SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Metal Furniture Surface Coating (40 CFR Part 63, Subpart RRRR) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Metal Furniture Surface Coating (40 CFR Part 63, Subpart RRRR) (Renewal), 

EPA ICR Number 1952.05, OMB Control Number 2060-0518. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Metal 

Furniture Surface Coating (40 CFR Part 63, Subpart RRRR) were proposed on April 24, 2002, 

and promulgated on May 23, 2003. These regulations apply to existing facilities and new

facilities that perform metal furniture surface coating operations where the total Hazardous Air 

Pollutants (HAPs) emitted are greater than or equal to 10 tons per year of any one HAP; or where 

the total HAPs emitted are greater than or equal to 25 tons per year of any combination of HAPs. 

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 

RRRR.

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).

Over the next three years, an average of 583 respondents per year will be subject to the 

standard, with no additional respondents per year becoming subject to the standard. 

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

without any Terms of Clearance. 
2

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

Burden and Cost – NESHAP for Metal Furniture Surface Coating (40 CFR Part 63, Subpart 

RRRR) (Renewal). The burden to the “Federal Government” is attributed entirely to work 

performed by federal employees or government contractors, and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Metal Furniture Surface Coating (40 CFR 

Part 63, Subpart RRRR) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the 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, HAP emissions from metal furniture surface coating 

facilities 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 RRRR.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

the applicable regulations which where promulgated in accordance with the Clean Air Act. 

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

proceedings.

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. 
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, that leaks are being detected and repaired, and that 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

RRRR.

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, 

there is no duplication.

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 (77 FR 47631) on August 9, 2012. 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 EPA's Office of Compliance. OTIS is EPA’s database for 

the collection, maintenance, and retrieval of all compliance data. The growth rate for the 

industry is based on our consultations with the Agency’s internal industry experts. 

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 contacted both the American Home Furnishing Alliance, at (336) 884-5000, and the 

American Coatings Association, at (202) 719-3689. 
4

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 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.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities that 

perform metal furniture surface coating. The United States Standard Industrial Classification

(SIC) codes, which correspond to the North American Industry Classification System (NAICS) 

codes, are listed below for this source category. 

Standard (40 CFR Part 63, Subpart RRRR) SIC Codes NAICS Codes

Metal household furniture manufacturing 2514 337124

Office furniture (except wood) manufacturing 2522 337214

Institutional furniture manufacturing 2531, 2599, 3999 337127

Showcase, partition, shelving, and locker 

manufacturing

2542, 3499, 3429 337215

Metal stamping 3469 332116

Spring (light gauge) manufacturing 3495 332612

Residential electric lighting fixture manufacturing 3645 335121

Commercial, industrial, and institutional electric 

lighting fixture manufacturing

3646 335122

Laboratory apparatus and furniture manufacturing 3821, 3841 339111

Reupholstery and furniture repair 7641 81142

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Metal 

Furniture Surface Coating (40 CFR Part 63, Subpart RRRR). 

A source must make the following reports:
6

Notifications

Initial notification 63.4910(b), 63.9(b)

Notification of compliance status 63.4910(c), 63.9(h)

Notification of construction or reconstruction 63.5

Notification of actual startup 63.9(b)

Notification of performance test 63.7(b)

Reports

Semiannual report 63.4920(a)

Excess emissions report 63.4920(a)(4-7)

Report of performance test 63.4920(b)

Startup, shutdown, malfunction report 63.4920(c)

A source must keep the following records:

Recordkeeping

Five year retention of records 63.4930(b), 63.10(b)

Material formulation data 63.4930(b)

Records of HAP content calculations 63.4930(c)

Copies of notifications and reports 63.4930(a)

Records of names of materials used 63.4930(d)

HAP fractions in each material used 63.4930(e)

Coating solids fraction in each material used 63.4930(f)

Density of materials used 63.4930(g)

Documentation of waste material shipped offsite 63.4930(h)

Start-up, shutdown, and malfunction plan/records 63.4930(k), 63.6(e)

Documentation of control device performance tests 63.4930(k), 63.10(b)

Values measured by continuous monitoring systems 63.4930(k)

Monitoring system calibrations, maintenance 63.4930(k)

Periods of monitoring system failure/shutdown 63.4930(j), 63.4930(k)

Work practice plan and implementation 63.4930(k)

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 
7

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting. 

