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 ICR 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 apply to existing and new facilities with miscellaneous 

metal parts and products surface coating operations, and associated 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 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/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

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

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

Environmental Protection Agency (EPA) regional office.

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

affected 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 ICR 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 for Miscellaneous 

Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal). The burden to the 

“Federal Government” is attributed entirely to work performed by 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, Subpart 
2

MMMM) (Renewal).

Over the next three years, approximately 4,992 respondents per year will be subject to 

these standards, and no additional respondents per year will become subject to the standard. 

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

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, 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, hazardous air pollutant (HAP) emissions (predominantly 

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

reasonably 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 were promulgated in accordance with the Clean Air Act. The 

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

Performance tests are required in order to determine an affected facility’s initial 
3

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 properly 

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 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, 

duplication does not exist.

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

An announcement of a public comment period for the renewal of this ICR 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 associations and other interested parties were provided an opportunity to 

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

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

compliance purposes. In developing 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 ICRs. 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 ICR 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 first Federal Register notice. In this 

case, no comments were received. 

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 requirement is consistent with 

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

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

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

questions.

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 (SIC) code for the respondents affected by 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 332311
6

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

Transportation 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 by the NESHAP for 

Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM). 

A source must make the following reports:

Notifications

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 system downtime 63.3920(a)

Results of any performance tests 63.3920(b)

Startup, shutdown, malfunction reports 63.3920(c)

A source must keep the following records:

Recordkeeping

Five-year 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 by continuous monitoring systems 63.3968

Monitoring system calibrations, maintenance 63.3968

Periods of monitoring system 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 recordkeeping 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 reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

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, analyze, and maintain data in Integrated Compliance Information System (ICIS) 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 properly installed and operated. Performance 

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

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

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

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

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

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

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

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

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

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for 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 ICR. The 

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

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

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

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 2,280,000 (Total Labor Hours from Table 

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

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

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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 by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The 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 

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
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 

facilities1

$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 ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR 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 over the next three years of the ICR 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 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 

$6,270,000. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

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

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

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 
12

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 ICR, on average over the next three years, approximately

4,992 existing respondents will be subject to these standards. It is estimated that no additional 

respondents per year 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 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 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.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 4,992. 

The total number of annual responses per year 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 $229,000,000. 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 2,280,000. 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 typical 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 typical 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 228 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 

138,000 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, Subpart 

MMMM) (Renewal).

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

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical 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. In this 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 228 hours per response. Burden means the total time, effort, or financial 

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

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

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

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

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

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

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

the information.

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

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

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

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

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2014-0090. An electronic version of the public docket is 

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

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

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

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

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

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), 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 is (202) 566-1752. 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 EPA Docket ID 

Number EPA-HQ-OECA-2014-0090 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 

personhours per 

year

(E=CxD)

(F)

Management 

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 c24 12 288 11 3168 158.4 316.8 $366,365 

7. Semiannual Reports d8 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 e4 2 8 4,992 39,936 1,996.8 3,993.6 $4,618,419 

9. Store/File information e4 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 91,853 $9,236,837 

TOTAL ANNUAL BURDEN AND COST (rounded) 2,280,000 $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

Assumptions:

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 increased 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 comments 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 

personhours per 

year

(E=CxD)

(F)

Management 

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 c12 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. 

Assumptions: 

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 Management (OPM), 2014 General Schedule, which excludes locality 

rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. 

c

 We have assumed that each respondent will take 12 hours twice a year to 

complete semiannual report.