SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

  SEQ CHAPTER \h \r 1 NESHAP for Metal Furniture Surface Coating (40 CFR
part 63, subpart RRRR)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	  SEQ CHAPTER \h \r 1 NESHAP for Metal Furniture Surface Coating (40
CFR part 63, subpart RRRR) (Renewal)

	1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for Metal Furniture Surface Coating published at 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 the proposal.  This information is
being collected to ensure 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 (SSM)
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 or 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 United States Environmental Protection
Agency (EPA) regional office.

	Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and each plant site
has only one respondent (i.e., the owner/operator of the plant site).

	Approximately 583 sources are currently subject to the standard, and it
is estimated that no additional sources per year will become subject to
the regulation in the next three years.

	OMB approved the currently active ICR without any “Terms of
Clearance.”

	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 or 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 from large household and commercial appliance surface coating
facilities cause or contribute to air pollution that may reasonably be
anticipated to endanger public health or welfare.  Therefore, NESHAP for
this source category were promulgated at 40 CFR Part 63, Subpart RRRR.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard(s) ensure
compliance with the applicable regulations, which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

	Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standards. 
Continuous emission monitors are used to ensure compliance with the
standards at all times.

	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 devices are
properly installed and operated, that leaks are being detected and
repaired, and that 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 problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

	The recordkeeping and reporting requested is required under 40 CFR part
63, subpart RRRR.

	3(a)  Nonduplication

	If the subject standards have not been delegated, the information is
sent 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 their 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 (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	The Agency has taken a number of steps to determine if consultations
are needed to estimate the burden to industry.  Any comments received
since the last ICR renewal including those submitted in response to the
first federal register notice announcing the renewal of this ICR have
been reviewed.  In this case, no comments were received.  The Agency’s
industry experts have been consulted.  The Agency’s internal data
sources and any projections of industry growth over the next three years
have been considered.  Based on this information, we have concluded that
additional consultations would not change our estimate of burden.

	The Agency’s primary source of information as reported by industry is
the AFS (AIRS Facility Subsystem) which is operated and maintained by
EPA's Office of Compliance.  AFS is EPA’s database for the collection,
maintenance, and retrieval of all compliance data.  Approximately 583
respondents are currently subject to the regulation, and our
consultations with Agency industry experts regarding the growth rate for
the industry indicated that no additional respondents per year are
expected to become subject to the regulation over the next three years.

	Estimates of industry size, growth rate, and burden were developed with
extensive participation and consultation with large appliance surface
coating industry representatives during recent rulemaking for 40 CFR
part 63, subpart RRRR.  EPA believes that these estimates remain valid,
and are the best information available.  The Agency currently collects
the minimum amount of information necessary to ensure compliance with
the standard.

	3(d)  Effects of Less Frequent Collection

	Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the required 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 likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

	3(e)  General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

 	These standards require affected facilities to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

	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

	None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested 

	4(a)  Respondents/SIC Codes

	The respondents of the recordkeeping and reporting requirements are
that perform surface coating of large household and commercial
appliances and related parts.  The United States Standard Industrial
Classification (SIC) codes for the respondents affected by the
standards, which corresponds to the North American Industry
Classification System (NAICS) codes, are listed below for source
category descriptions.

Standard	SIC Codes	NAICS Codes

40 CFR Part 63, Subpart RRRR	

2514	

337124

	

2522	

337214

	

2531	

337127

	

2542	

337215

	

2599	

337127

	

3429	

332951

	

3469	

332116

	

3495	

332612

	

3499	

337215

	

3645	

335121

	

3646	

335122

	

3821	

339111

	

3843	

339114

	

3999	

337127

	

7641	

81142



	4(b)  Information Requested

		(i)  Data Items

	All data in this ICR that is recorded and/or reported is required by 40
CFR part 63, subpart RRRR.

	A source must make the following reports:

	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)



Notification 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

	Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., inlet and outlet
concentrations when determining percent efficiency.  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.  In addition, some regulatory agencies are
setting up electronic reporting systems to allow sources to report
electronically which is reducing the reporting burden.  However,
electronic reporting systems are still not widely used by the regulatory
agencies.  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.