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for temperature, for gas flow, or for pressure 

drop for oxidizer, carbon adsorber, condenser, concentrator, or capture system.

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, 311, or ASTM Method D1475-90, 

D2697–86, D6093-97 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.

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

Observe initial performance tests and repeat performance tests if necessary.

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

reports, required to be submitted by industry.

Audit facility records.
8

Agency Activities

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 

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. According to the Background Information for the NESHAP 

for Metal Furniture Surface Coating1, 42 percent of the parent companies affected by proposed 

action were estimated to be small entities as defined by the Small Business Administration. The 

Agency assumes that 42 percent of the 583 facilities affected by this ICR, or 245 facilities, are 

small entities.

5(d) Collection Schedule

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

 

1 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Category: Metal Furniture 

Surface Coating – Background Information for Proposed Standards, U.S. EPA, October 2001, EPA-453/R-01-010
9

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Metal Furniture 

Surface Coating (40 CFR Part 63, Subpart RRRR) (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. 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 190,408 (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 $121.44 ($57.83 + 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “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(s) and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
10

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)

CEM $16,000 0 $0 $1,200 583 $699,600

There are no capital/startup costs for this ICR. This is the total of column D in the above 

table. 

The total operation and maintenance (O&M) costs for this ICR are $699,600. 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 $699,600. These are the 

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 

$1,251,472. 

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), 2012 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 Metal 

Furniture Surface Coating (40 CFR Part 63, Subpart RRRR) (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

583 existing respondents will be subject to the standard. It is estimated that no additional 
11

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below, is 583 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 0 583 0 0 583

2 0 583 0 0 583

3 0 583 0 0 583

Average 0 583 0 0 583

1

New respondents 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 583. 

The total number of annual responses per year is calculated using the following table: 
12

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 compliance status 0 1 0 0

Notification of 

construction/reconstruction 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of performance test 0 1.2 0 0

Report of performance test 0 1.2 0 0

Semiannual report 583 2 0 1,166

Excess emissions report 583 0.5 0 291.5

Startup, shutdown, malfunction report 583 0.5 0 291.5

Total 1,749

The number of Total Annual Responses is 1,749.

The total annual labor costs are $21,773,132. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Metal Furniture 

Surface Coating (40 CFR Part 63, Subpart RRRR) (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 190,408 at a cost of $21,773,132. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost –

NESHAP for Metal Furniture Surface Coating (40 CFR Part 63, Subpart RRRR) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 109 hours (rounded) per response.

The total annual capital/startup and O&M costs to the regulated entity are $699,600. 

These 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 

21,454 labor hours at a cost of $1,251,472. See below in Table 2: Average Annual EPA Burden 
13

and Cost – NESHAP for Metal Furniture Surface Coating (40 CFR Part 63, Subpart RRRR) 

(Renewal).

6(f) Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the previous ICR. This is 

due to two considerations. First, the regulations have not changed over the past three years and 

are not anticipated to change over the next three years. Secondly, the growth rate for the 

industry is very low, negative or non-existent, so there is no significant change in the overall 

burden. However, there is an increase in cost per labor hours due to the updated labor rates. 

This ICR uses the most recently available labor rates in all burden calculations. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 109 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-2012-0518. 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 
14

Number EPA-HQ-OECA-2012-0518 and OMB Control Number 2060-0518 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 Metal Furniture Surface Coating (40 CFR Part 63, Subpart

RRRR) (Renewal)

Burden Item

(A) 

Person-hours 

per 

occurrence

(B)

Number of 

occurrences 

per year

(C)

Person-hrs. 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E)

Technical 

person-hrs. 

per year 

(E=CxD)

(F) 

Management 

person-hrs. 

per year 

(F=Ex0.05)

(G)

Clerical 

person-hrs. 

per year 

(G=Ex0.1)

(H)

