**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (Renewal)**  **1. Identification of the Information Collection**  **1(a) Title of the Information**  **Collection** NSPS for Surface Coating of Plastic Parts for Business Machines ( 40 CFR Part 60, Subpart TTT) (Renewal), EPA I CR Number 1093.11 , OMB Control Number 2060

- 0162

. **1(b) Short Characterization/Abstract**  The New Source Performance Standards (NSPS) for the Surface Coating of Plastic Parts for Business Machines were proposed on January 8, 1986, promulgated on January 29, 1988, and amended on October 17, 2000. These regulations apply to new facilities that perform industrial surface coating operations on plastic parts for use in the manufacture of business machines: each spray booth that applies prime coats, color coats, texture coats or touch

- up coats. 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 60, Subpart TTT

. In general, all NSPS standards require initial notifications, performance tests, and periodic reports b y 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 s y stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to the NSPS

. Any owner/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 delegat ed state or local authority. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. The “Affected Public” constitutes both owners and operators of facilities that conduct industrial surface coating of plastic parts for use in business machines. The ‘ burden ’ to the Affected Public may

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

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (Renewal)

. The Federal Government ’s ‘ burden ’ is attributed entirel y to work performed b y either F ederal emplo ye es or government contractors and can be found below in Table 2: Average Annual EPA Burden an d Cost

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (Renewal)

. Based on our consultations with industry representatives, there is an average of one2

affected facilities at each plant site and that each p lant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, approximately 10 respondents per ye ar will be subject to the se standard s , and no additional respondents per year will become subject to the se same standard s . The Office of Management and Budget ( OMB ) approved the currentl y active I CR 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 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years. 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 reasonabl y require. In the Administrator's judgment, volatile organic compound (VOC) emissions from surface coating of plastic parts cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category

at 40 CFR Part 60, Subpart TTT

.3

**2(b) Practical Utility/Users of the Data**  The recordkeeping and reporting requirements in the se 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. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the se 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 properl y installed and operated , leaks are being detected and repaired , and the standard s are being met. The performance t est 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. Non** 
**- duplication, Consultations,**  **and Other Collection Criteria** The requested recordkeeping an d reporting are required under 40 CFR Part 60, Subpart TTT

. **3(a) Non** 
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regio nal office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y 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 I CR was published in the Federal Register ( 80 FR 32116 ) on June 5, 2015

. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** 4

The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard s as they were b eing developed. In developing this ICR, we contacted both the Chemical Coaters Association International , at (859) 356

- 1030; and the Society of the Plastics Industry

(SPI) , at (202) 974

- 5200. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Collect** **ion** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintena nce practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, 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 b y OMB under 5 CFR Part 1320, Section 1320.5. **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, Sept ember 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 se standard s do not include sensitive questions. **4. The Respondents and the Information Requested** 5

**4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are facilities that conduct surface coating of plastic parts

. The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the s tandard , and the corresponding North American Industry Classification Sy stem (NAICS ) codes are listed in the table below : **Standard ( 40 CFR Part**  **60 , Subpart**  **TTT )**  **SIC Codes NAICS Codes**  Paint and Coating Manufacturing 2851 32551 Electroplating, Plating, Polishing, Anodizing, and Coloring 3471 332813 Lead Pencil and Art Good Manufacturing 3579 339942 Watch, Clock, and Part Manufacturing 3579 334518 Office Machinery

Manufacturing 3578, 3579 333313 Telephone Apparatus Manufacturing 3661 33421 Printed Circuit Assembly (Electronic Assembly) Manufacturing 3661 334418 Photographic and Photocopying Equipment Manufacturing 3861 333315 Photographic Film, Paper, Plate, and Chemical Manufacturing 3861 325992 Computer Storage Devices Manufacturing 3572 334112 **4(b) Information Requested**  **(i) Data Items**  In this ICR , all the data that is recorded or reported is required b y the NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT). A source must make the following reports:
**Notification s**  Notification of construction/reconstruction 60.7(a)(1) Notification of actual startup 60.7(a)(3) Initial performance test results 60.8(a) , 60.724(a) Initial performance test 60.8(d)6
**Notification s**  Notification of physical or operational change 60.7(a)(4)
**Reports** Statement of compliance (semiannual) 60.724(b)(2) Excess emissions/noncompliance (quarterl y) 60.724(b)(1) A source must keep the following records: **Recordkeeping** Startups, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 60.7(b) Monthly performance test measures and calculations 60.724(a) Records are required to be retained for two ye ars. These records must be kept onsite. 60.724(d)
Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. **(ii) Respondent Activities**  **Respondent Activities** Familiarization with the regulatory requirements. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test, Reference Method 24 test, and repeat performance tests if necessary . Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and7 **Respondent Activities** sy stems for the purpose of collecting, validating, and verifying inform ation. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.