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,
excess emissions reports, startup, shutdown, malfunction plan, and
quality control plan for CMS required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).



5(b)  Collection Methodology and Management

	Following notification of startup, the reviewing authority might
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 the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS 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 AFS 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
or 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 requirements the minimum
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 in Table 1: Annual Respondent Burden and Cost,
NESHAP for Metal Furniture Surface Coating (40 CFR part 63, subpart
RRRR).

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).  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	$100.99  ($48.09 + 110%)

Technical	$87.97    ($41.89 + 110%)

Clerical	$43.81    ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 2005, Table 2. Civilian Workers, by
occupational and industry group.  The rates are from column 1, Total
compensation.  The rates have been increased by 110% to account for the
benefit packages available to those employed by private industry.

		(ii)  Estimating Capital and Operations and Maintenance Costs

	This section covers the costs associated with all types of continuous
monitoring equipment [e.g., continuous emissions monitoring systems
(CEMS) and continuous parameter monitors].  The type of industry costs
associated with the information collection activity in the subject
standards 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 monitors and other costs such as
photocopying and postage.

	6(b)  Capital/Startup vs. Operating 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)

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



	The total Capital/Start-up costs for this ICR are zero.  This is the
total of column D in the above table.  These costs are shown on the OMB
83-I form in block 14(a), Total annualized capital/startup costs.

 

	The total Operating and Maintenance (O&M) Costs for this ICR are
$700,000 (rounded).  This is the total of column G.  These costs are
shown on the OMB 83-I form in block 14(b), Total annual costs (O&M).

	The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  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 $700,000 (rounded).  This cost is shown on
the OMB 83-I form in block 14(c), Total annualized cost requested.  The
numbers in block 14 of the OMB 83-I form are rounded to show the cost in
thousands of dollars.  The continuous monitoring costs that are included
in this section consist only of those capital/start-up and O&M costs
that a source incurs as a result of the standard.  Some continuous
monitoring costs may not be included in this section.  For instance, if
a particular industry typically utilizes a control device that must have
a continuous monitor (e.g., temperature, pressure drop, etc.) to
function properly, and the recordation of additional measurements beyond
the minimum are required by the standard, then there is no
capital/startup or O&M cost, but there is a labor cost to record the
additional readings.  Such a cost would not appear in this section, but
in the industry burden Section 6(d) below.

	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 $888,137.

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

		Managerial	$57.20  (GS-13, Step 5, $35.75 x 1.6)

		Technical	$42.45  (GS-12, Step 1, $26.53 x 1.6)

		Clerical	$22.96  (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) 2006
General Schedule which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Annual Respondent Burden
and Cost, NESHAP for Metal Furniture Surface Coating (40 CFR Part 63,
Subpart RRRR).

	6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Based on our research for this ICR, there are approximately 583
existing sources currently subject to the standard.  It is estimated
that no additional sources per year will become subject to the
regulation in the next three years.

	The Number of respondents is calculated using the following table which
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.

	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three year period of
this ICR is 583.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

	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 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.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

Note that the total annual capital and O&M costs to the regulated entity
are $700,000 (rounded).  This number is shown on the OMB 83-I form in
block 14(c), Total annualized cost requested.  These costs are detailed
in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance
(O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents appear below.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 109
hours per response.

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		(i) Respondent Tally

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor costs are $16,126,797.  The annual labor costs
are not shown on the OMB 83-I form.  Details regarding these estimates
may be found in Table 1: Annual Respondent Burden and Cost: NESHAP for
Metal Furniture Surface Coating (40 CFR part 63, subpart RRRR). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 109 hours per
response.

	The total annual capital and O&M costs to the regulated entity are
$700,000 (rounded).  This number is shown on the OMB 83-I form in block
14(c), Total annualized cost requested.  These costs 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 $888,137.  See Table 2:
Annual Agency Burden and Cost, Annual Agency Burden and Cost, NESHAP for
Metal Furniture Surface Coating (40 CFR part 63, subpart RRRR).

