**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for**  **Miscellaneous Metal Parts and Products (40 CFR**  **Pa rt**  **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 IC R Number 2056 .04 , 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 ( 40 CFR part 63, subpart MMMM ) were proposed on August 13, 2002 , and promulgated on January 2, 2004 . These regulations apply to new, reconstru cted, and existing 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/operator s 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 s ys tem 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 4,992 respondents per ye ar will be subject to the standard, and no additional respondents per year will become subject to the standard. 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)

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

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

.2

The Office of Management and Budget ( OMB ) approved the current Information Collection Agency

(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. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintai n 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, duri ng 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 certification s 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 was promulgated f

or 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 s 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. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. 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.3

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 che ck if the pollution control devices are properl y installed and operated, leaks are being detected and repaired, and the standard is 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 b y 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** T he 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 the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agen cy ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR, we consulted with : 1) the National Electrical Manufacturers Association (NEMA) , at (703) 841

- 3245 ; 2) Superior Essex , at (770) 657

- 6000 ; and 3) MWS Wire Industries , at **(** 818) 991

- 8553

. In response to comments from NEMA, EPA corrected errors in the per - occurrence4

labor hour burden for the magnet wire industry (see Table 1 below ) . EPA also updated the respondent universe to reflect 11 magnet wire facilities, 8 of which are active members of the NEMA Magnet Wire Section Environmental Health and Safety ( EHS ) Committee. It is our policy

to respond after a thorough review o f comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facili ties 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. I f 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 no t 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 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 fiv e ye ars 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 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 acco rding to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 F R 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested**5

**4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are owners or operators of facilities that perform surface coating of miscellaneous metal parts and products . The United States Standard Industrial Classification (SI C ) codes for the respondents affected by the standards , and the corresponding North American Industry Classification Sy stem (NAICS ) codes are listed in the following table.
**Standard ( 40 CFR**  **P art 63,**  **S ubpart** 

**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 Components 3448 332311 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, 3369, 331316, 336991,6 3714, 3716, 375X, 3792 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 L isted 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 P art 63, S ubpart MMMM). A source must make the following reports: **Notification Reports** 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) Periodic reports (semiannual) 63.3920(a) Statement of compliance (if no exceedances occurred) 63.3920(a) 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, malfunction 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)7 **Recordkeeping** 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 recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 2 0 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. 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 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 maintaining information.8 **Respondent Activities** 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. 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 ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA cond

ucts 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 discern a source’s initial capability to compl y 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 formation 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 and9

government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agenci es, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve 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 Flexibili ty**  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 requirements are the same for both small and large entities. The Agency considers these to be the minimum require ments 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 sp ecific 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)

. **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. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 2,254,948 (Total Labor Hours from Table 1 below) . T hese 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**10
**(i) Estimating Labor Costs** This I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased 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 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. The capital/startup costs are one

- tim e costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O& M) Costs**  **Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) 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 1 1 $55 0,000

CPMS

– other facilities **1** $0 0 $0 $5,000 100 $500,000

Total $0 $1,05 0,000 **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 $1,05 0,000. This is11

the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the IC R is estimated to be $1,05 0,000

. These are recordkeeping costs. **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 en forcement 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 $ 6,20 8 , 990

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 General Schedule , which exclude s locality rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees
. D etails upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for 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 standard. It is estimated that no additional respondents per ye ar will become subject. The overall averag e number of respondents, as shown in the table below , i s 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**12 **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 respondent include sources with constructed, reconstructed and modified 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:
**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 9,98 4 Total 9,98 4 The number of Total Annual Responses is 9,98 4

. The total annual labor costs are $2 16,067,118

. 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)

.13

**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 2,254,948 at a cost of $216,067,118

. 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)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 226 hours per response

. The total annual capital/startup and O& M costs to the regulated entity are $1,05 0,000

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

**(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 137,779 labor hours at a cost of $6,208,990

. See below Table 2: Average Annual EPA Burden and Cost

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

. **6(f) Reasons for Change in Burden** There is an adjustment decrease in the labor hours for the respondent as compared to the most recentl y approved ICR. This decrease is not due to any program changes. The decrease reflects a co rrection in the “person