**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, analy sis, storage, and distribution of the required information. **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Enforcement and Compliance History Online (ECHO) and I CI S. **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capabi lity to comply

with the emission standard , and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual repo rts are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. In formation contained in the reports is reported b y state and local governments in the8

IC IS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforce ment 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 b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Sm**  **all Entity Flexibility** A majority

of the respondents are small entities (i.e., small businesses). The recordkeeping and reporting requirements were selected within the context of a small collection of process equipment and reflect the burden on small businesses. For the most part, smaller facilities will be using the same type of coating each month, and using the same spray application equipment. Consequently , the calculations for the monthly performance tests will be fairl y repetitive and not as time

- consuming as for larger sources which may use a much wider variety of coating typ es and application equipment of variable transfer efficiencies, etc. To the extent that larger businesses can use economies of scale to reduce their burden, th e overall burden will be reduced. The Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities. The number of small entities potentially subject to the requirements of this i nformation collection request is estimated to be 90 percent of the respondent universe, or 9 plants from a total of 10 respondents. This estimate is based on the percent of plants in this industry that were classified as small plants during the development of this rule. **5(d) Collection Schedule**  The specific frequency

for each information collection activity within this request is shown b elow in Table 1: Annual Respondent Burden and Cost

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (Renewal)

. **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to th is 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** 9

The averag e annual burden to industry over the next three years from these record

keeping and reporting requirement s is estimated to be 992 hours ( Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the de velopment of the regulation, Agency knowledge and experience with the NSPS program, the previously

- approved ICR, and any comments received. **6(b) Estimating Respondent Costs**  **(i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 9

. 93 ($ 61.87 + 110%) Technical $ 10 3

. 97 ($4 9

. 51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance**  **Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard s are labor costs. There are n either capital/startup n 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 n either capital/startup n or operation and maintenance costs. **6(c) Estimating Agency Burden and C**  **ost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic insp ection 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 $ 3, 370

. This cost is based on the average hourl y labor rate as follows:10 Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 5 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, 10 existing respondents will be subject to the se standard s . It is estimated that no additional respondents per ye ar will become subject to these same standards

. The overall average number of respondents, as shown in the table below, is 10 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 10 0 0 10 2 0 10 0 0 10 3 0 10 0 0 10 Average 0 10 0 0 10 1 New respondents include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 10

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) (B) (C) (D) Number of Existing (E) Total Annual Responses11 **Total Annual Responses** Information Collection Activity Number of Respondents Number of

Responses Respondents That

Keep Records But Do Not Submit Reports E=(BxC)+D

Notification of construction/ reconstruction 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of initial performance test 0 1 0 0 Report of performance test 0 1 0 0 Quarterly report of noncompliance 2 4 0 8 Semiannual report of compliance 10 2 0 20 Total 28 The number of Total Annual Responses is 28

. The total annual labor costs are $99, 700

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

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (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, respectively , and summarized below. **(i) Respondent Tally** The total annual labor h ours are 992 hours

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

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) ( Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical 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 ty pical 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 35 hours per response

. The total annual capital/startu p 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.12 **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 74 labor hours at a cost of $3, 370

. See below Table 2: Average Annual EPA Burden and Cost

– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required fo r technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. **6(f) Reasons for Change in Burden**  There is an adjustment increase in the respondent burden from the most

- recently approved ICR. The increase in respondent labor hour is caused b y a change in assumption; in this I CR, we assume all existing sources will take some time each ye ar to re

- familiarize themselves with the rule requirements. **6(g) Burden Statem**  **ent** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 35 hours per response. ‘ Burden ’ means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processin g and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Contro l Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 201 2

- 0534

. 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 sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and13

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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory A ffairs, 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

- 20 12

- 0534 and OMB Control Number 2060

- 0162 in any correspondence. **Part B of the Suppo rting Statement**  This part is not applicable because no statistical methods were used in collecting this information.14

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

**– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR**  **Part 60, Subpart TTT) (Renewal)**

REPORTING/RECORDKEEPING REQUIREMENT (A) Respondent Hours per Occurr ence (Technical hours) (B)

Number of Occurr ences per Respondent per Year (C)

Hours per Respondent per Year (C=A x B) (D)

Number of Respondent per Year (E)

Technical Hours per Year @ $103.97 (E=C x D) (F)

Management Hours per Year @ $129.93 (F= E x 0.05) (G)

Clerical Hours per Year @ $51.79 (G= E x 0.1) Total Labor

Costs per Year

b

1. AP PL ICATIONS 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 New Sources a
a. Familiarize with rule requirements 0.87 1 0.87 10 8.70 0.43 0.87 $1,005.61 b. Required Activities Initial Performance Tests c 2.61 1 2.61 0 0 0 0 $0.00 Demonstration of CMS N/A N/A N/A N/A N/A N/A N/A N/A Rep eat of Performance Tests d 2.61 0.2 0.52 0 0 0 0 $0.00 Method 24 Testing 78.26 4 313.04 0.01 3.13 0.16 0.31 $362.02
c. Create Information

------------------------ See 3b

---------------------------- d. Gather Existing Information

------------------------ See 3e

---------------------------- e. Write Report Notification of Construction/ Reconstruction e 1.74 1 1.74 0 0 0 0 $0.00 Notification of Actual Startup e 1.74 1 1.74 0 0 0 0 $0.00 Notification of Initial Performance Test e 1.74 1 1.74 0 0 0 0 $0.00 Report of Performance Test 5.22 1 5.22 0 0 0 0 $0.00 Quarterly Report of Noncompliance f 13.91 4 55.65 2 111.30 5.57 11.13 $12,871.84 Semiannual Report of Compliance g 0.43 2 0.87 10 8.70 0.43 0.87 $1,005.61 **Subtotal for Reporting Requirements 152**  **$15,245** 4. RECORDKEEPING REQUIREMENTS
a. Read Instructions