6(f)  Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to an
adjustment.  The adjustment increase in burden is due to a transition in
the types of activities undertaken by facilities to comply with 40 CFR
part 63, subpart RRRR.  The previous ICR included only the burden
incurred by facilities initiating activities related to compliance in
advance of the compliance date.  The increase in burden reflects the
need for facilities to fully comply with the rule requirements.  The
increase in O&M costs is due to maintenance of equipment used to verify
compliance with the rule requirements.

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’s 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-2005-0041 which is available for online viewing at 
www.regulations.gov,  or in person viewing at the Enforcement and
Compliance  Docket and  Information Center in the EPA Docket Center
(EPA/DC),  EPA West, Room B102, 1301 Constitution Avenue, 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 Enforcement and Compliance Docket and
Information Center is (202)566-1752.  An electronic version of the
public docket is available through EPA Dockets www.regulations.gov. 
This site can be used to submit or view public comments, access the
index listing of the contents of the public 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 above.  You can also 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 Number:EPA-HQ-OECA-2005-0041, 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.



Table 1:  Annual Respondent Burden and Cost, NESHAP for Metal Furniture
Surface Coating (40 CFR Part 63, Subpart RRRR)

Burden Item	

(A) Person-hours per occurrence	

(B) 

Number of occurrences per year	

(C) Person-hrs. per respondent per year

 (C=A*B)	

(D) Respondents per year 	

(E) Technical person-hrs. per year (E=C*D)	

(F) Management person-hrs. per year 

(F=E*0.05)	

(G) Clerical person-hrs. per year (G=E*0.1)	

(H) 

Annual costs ($)

1. Reporting requirements

	a. Read rule and instructions	4	1	4	583	  =d3*e3  2,332 	116.6	233.2
$227,138

b. Process/review information	4	4	16	583	  =d4*e4  9,328 	466.4	932.8
$908,552

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	6	2	12	583	6,996	349.8	699.6	$681,414

viii. Excess emissions report	4	.5	2	583	1,166	58.3	116.6	$113,569

ix. Startup, shutdown, malfunction report	4	.5	2	583	1,166	58.3	116.6
$113,569

2. Recordkeeping requirements

	a. Read rule and instructions	4	1	4	583	  =d3*e3  2,332 	116.6	233.2
$227,138

b. Plan activities	12	1	12	583	6,996	349.8	699.6	$681,414

c. Implement activities	12	1	12	583	6,996	349.8	699.6	$681,414

d. Maintain record system for material used	20	1	20	583	11,660	583	1,166
$1,135,690

e. Time to enter information

	i. Material usage	0.5	260	130	583	75,790	3,789.5	7,579	$7,381,984

ii. Compliance calculation	2	12	24	583	13,992	699.6	1,399.2	$1,362,828

f. Time to train personnel	10	1	10	583	5,830	291.5	583	$567,845

g. Store, file, and maintain records	2	12	24	583	13,992	699.6	1,399.2
$1,362,828

h. Retrieve records/reports	1	12	12	583	6,996	349.8	699.6	$681,414

Total Burden (Hrs) and Costs

	

	

	165,572	8,279	16,557	$16,126,797

	190,408

	



Table 2:  Annual Agency Burden and Cost, NESHAP for Metal Furniture
Surface Coating (40 CFR Part 63, Subpart RRRR)

Burden Item	

(A)

Person-hours per activity	

(B)

Number of activities per year	

(C)

Technical person-hours per year

(C=A*B)	

(D)

Management person-hours per year

(D=C*0.05)	

(E)

Clerical person-hours per year

(E=C*0.1)	

(F)

Annual costs ($/yr)



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	

12	

1,166	

13,992	699.6	1,399.2	$666,103

i) Excess emissions report	

8	

291.5	2332	116.6	233.2	$111,017

j) Startup, shutdown, malfunction report	

8	

291.5	2332	116.6	233.2	$111,017



Total Burden (Hrs) and Costs	

	

	18,656	932.8	1,865.6	

  =SUM(ABOVE)+g2+g3  $888,137 



	21,454	





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