SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 NSPS for Surface Coating of
Large Appliances (40 CFR Part 60, Subpart SS)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

  SEQ CHAPTER \h \r 1 NSPS for Surface Coating of Large Appliances (40
CFR Part 60, Subpart SS)

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Large Appliance Surface
Coating (40 CFR part 60, subpart SS) were proposed on   SEQ CHAPTER \h
\r 1 December 24, 1980, and promulgated on October 27, 1982.    SEQ
CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 These regulations apply to large
appliance coating facilities commencing construction, modification or
reconstruction after December 24, 1980.  This information is being
collected to assure compliance with 40 CFR part 60, subpart SS.

In general, all NSPS require initial notifications, performance tests,
and periodic reports.  Owners or operators also are 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 sources subject to NSPS.

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
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 directly to the appropriate United States Environmental
Protection Agency (EPA) regional office.

  SEQ CHAPTER \h \r 1 Approximately 72 sources currently are subject to
the regulation, and it is estimated that   SEQ CHAPTER \h \r 1 no
additional sources per year will become subject to the regulation in the
next three years.  These numbers are based on previous experience with
the industry and a search of the Agency’s Air Facility Subsystem (AFS)
database during a previous renewal.

OMB approved the current ICR without any Terms of Clearance.

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost.  The burden to the “Federal Government”
is attributed entirely to work performed by federal employees or
government contractors; this burden may be found in Table 2: Average
Annual EPA Burden.   

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The Clean Air Act (CAA) provides authority to the Agency to establish
standards to control air pollution and to ensure compliance with
promulgated regulations through adequate recordkeeping and reporting by
the affected industries (i.e., respondents).  The regulations include
the New Source Performance Standards (NSPS) under section 111 of the
Act, the National Emission Standards for Hazardous Air Pollutants
(NESHAP), which includes the original NESHAP standards and the more
recent Maximum Achievable Control Technology (MACT), or NESHAP-MACT
standards under section 112 of the Act, and emission guidelines for the
designated types of incinerators under section 129 of the Act.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) are used
by regulatory agencies, the public and the regulated community for a
variety of reasons including the determination of the respondent’s
compliance status, analytical studies to demonstrate compliance trends,
and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting are also used to: 1) certify
compliance with the regulations; 2) determine the respondent’s
compliance with the designated emission limitation(s); 3) notify
regulatory agencies when a standard is violated; 4) evaluate continuous
compliance through the use of emission, or operational parameter
monitors; and 5) ensure that plant personnel are following the required
procedures and are periodically trained, as indicated.

3.  Nonduplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested are required under 40 CFR part
60, subpart SS.

3(a)  Nonduplication

 The standards do not require duplication in the collection and
reporting of information.  If the subject standards have not been
delegated, the information is sent directly to the appropriate
Environmental Protection Agency (EPA) regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.

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 (74 FR 38004) on July 30, 2009. 
No comments were received on the burden published in the Federal
Register.

 3(c)  Consultations

During a previous renewal of this ICR, several consultations were
conducted.  Comments received including those submitted in response to
the first federal register notice announcing the previous renewal of
this ICR were reviewed.  The Agency’s internal industry experts were
consulted.  The Agency’s internal data sources and any projections of
industry growth over the next three years were also considered.

The Agency’s primary source of information as reported by industry, in
compliance with the recordkeeping and reporting provisions in the
standard, is the Air Facility Subsystem (AFS), 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. 
There are currently 72 sources subject to the regulation, and it is
estimated that no additional sources per year will become subject to the
regulation in the next three years, while an equal number will go
off-line during this time period.

It should be noted that the respondents, the 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, and
the standard previously has been reviewed to determine the minimum
information needed for compliance purposes.

3(d)  Effects of Less Frequent Collection

	

The effect of less frequent collection would be a decrease in the margin
of assurance that facilities are achieving the emission reductions
mandated by the CAA through the promulgation of the applicable
regulations.  In addition, the likelihood of detecting the poor
operation and maintenance of control equipment decreases, and the
detection of noncompliance could become problematic.

3(e)  General Guidelines

Neither the reporting, nor recordkeeping requirements violate the
regulations established by the Office of Management and Budget (OMB) at
5 CFR part 1320, section 1320.5.  However, most NESHAP standards and a
few NSPS standards require records to be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the permit
program at 40 CFR part 70, and the five-year statute of limitations on
which the permit program is based.

The retention of records for five years allows EPA to establish the
compliance history of the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. 
If records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance.

