2294ss06

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal), EPA ICR Number 2294.06, OMB Control Number 2060-0370.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plating and Polishing Area Sources (40 CFR Part 63, ;Subpart WWWWWW) were proposed on March 14, 2008; promulgated on July 1, 2008; and most-recently amended on both September 19, 2011 and November 19, 2020.¹ These regulations apply to both existing and new plating and polishing facilities that are an area source of hazardous air pollutant (HAP) emissions and that use one or more of the following metal HAP: cadmium, chromium, lead manganese, or nickel (hereafter referred to as the plating and polishing metal HAP). A plating and polishing facility is a plant site that is engaged in any of the following processes: non-chromium electroplating; electroless or non-electrolytic plating; other non-electrolytic metal coating processes such as chromate conversion coating, nickel acetate sealing, sodium dichromate sealing, and manganese phosphate coating, and thermal spraying; dry mechanical polishing of finished metals and formed products after plating or thermal spraying; electroforming; and electro-polishing. New facilities include those that commenced construction, modification ,or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart WWWWWW.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain this file for at least five years following the date of such measurements, maintenance reports, and records. All reports required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. If there is no such delegated authority, the EPA regional office can review them. All other reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the EPA regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator. 

The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal). The ‘burden’ to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal). There are approximately 2,900 plating and polishing aera source facilities, which are owned and operated by the plating and polishing industry. None of the 2,900 facilities in the United States are owned by either state, local, or tribal entities or by the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond.to EPA inquiries.

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).

Over the next three years, approximately 2,900 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards. Of these facilities, we estimate only 5 per cent or 145 facilities will be required to submit a report.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to either new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from plating and polishing facilities either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart WWWWWW.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards 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 these emission standards. Continuous emission monitors are used to ensure compliance with these same 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 these standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of these regulations. The reviewing authority may then inspect the source to check if the leaks are being detected and repaired and that these standards are being met. The performance test may also be observed.

The required annual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures, and for compliance determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart WWWWWW.

3(a) Non-duplication

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, if the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to either the delegated state or the local agency. If a state or local agency has adopted its own 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, duplication does 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 ICR was published in the Federal Register (86 FR 19256) on April 13, 2021. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 2,900 respondents will be subject to these standards over the three-year period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the ‘burden’ associated with these standards as they were being developed and that these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Wisconsin Department of Commerce, at (608) 210-6700, and the Policy Group/National Association for Surface Finishing, at (202) 457-8404.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less-frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to these standards. The 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. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. The EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to either the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators of plating and polishing operations. The United States Standard Industrial Classification (SIC) codes and the corresponding North American Industry Classification System (NAICS) codes for the respondents affected by the standard are listed in the following table:

Standard (40 CFR Part 63, Subpart WWWWWW)	SIC Codes	NAICS Codes
Hardware Manufacturing	3429/3499	33251
Commercial Gravure Printing	2754/2771	323111
Metal Stamping	3469	332119
Bolt, Nut, Screw, Rivet, and Washer Manufacturing	3429/3452	332722
Metal Heat Treating	3398	332811
Metal Coating, Engraving (except jewelry and silverware), and Allied Services to Manufacturers	3479	332812
Plumbing Fixture Fitting and Trim Manufacturing	3432	332913
Other Metal Valve and Pipe Fitting Manufacturing	3429/3432/3494/3499	332919
All Other Miscellaneous Fabricated Metal Product Manufacturing	3291/3429/3432/3494/3497/3499/3537/3599/3914/3999	332999
Bare Printed Circuit Board Manufacturing	3672	334412
Aircraft Engine and Engine Parts Manufacturing	3724	336412
Jewelry (except costume) Manufacturing	3479/3911	339910

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW).

A source must make the following reports:

Notifications
Initial Notification of Applicability	§§63.11509(a), 63.9(b)(2)(i)-(iv)
Notification of compliance status	§63.11509(b)

Reports
Annual Certification of Compliance	§63.11509(c)
Annual Report of Deviations	§63.11509(d)

A source must keep the following records:

Recordkeeping
Records of notifications and reports mentioned above	§§63.10, 63.11509(e)(1), 63.11509(f)
Records that demonstrate continuous compliance	§§63.10, 63.11509(e)(3)
Monitoring/inspection information	§63.10
SSM occurrences and durations	§63.10(b)(2)(i)-(ii)
All required maintenance performed on control and monitoring equipment	§63.10(b)(2)(iii)
Waiver of recordkeeping or reporting requirements	§63.10(f)

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate the appropriate capture and control devices or use wetting agents/fume suppressants or covers per the applicable requirements of 40 CFR 63.11507.

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 collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for 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

The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information:

Agency Activities

Review notifications and reports, including annual certification of compliance reports and deviation reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The annual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, and both EPA regional offices and headquarters. The EPA and its delegated authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Pesticide Active Ingredient Production (40 CFR Part 63, Subpart MMM) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of ‘Burden’ under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor 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 67,700 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $153.55 ($73.12 + 110%)

Technical $122.20 ($58.19 + 110%)

Clerical $61.51 ($29.29 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities required by the subject standard(s) are labor costs. There are no capital/startup and/or operation and maintenance costs.

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

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. The EPA's overall compliance and enforcement program includes such activities 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 $33,300.

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

Managerial $69.04 (GS-13, Step 5, $43.15 + 60%)

Technical $51.23 (GS-12, Step 1, $32.02 + 60%)

Clerical $27.73 (GS-6, Step 3, $17.33 + 60%)

These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 2,900 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 2,900 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR:

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	145	2,755	0	2,900
2	0	145	2,755	0	2,900
3	0	145	2,755	0	2,900
Average	0	145	2,755	0	2,900

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

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 of Applicability	0	1	N/A	0
Notification of Compliance Status	0	1	N/A	0
Annual Compliance Certification	145	1	2,755	2,900
Annual Report of Deviations	145	1	N/A	145
			Total	3,045

The number of Total Annual Responses is 3,045.

