SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for the Surface Coating of Large Household and Commercial
Appliances (40 CFR Part 63, Subpart NNNN)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NESHAP for the Surface Coating of Large Household and Commercial
Appliances (40 CFR part 63, subpart NNNN) (Renewal)

	1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for the Surface Coating of Large Household and Commercial Appliances
published at 40 CFR part 63, subpart NNNN were proposed on June 23,
2002, and promulgated on December 22, 2000.  These regulations apply
existing facilities and new facilities that perform surface coating of
large household and commercial appliances and related parts 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 NNNN.

	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 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 90 sources are currently subject to the standard, and it
is estimated that an additional four 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 NNNN.

	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 standard(s).
 Continuous emission monitors are used to ensure compliance with the
standard(s) at all times.

	The notifications required in the standard(s) 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 (and/or) leaks are being detected and
repaired and the standard(s) 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 NNNN.

	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 Office of
Management and Budget (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 90
respondents are currently subject to the regulation, and our
consultations with Agency industry experts regarding the growth rate for
the industry indicated that an additional four respondents per year will
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 NNNN.  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 (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
those that perform surface coating of large household and commercial
appliances and related parts.

Standard	SIC Codes	NAICS Codes

40 CFR part 63, subpart NNNN	3631	335221

	3632	335222

	3633	335224

	3639	335228

	3582	333312

	3585	333415

	3589	333319



	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 NNNN.

	A source must make the following reports:

	Notifications

Initial notification	63.4110(a)(1), 63.9(b)

Notification of compliance status	63.4110(a)(2), 63.4110(b), 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	63.4120

Excess emissions report	63.4120(c),(d),(e),

(f),(g)

Report of performance test	63.4120(h)

Startup, shutdown, malfunction report	63.4120(j)



	A source must keep the following records:

	Recordkeeping

Five year retention of records	63.4131(b), 63.10(b)

Material formulation data	63.4130(b)

Records of HAP content calculations	63.4131(c)

Copies of notifications and reports	63.4131(a)

Records of names of materials used	63.4131(d)

HAP fractions in each material used	63.4131(e)

Coating solids fraction in each material used	63.4131(f)

Density of materials used	63.4131(g)

Documentation of waste material shipped offsite	63.4131(h)

Start-up, shutdown, and malfunction plan/records	63.4131(j),(k),63.6

(e)

Documentation of control device performance tests	63.4131(k),63.10(b)

Values measured by continuous monitoring systems	63.4131(k)

Monitoring system calibrations, maintenance	63.4131(k)

Periods of monitoring system failure/shutdown	63.4131(j),(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, #A, 3B, 4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E,
204F, 311, or ASTM Method D1475-98, 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 AIRS 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 the Surface Coating of Large Household and Commercial
Appliances (40 CFR part 63, subpart NNNN).

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 28,845
(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	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 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 monitor(s) 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	4	$64,000	$1,200	90	$108,000



	The total Capital/Start-up costs for this ICR are $64,000.  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
$108,000.  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 $172,000.  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 $110,772 [see Table 2 in Section (F).]

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

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Annual Respondent Burden
and Cost, National Emission Standards for Hazardous Air Pollutants
(NESHAP) for the Surface Coating of Large Household and Commercial
Appliances (40 CFR part 63, subpart NNNN).

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

	Based on our research for this ICR, there are approximately 82 existing
sources currently subject to the standard.  It is estimated that an
additional four 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	4	82	0	0	86

2	4	86	0	0	90

3	4	90	0	0	94

Average	4	86	0	0	90

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 90.  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	4	1	0	4

Notification of compliance status	4	1	0	4

Notification of construction/reconstruction	4	1	0	4

Notification of actual startup 	4	1	0	4

Notification of performance test 	4	1.2	0	4.8

Report of performance test	4	1.2	0	4.8

Semiannual report 	90	2	0	180

Excess emissions report	90	0.5	0	45

Startup, shutdown, malfunction report	90	.5	0	45



	Total	296 (Rounded)

The number of Total Annual Responses is 296 (rounded).  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 $172,000.  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 97
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 $2,326,984.  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: National
Emission Standards for Hazardous Air Pollutants (NESHAP) for the Surface
Coating of Large Household and Commercial Appliances (40 CFR part 63,
subpart NNNN).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 97 hours per response.

	The total annual capital and O&M costs to the regulated entity are
$172,000.  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 2,732 labor hours at a cost of $110,772.  See Table 2:
Annual Agency Burden and Cost,  National Emission Standards for
Hazardous Air Pollutants (NESHAP) for the Surface Coating of Large
Household and Commercial Appliances (40 CFR part 63, subpart NNNN).

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 NNNN.  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 installation and 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 97 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-2005-0042, 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-2005-0042, and OMB
Control Number 2060-0457 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, National Emission
Standards for Hazardous Air Pollutants (NESHAP) for the Surface Coating
of Large Household and Commercial Appliances (40 CFR part 63, subpart
NNNN) (Renewal)

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 ($)

1.0 Read Rule and Instructions	4	1	4	90	360	18	36	$33,422

2.0 Plan Activities	8	1	8	90	720	36	72	$66,843

3.0 Training	8	1	8	90	720	36	72	$66,843

4.0 Create, Test, and Research and Development	1	0	0	90	0	0	0	0

5.0 Gather Information, Monitor, and Inspect	12	12	144	90	12,960	648
1,296	$1,203,180

6.0 Process/Compile and Review	8	12	96	90	8,640	432	864	$802,120

7.0 Complete Reports	8	2	16	90	1,440	72	144	$133,687

8.0 Record/Disclose	1	2	2	90	180	9	18	$16,711

9.0 Store/File	0.25	2	0.5	90	45	2.25	4.5	$4,178

10.0 LDAR Reporting and Recordkeeping	0	0	0	0	0	0	0	0

Total Burden (Hrs) and Costs

	

	

	  =SUM(ABOVE)  25,065 	1,253.25	2,507.5	$2,326,984

	28,845

	

Table 2:  Annual Agency Burden and Cost, National Emission Standards for
Hazardous Air Pollutants (NESHAP) for the Surface Coating of Large
Household and Commercial Appliances (40 CFR part 63, subpart NNNN)
(Renewal)

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)



1.0 Initial performance and test	

24	

4	

96	4.8	9.6	$4,476



2.0 Repeat performance test	

24	

1	

24	1.2	2.4	$1,119



3.0 Report review 	

	

	





	

  a) Initial notification	

8	

4	

32	1.6	3.2	$1,492



  b) Notif. of performance test	

8	

4	

32	1.6	3.2	$1,492



  c) Notif. of compliance status	

8	

4	

32	1.6	3.2	$1,492



  d) Semiannual report	

12	

180	

2,160	108	216	$100,701



Total Burden (Hrs) and Costs	

	

	

  =SUM(ABOVE)  2,376 	

  =SUM(ABOVE)  118.8 	

  =SUM(ABOVE)  237.6 	

  =SUM(ABOVE)+g2+g3  $110,772 



	

2,732	





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