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

The recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

  SEQ CHAPTER \h \r 1 The respondents of the record keeping and
reporting requirements are facilities which conduct surface coating of
metal furniture. The United States Standard Industrial Classification
(SIC) and corresponding North American Industry Classification System
(NAICS) codes for the respondents affected by the standards are shown in
the table below.

Regulation	SIC Codes	NAICS Codes

40 CFR part 60, subpart SS	3631	  SEQ CHAPTER \h \r 1 335221

	3632	  SEQ CHAPTER \h \r 1 335222

	3633	  SEQ CHAPTER \h \r 1 335224

	3639	  SEQ CHAPTER \h \r 1 335212, 333298, 335228



4(b)  Information Requested 

Data Items

  SEQ CHAPTER \h \r 1 All data in this ICR that is recorded and/or
reported is required by subpart SS, New Source Performance Standards
(NSPS) for Large Appliance Surface Coating, 40 CFR part 60, subpart SS.

 

A source must make the following reports:

Reports for 40 CFR part 60, subpart SS

Notification of construction/reconstruction 	60.7(a)(1)

Notification of initial performance test	60.8(d)

Initial performance test results	60.8(a),   SEQ CHAPTER \h \r 1
60.455(a)

Notification of actual startup	60.7(a)(3)

Demonstration of continuous monitoring system	60.7(a)(5)

Notification of a physical or operational change.	60.7(a)(4)

Semiannual report	60.7(d)

Excess emissions report	60.7(c),   SEQ CHAPTER \h \r 1 60.455(b),
60.455(c)

	

	A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart SS

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	60.7(b)

Records are required to be retained for two years at the facility.	  SEQ
CHAPTER \h \r 1 60.455(d)

  SEQ CHAPTER \h \r 1 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. Monthly performance test.	60.7(e),   SEQ CHAPTER \h \r 1
60.453(a), 60.7(d)

Maintain daily records of incinerator combustion temperature, or amounts
of solvent recovered.	  SEQ CHAPTER \h \r 1 60.454(a)(3), 60.455(d)



		(ii) Respondent Activities

Respondent Activities

Read instructions.

  SEQ CHAPTER \h \r 1 Install, calibrate, maintain, and operate a device
that continuously records the combustion temperature of any effluent
gases incinerated to achieve compliance.

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 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.

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.

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,
and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS (Aerometric Information
Retrieval System) Facility Subsystem (AFS) database.



5(b)  Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a
partial compliance evaluation, full compliance evaluation or inspection,
or through an off-site review of compliance monitoring records and
reports.  Evaluation reports and inspection results are maintained by
the Agency or delegated authority.

The results of these evaluations are entered into the Air Facility
Subsystem (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 delegated
authorities can retrieve and analyze the data.

5(c)  Small Entity Flexibility

A majority of the affected facilities are large entities (e.g., 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 also
expected to continue as small manufacturers, unable to compete with mass
producers, become prime candidates for acquisition.  Assuming this
predicted trend has continued, it is not likely that a significant
number of small businesses 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 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 below in Table 1: Annual Respondent Burden and
Cost.

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. 
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.

6(a)  Estimating Respondent Burden

The respondent burden is shown in Table 1.  The labor hours in Table 1
are based on Agency studies and background documents from the
development of the regulation, Agency knowledge and experience with the
standard, 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/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection
activity in the regulations are labor and Continuous Emission Monitors
(CEMS).  The capital/startup costs are one-time costs when a facility
becomes subject to the regulation.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitor and other costs such
as photocopying and postage.

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 Costs, 

(B X C)	(E)

Annual O&M Cost for One Respondent	(F)

Number of Respondents with O&M1	(G)

Total O&M Costs,

(E X F)

Temperature	8,000	0	$0	$2,100	4	$8,400

1 Five percent of facilities use incineration

The total capital/startup costs for this ICR is the total of column D.  

The total operation and maintenance (O&M) costs for this ICR is the
total of column G.  

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those 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 and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
shown in Table 2, attached.

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.

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

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	72	0	0	72

2	0	72	0	0	72

3	0	72	0	0	72

Average	0	72	0	0	72

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

To avoid double-counting respondents, column D is subtracted.  The
average Number of Respondents over the three-year period of this ICR is
shown in column D.  

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

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	72

Temperature variance report	72	2	0	72



	Total	144



The number of Total Annual Responses is shown in column E.  

The total annual labor cost may be found in Table 1.

The average annual Agency burden and cost over next three years is shown
in Table 2.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.