The total annual labor costs are $8,000,000. Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

(i) Respondent Tally

The total annual labor hours are 67,700 hours. Details regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. 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 667 labor hours at a cost of $33,300; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is no change in burden from the most-recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. This situation 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. Second, the growth rate for this industry is very low or non-existent, so there is no significant change in the overall burden. Since there are no changes in the regulatory requirements and there is no significant industry growth, there are also no changes in the capital/startup or operation and maintenance (O&M) costs. There is a slight increase in costs, which is wholly due to the use of updated labor rates. This ICR uses labor rates from the most- recent Bureau of Labor Statistics report (March 2021) to calculate respondent burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2021-0116. 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), WJC 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2021-0116 and OMB Control Number 2060-0623 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 Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal)

Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per year a
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Familiarization with Regulatory Requirements b	1	1	1	2,900	2,900	145	290	$394,482.65
B. Required activities
Initial Notification of applicability c	2	1	2	0	0	0	0	$0
Notification of Compliance Status d	4	1	4	0	0	0	0	$0
Annual Compliance Certification e	2	1	2	2,900	5,800	290	580	$788,965.30
Annual Report of Deviations f	2	1	2	145	290	14.5	29	$39,448.27
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Reporting Subtotal					10,339			$1,222,896
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Develop record system	See 5E
E. Time to enter information	N/A
Records of all information required by standards g	0.33	52	17.16	2,900	49,764	2,488.2	4,976.4	$6,769,322.27
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information h	0.25	1	0.25	290	72.5	3.63	7.25	$9,862.07
I. Time for audits	N/A
Recordkeeping Subtotal					57,312			$6,779,184.34
TOTAL LABOR BURDEN AND COST (rounded)i					67,700			$8,000,000
TOTAL CAPITAL AND O&M COST (rounded)i								$0
GRAND TOTAL (rounded)i								$8,000,000

Assumptions
a This ICR uses the following labor rates: $153.55 for managerial labor, $122.20 for technical labor, and $61.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021 “Table 2. Civilian Workers, by occupational and industry group.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
b There are an estimated 2,900 existing plating and polishing plants and no new facilities are expected. We assume that each source subject to the standard will have to familiarize with the regulatory requirements each year.
c Each of the 2,900 existing plants noted above would have already submitted an initial notification. Since there are no new facilities expected, the number of respondents required to submit an initial notification is 0.
d Each of the 2,900 existing plants noted above would have already submitted a notification of compliance status by the appropriate compliance date. Since there are no new facilities expected, the number of respondents required to submit a notification of compliance status is 0.
e The 2,900 existing plants would be required to prepare an annual compliance certification every year. They would only submit the certifications if a deviation occurred; assuming that 5 percent of the plants experience a deviation, the number of compliance certifications submitted will be (2,900*0.05) = 145.
f Assumes that 5% of existing facilities would have to submit a report of deviations starting in Year 3 of the ICR clearance period, or (2,900 * 0.05) = 145.
g It is assumed that 0.33 hr (20 minutes) per week will be required per facility for recordkeeping.
h Annual transmittals would include submission of annual compliance certifications (145) and reports of deviations (145) for 5% of one-third of 2,900 facilities, so (2,900* 0.05) *2 = 145 *2 = 290 respondent.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Plating and Polishing Area Sources (40 CFR Part 63, Subpart WWWWWW) (Renewal)

Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Person-hours per occurrence	No. of occurrences per respondent per year	EPA Person-hours per plant per year (A) x (B)	Plants per year	Technical person-hours (C) x (D)	Managerial person-hours (E) x 0.05	Clerical person-hours (E) x 0.10	Cost, $
Report Review:
Initial Notification of applicability b	1	1	1	0	0	0	0	$0
Notification of Compliance Status c	2	1	2	0	0	0	0	$0
Annual Compliance Certification d	2	1	2	145	290	14.5	29	$16,661.95
Annual Report of Deviations e	2	1	2	145	290	14.5	29	$16,661.95
TOTAL ANNUAL BURDEN AND COST (rounded)f					667			$33,300

Assumptions
a This ICR uses the following average hourly labor rates: $69.04 for managerial (GS-13, Step 5, $43.15 +60%), $51.23 (GS-12, Step 1, $32.02 + 60%) for technical and $27.73 (GS-6, Step 3, $17.33 + 60%) for clerical. These rates are from the Office of Personnel Management (OPM) 2021 General Schedule, which excludes locality rates of pay. These rates have been increased by 60 percent to account for the benefit packages available to government employees.
b Assumes no new plants in the next three years.
c Each of the 2,900 existing plants noted above would have already submitted a notification of compliance status by the appropriate compliance date. Since there are no new facilities expected, the number of respondents required to submit a notification of compliance status is 0.
d The 2,900 existing plants would be required to prepare an annual compliance certification; any plant that experiences a deviation will have to submit the compliance certification; assuming 5 percent of the plants experience a deviation during the three year ICR period, the number of submittals would be (2,900 * 0.05) =145.
e Assumes that 5% of existing facilities would have to submit a report of deviations in the three year ICR period, or (2,900 * 0.05) = 145.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

1 The amendments published on November 19, 2020 (85 FR 73854) included revisions to the initial notification provisions of the NESHAP to include additional language so that the notification shall be submitted no later than 120 calendar days after the source becomes subject to the relevant NESHAP requirements. The revisions did not impose any new information collection burden.

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