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 ICR 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 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 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 delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly 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 entirely to work performed by either 

Federal employees or government contractors and can be found 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). 

Based on our consultations with industry representatives, there is an average of one
2

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, approximately 10 respondents per year will be subject to these

standards, and no additional respondents per year will become subject to these same standards.

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 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 system 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 

Administrator determines has been adequately 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

reasonably 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 reasonably 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 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 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 these standards are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standards are being met.

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

The requested recordkeeping and 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 directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted 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. 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 (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 by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) 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 standards as they were being 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 Collection

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 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.

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 these standards 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 

(SIC) codes for the respondents affected by the standard, and the corresponding North American 

Industry Classification System (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 by the NSPS for Surface 

Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT).

A source must make the following reports:

Notifications

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

Notifications

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

Reports

Statement of compliance (semiannual) 60.724(b)(2)

Excess emissions/noncompliance (quarterly) 60.724(b)(1)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative 

60.7(b)

Monthly performance test measures and calculations 60.724(a)

Records are required to be retained for two years. 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 and 
7

Respondent Activities

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

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 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. Performance 

test reports are used by the Agency to discern a source’s initial capability 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 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 
8

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. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two

years.

5(c) Small 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 

fairly repetitive and not as time-consuming as for larger sources which may use a much wider 

variety of coating types and application equipment of variable transfer efficiencies, etc. To the 

extent that larger businesses can use economies of scale to reduce their burden, the 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 information 

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 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. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden
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The average annual burden to industry over the next three years from these recordkeeping and reporting requirements 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 

development 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 ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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 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 standards are labor costs. There are neither capital/startup nor 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 neither capital/startup nor 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. EPA's overall compliance and enforcement program includes activities such as 

the examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$3,370.

This cost is based on the average hourly labor rate as follows:
10

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 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 ICR, on average over the next three years, 10 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 10 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 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.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 10. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A) (B) (C) (D)

Number of Existing 

(E)

Total Annual Responses
11

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 hours 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 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 35 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.
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(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 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 an adjustment increase in the respondent burden from the most-recently

approved ICR. The increase in respondent labor hour is caused by a change in assumption; 

in this ICR, we assume all existing sources will take some time each year to re-familiarize 

themselves with the rule requirements. 

6(g) Burden Statement

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 by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA 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-2012-0534. 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 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 
13

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. 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-OECA-2012-0534 and OMB Control Number 2060-0162 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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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 

Occurrence

(Technical 

hours) 

(B) 

Number of 

Occurrences 

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. 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

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 c2.61 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

Repeat of Performance Tests d2.61 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 e1.74 1 1.74 0 0 0 0 $0.00 

Notification of Initial Performance Test e1.74 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 f13.91 4 55.65 2 111.30 5.57 11.13 $12,871.84 

Semiannual Report of Compliance g0.43 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 

Occurrence

(Technical 

hours) 

(B) 

Number of 

Occurrences 

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. Plan 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 h992 $99,700 

Capital 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 additional 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, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit 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 c2.61 1 2.61 0 0 0 0 $0.00 

REPEAT PERFORMANCE TEST

New Plant d2.61 0.2 0.52 0 0 0 0 $0.00 

REPORT REVIEW

New Plant

Notification of Construction e1.74 1 1.74 0 0 0 0 $0.00 

Notification of Initial Startup e1.74 1 1.74 0 0 0 0 $0.00 

Notification of Actual Startup e1.74 1 1.74 0 0 0 0 $0.00 

Notification of Initial Test e1.74 1 1.74 0 0 0 0 $0.00 

Review Test Results e1.74 1 1.74 0 0 0 0 $0.00 

QUARTERLY REPORTS OF NONCOMPLIANCE f6.96 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 h74 $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 additional 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, which excludes locality, rates of 

pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
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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 exactly due to rounding.