**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for**  **Surface Coating of Large Appliances (40 CFR**  **Part 60,**  **Subpart SS)**  **(Renewal )**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  N S P S for Surface Coating of Large Appliances (40 CFR Part 6 0 , Subpart S S ) (Renewal), EPA I CR Number 0659.12 , OMB Control Number 2060

- 0108 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Surface Coating of Large Appliances were proposed on December 24, 1980 , and promulgated on October 27, 1982

. These regulations appl y to existing and new large appliance coating facilities . New facilities include those that commenced construction, modific ation or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart SS

. In general, all NSPS standards require initial notifications, performance tests, and periodic reports by

the own ers/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 an y 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 NSPS

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurem ents, and retain the file for at least two 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 72 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the standard. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any

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

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (Renewal). The “Federal Government” burden is attributed entirel y to work performed b y either F ederal emplo ye es or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (Renewal).2

**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 111 o f the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achiev ing such emissions reduction, or any non - air quality

health and environmental impact and energy requirements) the Administrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every

four ye ars. In addition, section 114(a) states that the A dministrator 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 variab les or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, volatile organic compound (VOC) e missions from surface coating operations cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS w as promulgated for this source cat egory at 40 CFR part 60, subpart SS

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard(s) 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.3

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

with the emission standards. Continuous emission monitors are used to ensure compliance with the standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standards 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 de vices are properl y installed and operated, leaks are being detected and repaired , and the standards are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify prob lems 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 60, subpart SS

. **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 age ncy has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication doe s not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (77 FR 47631) on August 9, 2012. No comments were received on the burde n 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. OT IS 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.4

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR, we contacted : 1) the Lennox Manufacturing, Incorporated , at (515) 754

- 436; and 2) the Sherwin

- Williams C ompany , at (216) 566

- 3316

. 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) Ef fects 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detec ting violations would be less likely

. **3(e) General Guidelines**
T hese 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

- 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 five ye ars allows EPA to establish the compliance history of a source, an y 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) Confid entiality**  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**
T he reporting or recordkeeping requirements in the standard do not include sensiti ve5

questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are facilities that conduct surface coating of large appliances

. The United States Standard Indu strial Classification (SI C ) code for the respondents affected b y the standard and the corresponding North American Industry Classification Sy stem (NAICS ) codes are presented in the following table.
**Standard ( 40 CFR**  **P art 60,**  **S ubpart SS**  **) SIC Codes**  **NAICS Codes**  Household Cooking Equipment 3631 335221 Household Refrigerators and Home and Farm Freezers 3632 335222 Household Laundry

Equipment 3633 335224 Household Appliances, Not Elsewhere Classified 3639 335212, 333298, 335228 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y NSPS for Surface Coating of Large Appliances (40 CFR P art 60, S ubpart SS)

. A source must make the following reports:

**Notification s**  **/Reports** Notification of construction/reconstruction 60.7(a)(1) Notification of initial performance test 60.8(d) Initial performance test results 60.8(a), 60.455(a) Notification of actual startup 60.7(a)(3) Demonstration of continuous monitoring sy stem 60.7(a)(5) Notification of a ph ys ical or operational change. 60.7(a)(4) Semiannual report 60.7(d) Excess emissions report 60.7(c), 60.455(b

- c ),6

A source must keep the following records: **Recordkeeping** Startups, shutdowns, malfunction , periods where the continuous monitoring sy stem is inoperative. 60.7(b) Records are required to be retained for two ye ars at the facility

. 60.455(d) Maintain a file of all measurements including the monitoring device, performance testing measurements, and monitoring device calibrations, checks, adjustments and maintenance performed on these devices . Monthl y performance test. 60.7(e), 60.453(a), 60.7(d)

Maintain daily

records of incinerator combustion temperature, or amounts of solvent recovered. 60.454(a)(3), 60.455(d)

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 10 percent of the respon dents 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 control device. Perform initial performance test, Reference Method 24 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 inform ation.7 **Respondent Activities** Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. 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 type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Act ivities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, 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. 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 p roperl 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.8

