 properl y installed and operated , 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 requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart MMMM

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is 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, duplication does not exist. **3(b) Pub lic 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 ( 79 FR 30117 ) on May 27, 2014

. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts.4

Industry trade association s and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the se standard s has been reviewed previousl y to determine the minimum information needed for compliance purposes. Indeveloping this ICR , we contacted both the National Electrical Manufactures Association (NEMA) , at (703) 841

- 3245 , and Essex Group , at (260) 461

- 5110

. EPA received comments from NEMA requesting that the ICR language found in section 2(a), regarding the intent of Section 112 of the Clean Air Act, be revised in future I CRs. NEMA asks that the language be clarified so that it’s clear the standard is not to achieve a “maximum degree of emissions reduction”, which can be misconstrued to mean an 100% emissions reduction, but rather a “maximum degree of emissions reduction that the Administrator determines is achievable when taking into account cost and other relevant factors”. No revisions were made to this I CR renewal as a result of the comment. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. In this case, no comments were received. **3(d) Effects of Less Frequent Colle ction**  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 operation and maintenance of control equipment and the possibility

of detecting violations would be les s likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar st atute of limitations on which the permit program is based. The retention of records for five years allow s 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 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 2,5

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 question s. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements owners or operators of facilities that perform surface coating of miscellaneous metal parts and products . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards , and the corresponding North American Industry Classification System (NAICS ) codes are listed in the following table:

**Standard (** **40 CFR Part 63, Subpart** 

**MMMM) SIC Codes**  **NAICS Codes** Engines and Turbines, Aircraft Engines and Engine Parts, Aircraft Parts and Auxiliary Equipment 3724, 3728, 376X 336413, 336414, 336415, 54171
Motor Vehicles and Motor Vehicle Equipment 3711, 3713, 3714, 3292, 3429, 3465, 3694, 3829 335312, 336111, 336211, 336312, 33632, 33633, 33634, 33637, 336399 Rolling, Drawing, and Extruding of Nonferrous Metals 3354, 3365, 3442, 3446 331316, 331524, 332321, 332323 Farm and Garden Machinery and Equipment, Construction Machinery and Equipment 3511, 3519, 352X, 353X, 33312, 333611, 333618 Coat Products by

Job and Customer Rather than Coating the One Product or Group of Products 3441, 3471, 3499, 3999 332312, 332722, 332813, 332991, 332999, 334119, 336413, 339999 Motor Vehicles and Motor Vehicle Equipment 3711, 3713, 3716 33612, 336211 Rolling, Drawing, and Extruding of Nonferrous Metal Wire 3351, 3357 331319, 331422, 335929 Prefabricated Metal Buildings and 3448 3323116

Components Metal Shipping Barrels, Drums, Kegs, and Pails 2655, 3089, 3325, 3412, 3443, 5085 33242, 81131, 322214, 326199, 331513, 332439 Primary Metal Industries 331X, 332X, 336X, 3399 331111, 331513, 33121, 331221, 331511 Transportation Equipment 3731, 3743, 4011, 4741 33651, 336611, 482111 Transp ortation Equipment 3083, 3354, 3713, 3714, 3716, 375X, 3792 3369, 331316, 336991, 336211, 336112, 336213, 336214, 336399 Fabricated Rubber Products (applied to metal) 3061, 3069, 3479 326291, 326299 Fabricated Structural Metal Products 3441, 3448 332311, 332312 Transportation Equipment Not Listed Otherwise 3711, 3519, 3714, 3715, 3795, 3621, 336212, 336999, 56211 33635, 56121, 8111, **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM). A source must make the following reports:

**Notification s**  Initial Notification 63.3910(b) Notification of Compliance Status 63.3910(c) Notification of construction or reconstruction 63.9(b) Notification of actual date of initial startup 63.9(b) Notification of intent to conduct a performance test 63.7(b); 63.9(e); 63.3910(a)
**Reports** Periodic reports (semiannual) 63.3920(a) Statement of compliance (if no exceedances occurred) 63.3920(a)7 **Reports** Average monitoring data for any periods where exceedances or excursions occur 63.3920(a) Periods of monitoring s ystem downtime 63.3920(a) Results of any

performance tests 63.3920(b) Startup, shutdown, malfuncti on reports 63.3920(c) A source must keep the following records:
**Recordkeeping** Five

