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 2056.04, 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, 

reconstructed, 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/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.

Over the next three years, an average of 4,992 respondents per year 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). The burden to the “Federal Government” is attributed entirely to 

work performed by either Federal 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 Miscellaneous 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. 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 was 

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 ensures 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 check if the pollution control devices are properly 

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 directly to the 

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

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

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

can be sent to the Administrator in lieu of the report required by the Federal standards. 

Therefore, no duplication exists.

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

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

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

burden published in the Federal Register. 

3(c) Consultations

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

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is 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 Agency’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 ICR, 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-occurrence 
4

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 of 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 

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 the 

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

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

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

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

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

nonexistence of essential records.

3(f) Confidentiality

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

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

subpart B - Confidentiality of Business Information (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
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 (SIC) codes 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 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 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:

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 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)
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 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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 20 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 

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.
8

Respondent Activities

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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping.

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

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source 

to determine whether the pollution control devices are properly installed and operated. 

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

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

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

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

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 
9

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

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

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

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

years.

5(c) Small Entity Flexibility

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).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

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

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

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

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

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 2,254,948 (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
10

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

September 2011, “Table 2. Civilian Workers, by occupational and industry group.” The rates are 

from column 1, “Total compensation.” The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance 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

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 
11

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 

recordkeeping costs. 

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 

$6,208,990. 

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

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

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011 General Schedule,

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

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

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

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 the standard. 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
12

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 respondent include sources with constructed, reconstructed and modified 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: 

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 $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).
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), respectively, 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 $1,050,000. 

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

Maintenance (O&M) Costs.

(ii) The Agency Tally

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 recently approved ICR. This decrease is not due to any program changes. The decrease 

reflects a correction 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 

estimate for line items “5.1 Gather information and monitor” and “6.1 Process/compile and 

review” in the previous ICR were incorrectly 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 ICR as compared to the previous ICR. 

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 accurately 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 ICR uses the most recent labor rates from the Bureau of 

Labor Statistics in calculating the labor costs.
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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 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-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 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), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the 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-2011-0254 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.
15

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

(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) 

Cost, $ b

1. Read rule and instructions 4 1 4 0 0 0 0 $0

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 $118,555,132.00

5.1 Gather information and monitor

 - 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 $79,036,754.68

6.1 Process/Compile and Review

 - Magnet wire facilities c 24 12 288 11 3,168 158.4 316.8 $349,088.26

7. Semiannual Reports d8 2 16 4,992 79,872 3,993.6 7,987.2 $8,801,255.42

Subtotal for Reporting Requirements 2,163,094.8

Recordkeeping requirements

8. Record/disclose information e4 2 8 4,992 39,936 1,996.8 3,993.6 $4,400,627.72

9. Store/File information e4 2 8 4,992 39,936 1,996.8 3,993.6 $4,400,627.72

10. LDAR reporting and recordkeeping 0 0 0 0 0 0 0 $0

Subtotal for Recordkeeping Requirements 91,852.8

1,960,824 98,041.2 196,082.4

TOTAL LABOR BURDEN AND COST 

(rounded) 2,254,948 $216,067,118
16

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: $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, 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.
17

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

(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)

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) 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 $6,208,989.70

Total Burden Hours and Costs 119,808 5,990.4 11,980.8 $6,208,989.70

TOTAL ANNUAL BURDEN and COSTS (rounded) 137,779 $6,208,990

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 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, $15.63 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.