6(f)  Reasons for Change in Burden

There is no change in the labor hours to the respondents in this ICR
compared to the previous ICR.  This is due to two considerations. 
First, the regulations have not changed over the past three years and
are not anticipated to change over the next three years.  Secondly, the
growth rate for respondents is very low, negative, or non-existent. 
Therefore, the labor hours in the previous ICR reflect the current
burden to the respondents and are reiterated in this ICR.  There is a
minor change to the cost figures, since the previous ICR rounded to the
nearest $1,000; this ICR presents cost figures which differ by less than
$500 from the previous ICR due to using exact figures instead of
rounding.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 53 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, disclose, or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; to 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; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
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-2009-0529.  An electronic version of the public docket is
available at http://www.regulations.gov which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1927.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA–HQ–OECA–2009-0529 and OMB Control Number 2060-0108 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:  NEW SOURCE PERFORMANCE
STANDARD (NSPS) FOR LARGE APPLIANCE SURFACE COATING (40 CFR part 60,
subpart SS)

	REPORTING/

RECORDKEEPING REQUIREMENT	Hours/

Occurrence

(A)	Occurrences/  Year 

(B)	Hours/Year   (C=AxB)

 (C)	Respondents/

Year

(D)	Technical

Person Hours

(E=CxD)

	Managerial

Person Hours

(Ex0.05)	Clerical Person Hours

(Ex0.10)	Total Costs/Year    

(F)

1.	APPLICATIONS	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

2.	SURVEY AND STUDIES	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

3.	REPORTING REQUIREMENTS









	a.	Read Instructions	1	1	1	0	0	0	0	$0

	b.	Required Activities











	Initial Performance Tests	60	1	60	0	0	0	0	$0



	Repeat of Performance Tests	60	0.2	12	0	0	0	0	$0

	c.	Gather Existing Information

------------------------Included in 3b----------------------------

	d.	Write Report











	Notification of Construction/

Reconstruction	2	1	2	0	0	0	0	$0



	Notification of Initial Performance Test	2	1	2	0	0	0	0	$0



	Notification of Actual Startup	2	1	2	0	0	0	0	$0



	Report of Performance Test

------------------------Included in 3b----------------------------



	Semiannual Report	5	2	10	72	720	36	72	$70,128



	Temperature Variance Report	4	2	8	72	576	29	58	$56,103

	SUBTOTAL REPORTING	Subtotal burden hours = 1,491	$126,231

4.	RECORDKEEPING REQUIREMENTS









	a.	Read Instructions

------------------------Included in 3a----------------------------

	b.	Plan Activities

------------------------Included in 3b----------------------------

	c.	Implement Activities (Monthly Performance Test)	1	12	12	72	864	43	86
$84,154

	d.	Develop Record System	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Records of Operating Parameter	0.25	250	62.5	72	4,500	225	450	$438,302

SUBTOTAL RECORDKEEPING	Subtotal burden hours = 6,168	$522,456

COMBINED ANNUAL BURDEN



	6,660	333	666	$648,687

GRAND TOTAL





7,659







TABLE 2:  AVERAGE ANNUAL EPA BURDEN:  NEW SOURCE PERFORMANCE STANDARD
(NSPS) FOR LARGE APPLIANCE SURFACE COATING (40 CFR part 60, subpart SS)

REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/Occurrence    (A)
Occurrences/Plant/Year    (B)	EPA Hours/  Year (C=A*B)	Plants/Year

(D)	Technical Person Hours

(E=CxD)	Managerial Person Hours

(Ex0.05)	Clerical Person Hours

(Ex0.10)	Total Costs/Year

(F)

INITIAL PERFORMANCE TESTS









New Plant	24	1	24	0	0	0	0	$0

REPEAT PERFORMANCE TEST









New Plant	24	0.2	4.8	0	0	0	0	$0

REPORT REVIEW









New Plants









	Notification of Construction	2	1	2	0	0	0	0	$0

	Notification of Initial Startup	0.5	1	0.5	0	0	0	0	$0

	Notification of Actual Startup	0.5	1	0.5	0	0	0	0	$0

	Notification of Initial Test	0.5	1.2	0.6	0	0	0	0	$0

	Review Test Results	8	1.2	9.6	0	0	0	0	$0

Existing Plants









	Semiannual Reports	2	2	4	72	288	14	29	$13,711

	Temperature Variance Reports	2	2	4	72	288	14	29	$13,711

SUBTOTAL ANNUAL BURDEN



	576	29	58	$27,421

GRAND TOTAL





662





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