- hours per occurrence” estimate for magnet wire facilities in Table 1 based on comments received from industry consultation. The per - person burden hour es timate for line items “5.1 Gather information and monitor” and “6.1 Process/co mpile and review” in the previous ICR were incorrectl y based on burden estimates for the entire industry sector rather than a single magnet wire facility , and therefore were inflated by a factor of ten. There is an increase in the total O&M costs in this IC R as compared to the previous I CR. This change reflects an update in the respondent universe for the magnet wire industry . Based on comments received from consultation, EPA updated the number of magnet wire facilities from 10 to 11 to more accuratel y reflect the potential respondent universe. In addition, there is an increase in burden costs to both the respondent and the Agency due to an adjustment in labor rates. This I CR uses the most recent labor rates from the Bureau of Labor Statistics in calculating the labor costs.14

**6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 226 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 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. 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 t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0254. 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 sy stem , select “search,” then key in the docket ID number identified in this document. The documents are al so available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. 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

- 2011

- 0254 and OMB Control Number 2060

- 0486 in any correspondence. **Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.15

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

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

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

No. of occurrences per respondent per year (C)

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

Respondents per year a (E)

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

Management person hours per year (Ex0.05) (G)

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

Cost, $ b

1. Read r

ule and i nstructions 4 1 4 0 0 0 0 $0 2. Plan a ctivities 8 1 8 0 0 0 0 $0 3. Training 8 1 8 0 0 0 0 $0 4. Create, t est, and r esearch and d evelopment 0 1 0 0 0 0 0 $0 5. Gather i nformation and m onitor 18 12 216 4,981 1,075,896 53,794.8 107,589.6 $118,555,132.0 0 5.1 Gather i nformation and mo nitor

- Magnet wire facilities c 36 12 432 11 4,752 237.6 475.2 $523,632.38 6. Process/Compile and Review 12 12 144 4,981 717,264 35,863.2 71,726.4 $79,036,754.6 8 6.1 Process/Compile and Review

- Magnet wire f

acilities **c** 24 12 288 11 3,168 158.4 316.8 $349,088.26 7. Semiannual Reports d 8 2 16 4,992 79,872 3,993.6 7,987.2 $8,801,255.42 **Subtotal for**  **Reporting Requirements**  **2,163,09 4.8**  **Recordkeeping requirements** 8. Record/d isclose information e 4 2 8 4,992 39,936 1,996.8 3,993.6 $4,400,627.7 2 9. Store/File information e 4 2 8 4,992 39,936 1,996.8 3,993.6 $4,400,627.7 2 10. LDAR r eporting and r ecordkeeping 0 0 0 0 0 0 0 $0 **Subtotal for R**  **ecordkeeping R**  **equirements 91,85**  **2.8** 1,960,8 24 98,041.2 196,082.4 **TOTAL LABOR BURDEN AND COST (rounded)**  **2,254,948 $**  **216,067,118**16

**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 r ates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, Septemb er, 20 11 “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 p ercent 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 comme nts 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.17

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

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

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

No. of occurrences per respondent per year (C)

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

Respondents per year a (E)

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

Management person hours per year (Ex0.05) (G)

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

Cost, $ 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 0 0 a) I nitial n otification 8 0 0 0 0 0 0 0 b) Notification of p erformance t est N/A 0 0 0 0 0 0 0 c) Notification of c om

pliance s tatus 12 0 0 0 0 0 0 0 d) Semiannual r eport c 12 2 24 4,992 119,808 5,990.4 11,980.8 $6,208,989.70 **Total Burden Hours and Costs 119,808**  **5,990.4 11,980.8**  **$6,208,989.70**
**T OTAL**  **A NNUAL**  **B URDEN**  **and C OSTS**  **(rounded) 137,779**  **$6,208,990**
**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 which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS

- 13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 Clerical (GS

- 6, Step 3, $1 5.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.
c We have assumed that each respondent will take 12 hours twice a year to complete semiannual report

.