Annual costs 

($)b

1. Reporting requirements

a. Read rule and instructions 4 1 4 583 2,332 116.6 233.2 $306,664 

b. Process/review information 4 4 16 583 9,328 466.4 932.8 $1,226,655 

c. Write reports

i. Initial notification 2 1 2 0 0 0 0 $0 

ii. Notification of compliance status 2 1 2 0 0 0 0 $0 

iii. Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 

iv. Notification of actual startup 2 1 2 0 0 0 0 $0 

v. Notification of performance test 2 1.2 2.4 0 0 0 0 $0 

vi. Report of performance test 10 1.2 12 0 0 0 0 $0 

vii. Semiannual report c6 2 12 583 6,996 349.8 699.6 $919,991 

viii. Excess emissions report d4 0.5 2 583 1,166 58.3 116.6 $153,332 

ix. Startup, shutdown, malfunction (SSM) report d4 0.5 2 583 1,166 58.3 116.6 $153,332 

Subtotal Reporting 24,136.2 $2,759,974 

2. Recordkeeping requirements

a. Read rule and instructions 4 1 4 583 2,332 116.6 233.2 $306,664 

b. Plan activities 12 1 12 583 6,996 349.8 699.6 $919,991 

c. Implement activities 12 1 12 583 6,996 349.8 699.6 $919,991 

d. Maintain record system for material used 20 1 20 583 11,660 583 1,166 $1,533,319 

e. Time to enter information

i. Material usage e0.5 260 130 583 75,790 3,789.5 7,579 $9,966,574 

ii. Compliance calculation f2 12 24 583 13,992 699.6 1,399.2 $1,839,983 

f. Time to train personnel 10 1 10 583 5,830 291.5 583 $766,660 

g. Store, file, and maintain records f2 12 24 583 13,992 699.6 1,399.2 $1,839,983 

h. Retrieve records/reports f1 12 12 583 6,996 349.8 699.6 $919,991 

Subtotal Recordkeeping 166,271.6 $19,013,157 
16

TOTAL LABOR BURDEN AND COST (rounded)

190,407.8

190,408 (rounded) $21,773,132 

Assumptions:

a

 We have assumed that there are approximately 583 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

b This ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 ”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 have assumed that each respondent will take six hours twice per year to complete the semiannual report.

d

 We have assumed that each respondent will take four hours twice per year to complete the excess emissions reports and also four hours twice per year for the SSM reports.

e

 We have assumed that each respondent will take 0.5 hours 260 times per year to enter information.

f

 We have assumed that each respondent will have to complete task once per month.
17

 Table 2: Average Annual EPA Burden and Cost – NESHAP for Metal Furniture Surface Coating (40 CFR Part 63, Subpart

 RRRR) (Renewal)

Burden Item (A) (B) (C) (D) (E) (F)

Person-hours 

per activity

Number of 

activities per 

year

Technical 

person-hours per 

year (C=AxB)

Management 

person-hours per 

year (D=Cx0.05)

Clerical 

person-hours 

per year 

(E=Cx0.1)

Annual costs 

($/yr)a

1. Initial performance test 24 0 0 0 0 $0 

2. Repeat performance test 24 0 0 0 0 $0 

3. Report review

 a) Initial notification 8 0 0 0 0 $0 

 b) Notification of performance test 8 0 0 0 0 $0 

 c) Notification of compliance status 8 0 0 0 0 $0 

 d) Notification of construction/reconstruction 8 0 0 0 0 $0 

 e) Notification of actual startup 8 0 0 0 0 $0 

 f) Notification of performance test 8 0 0 0 0 $0 

 g) Report of performance test 8 0 0 0 0 $0 

 h) Semiannual report b12 1,166 13,992 699.6 1399.2 $938,604 

i) Excess emissions report 8 291.5 2,332 116.6 233.2 $156,434 

 j) Startup, shutdown, malfunction report 8 291.5 2,332 116.6 233.2 $156,434 

TOTAL LABOR BURDEN AND COSTS (rounded) 21,454 $1,251,472 

Assumptions:

a

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.57 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) “2012 General Schedule” which excludes locality rates of pay.

b

 The semiannual report would have to be completed twice per year.