- ye ar retention of records 63.10(b)(1) Material formulation data 63.3930(b) Records of HAP content calculations 63.3930(c) Copies of Notifications and Reports 63.3930(a) Records of names of materials used 63.3930(d) HAP fractions in each material used 63.3930(e) Coating solids fraction in each material used 63.3930(f) Density of materials used 63.3930(g) Documentation of waste material shipped offsite 63.3930(h) Startup, shutdown, and malfunction plan/records 63.6(e)(3); 63.3900(c); 63.3930(k) Documentation of control device performance tests 63.10(b)(2); 63.3930(k) Values measured b y continuous monitoring systems 63.3968 Monitoring s ys tem calibrations, maintenance 63.3968 Periods of monitoring s ystem failure/shutdown 63.3968 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 recordke eping at a plant site. **(ii) Respondent Activities**8

**Respondent Activities** Familiarization with the regulatory requirements. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for the control device. 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 or 311 test , and repeat performance tests if necessary

. Write the notifications and rep orts 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 sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.

**5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, 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.9 **Agency Activities** Input, anal yz e, and maintain data in Integrated Compliance Information System (I CI S) and ECHO. **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y 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.
In fo rmation contained in the reports is reported b y state and local governments in the IC IS Air database which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data f or industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retri eve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting re quirements 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 e conomies of scale to reduce their burden, the overall burden will be reduced.

**5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal)

.10

**6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these record

keeping and reporting requirement s is estimated to be 2, 280,000 ( Total Labor Hours from Table 1 below). These hours are base d on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously

- approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor**  **Costs** This I CR uses the following labor rates: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) E stimating Capital/Startup and Operation and Maintenance 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 costs associated with continuous monitoring. Th e 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**11 **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 Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)
CPMS

– magnet wire facilities $0 0 $0 $50,000 11 $550,000
CPMS

– other facilities **1** $0 0 $0 $5,000 100 $500,000
**Total $0**  **$1,050,000 1**  An estimated 2 percent of non

- magnet wire facilities have installed add

- on control devices. Other facilities comply with the standards by reformulating their coating materials. The total capital/startup costs for this I CR are $ 0

. This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 1,050,000

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry o ver the next three years of the IC R is estimated to be $ 1,050,000

. These are the costs of recordkeeping

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 6,270, 000

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 for12

Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM ) (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 4,992 existing respondents will be subject to the se standard s . It is estimated that n o additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 4,992 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 4,992 0 0 4,992
2 0 4,992 0 0 4,992
3 0 4,992 0 0 4,992 Average 0 4,992 0 0 4,992 1 New respondents include sources with constructed and reconstructed affected facilities

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 4,992

. The total number of annual responses per ye ar is calculated using the following table:13 **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 0 1 0 0 Notification of Performance Test 0 1 0 0 Notification of Compliance Status 0 1 0 0 Semiannual Report 4,992 2 0 9,984 Total 9,984 The number of Total Annual Responses is 9,984. The total annual labor costs are $ 22 9 , 000 , 000

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 below , respectively , and summarized below. **(i) Respondent Tally**  The total annual labor hours are 2, 2 80 , 000

. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost

– NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 8 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are 1,050,000

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

**(ii) The Agency Tally**14

The average annual Agency burden and cost over next three years is estimated to be 13 8 , 000 labor hours at a cost of $ 6,270, 000 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subp art MMMM) (Renewal). We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. **6(f) Reasons for Change in Burden** There is a small increase in the respondent burden due to adjustments. The increase is not due to regulation changes. Inthis ICR, we assume existing respondents have to re

- familiarize themselves each year with the regulatory requirements. In addition, we have rounded the estimates to three significant digits, which results in an apparent increase. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 8 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of inform ation; 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 disp lays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested method s for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 201 4