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 and government

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

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. According to the promulgated rule notice in the Federal Register (47 FR 47779) on October 27, 1982, industry growth is expected to be confined to major manufacturers; the acquisition trend is al so expected to continue as small manufacturers, unable to compete with mass producers, become prime candidates for acquisition. Based on this predicted trend, EPA assumes there is not likely that a significant number of small businesses who are currently subject to this 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 th ese 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

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (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. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are ma ndatory

. 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**9

The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 7,659 hours ( 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 NSPS program, the previously

approved ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 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 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**
T he ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. Th e capital/startup costs are one

- t ime 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 photocop ying 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 1 (G)

Total O&M, (E X F)

Tem perature 8,000 0 $0 $2,100 4 $8,400

1 Five percent of facilities use incineration The total capital/startup costs for this I CR are $0. This is the total o f column D in the above table.10

The total operation and maintenance (O&M) costs for this I CR are $8,400. This is the total of column G. The average annual cost for both capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 8,400

. These are recordkeeping costs

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

are those costs associat ed with anal ys is 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 $ 29,85 1

. 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% ) Techni cal $ 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) , 2012 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 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

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart S S) (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 72 existing respondents will be subject to the standard. It is estimated that no ad ditional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 72 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.11 **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 72 0 0 72
2 0 72 0 0 72 3 0 72 0 0 72 Average 0 72 0 0 72 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 72

. 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

Notification of construction/ reconstruction 0 1 0 0 Notification of performance test 0 1.2 0 0 Notification of actual startup 0 1 0 0 Report of performance test 0 1.2 0 0 Semiannual report 72 2 0 144 Temperature variance report 72 2 0 144
Total 288 The number of Total Annual Responses is 288

. The total annual labor costs are $741,611

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

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (Renewal)

.12

**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, respectivel y, and summarized below.

**(i) Respondent Tally** The total annual labor hours are 7,659 at a cost of $741,611

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 27 hours per response

. The total annual ca

pital/startup and O&M costs to the regulated entity are $8,400

. 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 662 labor hours at a cost of $29,851 . See below Table 2: Average Annual EPA Burden and Cost

– NSPS for Surface Coating of Large Appliances (40 CFR Part 60, Subpart SS) ( Ren ewal)

. **6(f) Reasons for Change in Burden** There is no change in the labor hours in this I CR compared to the previous ICR. This is due to two considerations : 1) the regulations have not changed over the past three years and are not anticipated to change over the next three ye ars ; and 2) 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 adjustment increase in burden costs for both the respondents and the Agency . The cost increase is due to an adjustment in labor rates. This ICR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs. Additionally , there is an increase in the total number of annual responses due to a mathematical correction in the previous ICR. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 27 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instru ctions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and13

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 this I CR under Docket ID Number EPA

–HQ

–OECA

–2012

–0531. 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, acces s 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 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 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

–2012

–0531 and OMB Control Number 2060

- 0108 in any correspondence.
**P art B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.14

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

**– NSPS for Surface Coating of Large Applianc**  **es (40 CFR Part 60, Subpart SS) (Renewal)** 

Burden Items (A) Person hours per Occurrence (B)

Occurrences per respondent per year (C)

Person H ours per respondent per year (C=AxB) (D)

Respondents per year a (E)

Technical Person Hours (E=CxD) (F)

Managerial Person Hours (Ex0.05) (G)

Clerical Person Hours (Ex0.1 ) (H)