------------------------ See 3a

----------------------------15

REPORTING/RECORDKEEPING REQUIREMENT (A) Respondent Hours per Occurr ence (Technical hours) (B)

Number of Occurr ences per Respondent per Year (C)

Hours per Respondent per Year (C=A x B) (D)

Number of Respondent per Year (E)

Technical Hours per Year @ $103.97 (E=C x D) (F)

Management Hours per Year @ $129.93 (F= E x 0.05) (G)

Clerical Hours per Year @ $51.79 (G= E x 0.1) Total Labor

Costs per Year

b

b. Pla n Activities

------------------------ See 3b

---------------------------- c. Implement Activities

------------------------ See 3b

---------------------------- d. Develop Record System 0.87 1 0.87 0 0 0 0 $0.00
e. Time to Enter Information Record of monthly performance tests 6.09 12 73.04 10 730.43 36.52 73.04 $84,471.47 f. Train Personnel N/A N/A N/A N/A N/A N/A N/A N/A g. Audits N/A N/A N/A N/A N/A N/A N/A N/A **Subtotal for Recordkeeping Requirements 840**  **$84,471 TOTAL ANNUAL LABOR BURDEN AND COST**  **h 992**  **$99, 700**  **Cap i**  **tal and O&M Cost (see Section 6(b)(iii)): h**  **$0 TOTAL COST:**  **h $99,**  **700** Assumptions
a We have assumed that the average number of sources that will be subject to the standard will be 10. There will be no additio nal new source per year that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: Managerial $62.90 (GS

- 13, Step 5, $39.31 + 60%) ; Technical $46.67 (GS

- 12, Step 1, $29.17 + 60%); and Clerical $25.25 (GS

- 6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2 015 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the bene fit packages available to government employees.
c We have assumed that it will take 2.61 hours once per year to complete initial performance test. d We have assumed that it will take 2.61 hours 0.2 times per year to repeat performance test.

e We have assumed that it will take 1.74 hours once per year to review notification and review test results. f We have assumed that 20 percent of facilities will report noncompliance. g We have assumed that each facility will take 0.43 hours two times per year to report semiannual compliance. h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.16

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

**– NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR**  **Part 60, Subpart TTT) (Renewal)**

**Burden Item (A)**  **EPA Hours per**  **Occurrence (Technical**  **hours) (B)** 

**Number of Occurrences**  **per Plant per Year**  **(C)**

**EPA Hours per Year**  **(C=A x B) (D)** 

**Plants per Year**  **a (E)** 

**Technical Hours per**  **Year (E=C x D)**  **(F)**

**Management Hours per**  **Year (F= E x 0.05)**  **(G )** 

**Clerical Hours per**  **Year (G= E x 0.1)**  **(H)**

**Costs per Year**  **b**

INITIAL PERFORMANCE TESTS

New Plant c 2.61 1 2.61 0 0 0 0 $0.00 REPEAT PERFORMANCE TEST

New Plant d 2.61 0.2 0.52 0 0 0 0 $0.00 REPORT REVIEW

New Plant Notification of Construction e 1.74 1 1.74 0 0 0 0 $0.00 Notification of Initial Startup e 1.74 1 1.74 0 0 0 0 $0.00 Notification of Actual Startup e 1.74 1 1.74 0 0 0 0 $0.00 Notification of Initial Test e 1.74 1 1.74 0 0 0 0 $0.00 Review Test Results e 1.74 1 1.74 0 0 0 0 $0.00 QUARTERLY REPORTS OF NONCOMPLIANCE f 6.96 4 27.83 2 55.65 2.78 5.57 $2,912.83 SEMIANNUAL REPORTS OF COMPLIANCE g 0.43 2 0.87 10 8.70 0.43 0.87 $455.13 SALARY BURDEN (per year) $3,367.96 **TOTAL ANNUAL BURDEN h**  **74 $3,**  **370** Assumptions

a We have assumed that the average number of sources that will be subject to the standard will be 10. There will be no additio nal new source per year that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: Managerial $62.90 (GS

- 13, Step 5, $39.31 + 60%) ; Technical $46.67 (GS

- 12, Step 1, $29.17 + 60%); and Clerical $25.25 (GS

- 6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2015 General Schedule, whic h excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.17

c We have assumed that it will take 2.61 hours once per year to complete initial performance test. d We have assumed that it will take 2.61 hours 0.2 times per year to repeat performance test.

e We have assumed that it will take 1.74 hours once per year to review notification and review test results. f We have assumed that 20 percent of facilities will take 6.96 hours four times per year to report noncompliance. g We have assumed that each facility will take 0.43 hours two times per year to report semiannual compliance. h Totals have been rounded to 3 significant figures. Figures may not add exac tly due to rounding.