- 0 0 90. An elec tronic 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 do cuments 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), WJC West,15

Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street , NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 1 4

- 0 0 90 and OMB Control Number 2060

- 0486 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.16

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for Miscellaneous Metal Parts and**  **Products (40 CFR Part 63, Subpart MMMM)**  **(Renewal)**

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

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

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

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

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

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

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

**Total Cost Per year**  **b**

1. Familiarization with rule requirements 4 1 4 4,992 19,968 998.4 1,996.8 $2,309,209 2. Plan activities 8 1 8 0 0 0 0 $0 3. Training 8 1 8 0 0 0 0 $0 4. Create, test, and research and development 0 1 0 0 0 0 0 $0 5. Gather information and monitor 18 12 216 4,981 1 , 075 , 896 53 , 794.8 107 , 589.6 $124,422,531 5.1 Gather information and monitor Magnet wire facilities c 36 12 432 11 4 , 752 237.6 475.2 $549,547 6. Process/Compile and Review 12 12 144 4,981 717 , 264 35 , 863.2 71 , 726.4 $82,948,354 6.1 Process/Compile and Review

- Magnet wire facilities c 24 12 288 11 3168 158.4 316.8 $366,365 7. Semiannual Reports d 8 2 16 4,992 79 , 872 3 , 993.6 7 , 987.2 $9,236,837 **Subtotal for Reporting Requirements 2,**  **186,058 $** **219,832,844** Recordkeeping requirements 8. Record/disclose information e 4 2 8 4,992 39 , 936 1 , 996.8 3 , 993.6 $4,618,419 9. Store/File information e 4 2 8 4,992 39 , 936 1 , 996.8 3 , 993.6 $4,618,419 10. LDAR reporting and recordkeeping 0 0 0 0 0 0 0 $0 **Subtotal for Recordkeeping Requirements 91,85** **3 $9,236,837**  **TOTAL ANNUAL**  **BURDEN AND COST (rounded) 2,2**  **80,000 $** **229,000,000 Capital and O&M Costs (see Section 6(b)(iii))**  **$ 1,050,000**  **GRAND TOTAL (Labor and Capital/O&M Costs)**  **$ 230,000,000**  Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.17

**Assu mptions:** 

a We have assumed that there are approximately 4,992 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR. b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 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 increa sed by 110 percent to account for the benefit packages available to those employed by private industry.

c We assumed that the eleven magnet wire facilities on average incorporate a higher number of processes that’s typical for the industry. The burden of gathering information, monitoring, and processing compiling, and reviewing has been estimated based on c omments received from NEMA. d We have assumed that each respondent will take eight hours twice per year to complete the semiannual reports.
e We have assumed that each respondent will take four hours twice per year to complete task.18

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63,**  **Subpart MMMM) (Renewal)** 

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

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

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

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

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

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

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

**Total Cost Per year**  **b**

1. Initial performance and test N/A 0 0 0 0 0 0 $ 0 2. Repeat performance test N/A 0 0 0 0 0 0 $ 0 3. Report review a) Initial notification 8 0 0 0 0 0 0 $ 0 b) Notification of performance test N/A 0 0 0 0 0 0 $ 0 c) Notification of compliance status 12 0 0 0 0 0 0 $ 0 d) Semiannual report c 12 2 24 4,992 119 , 808 5 , 990.4 11 , 980.8 $ 6 , 270 , 750.72 **TOTAL ANNUAL EPA BURDEN and COST**  **(rounded) 138,000**  **$6,270, 000**  Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

**Assu mptions:**  a We have assumed that there are approximately 4,992 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR.
b This cost is based on the following labor rates: $62.90 for Managerial (GS

- 13, Step 5, $39.31 + 60%), $46.67 for Technical (GS

- 12, Step 1, $29.17+ 60%), and $25.25 Clerical (GS

- 6, Step 3, $15.78+ 60%). These rates are from the Office of Personnel Manage ment (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.

c We have assumed that each respondent will take 12 hours twice a year to complete semiannual report.