Total Costs/Year b

1 A pplications 2 Survey and st

udies 3 Reporting Requirements a. Read i nstructions 1 1 1 0 0 0 0 $0 b. Required a ctivities Initial p erformance t ests 60 1 60 0 0 0 0 $0 Repeat of p erformance t ests 60 0.2 12 0 0 0 0 $0 c. Gather e xisting i nformation Included in 3b d. Write Report Notification of c onstruction/ r econstruction 2 1 2 0 0 0 0 $0 Notification of i nitial p erformance t est 2 1 2 0 0 0 0 $0 Notification of a ctual s t artup 2 1 2 0 0 0 0 $0 Report of p erformance t est Included in 3b Semiannual r eport c 5 2 10 72 720 36 72 $80,174.16 Tem perature v ariance r eport d 4 2 8 72 576 28.8 57.6 $64,139.33 **Subtotal for Reporting Requirements 1,490**  **.4 $144,313.49**  4 Recordkeeping Requirements
a. Read i nstructions Included in 3a b. Plan a ctivities Included in 3b
c. Im plement a ctivities ( monthly p erformance t est) e 1 12 12 72 864 43.2 86.4 $96,208.99 d. Develop r ecord s ys tem15

Burden Items (A) Person hours per Occurrence (B)

Occurrences per respondent per year (C)

Person H ours per respondent per year (C=AxB) (D)

Respondents per year a (E)

Technical Person Hours (E=CxD) (F)

Managerial Person Hours (Ex0.05) (G)

Clerical Person Hours (Ex0.1 ) (H)

Total Costs/Year b

Records of o perating p arameter f 0.25 250 62.5 72 4,500 225 450 $501,088.50 **Subtotal for Recordkeeping Requirements 6,16**  **8.6 $597,297.49**  **TOTAL LABOR BURDEN AND COST (rounded)**  **7,659 $741,611** 

**Assu mptions:** 
a We have assumed that there are approximately 72 existing sources currently subject to this rule. There will be no additional new sources that will become subject to the rule over the three

- year period of this ICR

. 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. T hese rates are from the United States Department of Labor, Bur eau of L abor Statistics, March 2012, Table 2. Civilian Workers, by occupational and industry group. Th e rates are from column 1, “T otal compensation.” Th e rates have been increas ed by 1 10 percent to account for the benefit packages available to those emp loyed by private industry.
c We have assumed that each respondent will take 5 hours twice per year to w rite the semiannual report. d We have assumed that each respondent will take 4 hours twice per year to w rite the temperature variance report.
e We hav e assumed that each respondent will take one hour once per month to record monthly performance tests. f We have assumed that each respondent will take 0.25 hours 250 times per year to record operating parameter.16

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

**– NSPS**  **for Surface**  **Coating of**  **Large Appliances**  **(40 CFR**  **Part 60,**  **Subpart SS) (Renewal)** 

Activity (A) EPA person h ours per o ccurrence (B)

No. of Occurrences per p lant per year (C)

EPA person - hours per plant (C=A*B) (D)

Plants Per year a (E)

Technical p erson h ours per year ( E =CxD) (F)

Managerial p erson h ours per year (Ex0.05) (G)

Clerical p erson h ours per year (Ex0.1) (H)

Total Costs/Year b

I nitial P erformance T est New Plant 24 1 24 0 0 0 0 $0 Repeat P erformance T est New Plant 24 0.2 4.8 0 0 0 0 $0 Report Review New Plants Notification of c onstruction 2 1 2 0 0 0 0 $0 Notification of i nitial s tartup 0.5 1 0.5 0 0 0 0 $0 Notification of a ctual s tartup 0.5 1 0.5 0 0 0 0 $0 Notification of i nitial t est 0.5 1.2 0.6 0 0 0 0 $0 Review t est r esults 8 1.2 9.6 0 0 0 0 $0 Existing Plants Semiannual r eports c 2 2 4 72 288 14.4 28.8 $14,925 .46 Tem perature v ariance r eports c 2 2 4 72 288 14.4 28.8 $14,925 .46 SUBTOTAL ANNUAL BURDEN 576 28.8 57.6 **$29,85 1**  **TOTAL ANNUAL BURDEN AND COST 662**  **(rounded)** Assumptions:

a We have assumed that there are approximately 72 existing sources currently subject to this rule. There will be no additional new sources that will become subject to the rule over the three

- year period of this ICR. b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $6 2.57 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. c We have assumed that each respondent will take two hours twice per year to review semiannual reports and temperature variance reports.