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 1093.10, OMB Control Number 2060-0162.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for 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 the 

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 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.

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

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, an average of 10 respondents per year will be subject to the 

standard, and no additional respondents will become subject to the standard. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”
2

The “Affected Public” is owners or 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 burden to 

the “Federal Government” is attributed entirely to work performed by either Federal employees 

or government contractors; this burden is 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).

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 
3

anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this 

source category at 40 CFR part 60, subpart TTT.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance 

with the applicable regulations which where 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. 

The notifications required in the standard are used to inform the Agency or delegated 

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

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

installed and operated and leaks are being detected and repaired and the standard 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 (77 FR 47631) on date. No comments were received on the burden 

published in the Federal Register.
4

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 the standard, is the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s 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 and the 

standards have previously been reviewed to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the Chemical Coaters 

Association International, at (859) 356-1030; and 2) The Society of the Plastics Industry (SPI), 

at (202) 974-5200. (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. 

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.

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 

the standards. EPA believes that the five-year records retention requirement is consistent 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. 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 the destruction or 

nonexistence of essential records.
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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 industrial coating 

operations that apply surface coatings to plastic parts for business machines. The United States

Standard Industrial Classification (SIC) codes for the respondents affected by the standards, 

which corresponds to the North American Industry Classification System (NAICS) codes, are 

listed below for this source category.

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 NSPS for Surface 

Coating of Plastic Parts for Business Machines (40 CFR Part 60, Subpart TTT). 
6

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)

Initial performance test 60.8(d)

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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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.
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Respondent Activities

Submit the required reports developing, acquiring, installing, and utilizing technology and 

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

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

maintaining information.

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

providing information.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

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

Information Management

5(a) Agency Activities

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

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

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. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 
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maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

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

Both 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 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. Wherever 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.
9

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 979 (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 $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2012, “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 are labor costs. There are no capital/startup 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 is 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. 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 

$4,312. 
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This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 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, approximately

10 existing respondents will be subject to the standard. It is estimated that no additional

respondents will become subject. 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 respondent 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: 
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Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That Keep 

Records But Do Not 

Submit Reports

(E)

Total Annual 

Responses

E=(BxC)+D

Notification of construction/ reconstruction 0 1 0 0

Notification of 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 $94,725. 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 979 at a cost of $94,725. 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).

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 35 hours per response.

There are no capital/startup or O&M costs.

(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 $4,312. 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).
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6(f) Reasons for Change in Burden

There is an increase of one hour in the total estimated burden as currently identified in the 

OMB Inventory of Approved Burdens. This increase is not due to any program change. This is 

due to the fact that we did not round off the burden hours, as was done in the previous ICR.

There is an increase in costs for both the respondents and the Agency from the most 

recently approved ICR. The increase in burden cost is due to an increase in labor rates. This 

ICR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs.

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 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. 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. 
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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)

Burden Item

(A) 

Respondent 

Hours per 

Occurrence

(B) 

Number of 

Occurrences 

per 

Respondent 

per Year 

(C) 

Hours per 

Respondent 

per Year 

(C=A x B) 

(D) 

Number of 

Respondents 

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)

Total Labor 

Costs per 

Year b 

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

New sources

a. Read instructions 0.87 1 0.87 0 0 0 0 $0 

b Required activities

Initial performance tests c2.61 1 2.61 0 0 0 0 $0 

Demonstration of CMS N/A

Repeat of performance tests d2.61 0.2 0.52 0 0 0 0 $0 

Method 24 testing e & f78.26 4 313.04 0.001 0.31 0.02 0.03 $34.86 

c. Create information ------------------------Included in 3b----------------------------

d Gather existing information ------------------------Included in 3e----------------------------

e. Write Report

Notification of construction/ 

reconstruction g 1.74 1 1.74 0 0 0 0 $0 

Notification of actual startup g1.74 1 1.74 0 0 0 0 $0 

Notification of initial performance 

test g 1.74 1 1.74 0 0 0 0 $0 

Report of performance test 5.22 1 5.22 0 0 0 0 $0

Quarterly report of noncompliance h13.91 4 55.64 2 111.28 5.56 11.13 $12,390.98

Semiannual report of compliance i0.43 2 0.86 10 8.6 0.43 0.86 $957.64

Subtotal for Reporting Requirements 138.22

4. Recordkeeping Requirements

a. Read Instructions ------------------------Included in 3a----------------------------
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Burden Item

(A) 

Respondent 

Hours per 

Occurrence

(B) 

Number of 

Occurrences 

per 

Respondent 

per Year 

(C) 

Hours per 

Respondent 

per Year 

(C=A x B) 

(D) 

Number of 

Respondents 

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)

Total Labor 

Costs per 

Year b 

b Plan Activities ------------------------Included in 3b----------------------------

c. Implement Activities ------------------------Included in 3b----------------------------

d Develop Record System 0.87 1 0.87 0 0 0 0 $0

e. Time to Enter Information

 Record of monthly performance tests i, j 6.09 12 73.08 10 730.80 36.54 73.08 $81,376.77

f. Train Personnel N/A

g Audits N/A

Subtotal for Recordkeeping Requirements 840.42

TOTAL ANNUAL LABOR BURDEN AND 

COST (rounded) 979 $94,725

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: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 ”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.

c We have assumed that it will take each respondent 2.61 hours once per year to complete the initial performance tests. 

d We have assumed that 20 percent of respondents will have to repeat performance tests due to failure.

e

 We have assumed that it will take 78.26 hours to perform a Method 24 testing. This testing is performed on the coatings used by the respondents and is generally done by the 

coating manufacturers, who will then provide the test result to the respondents.

f We have assumed that 0.1 percent of respondents must generate Method 24 test data for coating usage due to modification. This situation occurs four times per year.

g

 We have assumed that it will take 1.74 hours once per year to complete notification reports.

h

 We have assumed that it will take 13.91 hours four times per year to write quarterly report of noncompliance.

I

 We have assumed that each respondent will take 0.43 hours two times per year to write the semiannual report of compliance.
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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 

New Plant

Initial performance tests c2.61 1 2.61 0 0 0 0 $0 

 Repeat performance test d2.61 0.2 0.52 0 0 0 0 $0 

Report Review

New Plant

Notification of construction e1.74 1 1.74 0 0 0 0 $0 

Notification of initial startup e1.74 1 1.74 0 0 0 0 $0 

Notification of actual startup e1.74 1 1.74 0 0 0 0 $0 

Notification of initial test e1.74 1 1.74 0 0 0 0 $0 

Review test results e1.74 1 1.74 0 0 0 0 $0 

Quarterly reports of noncompliance f6.96 4 27.84 2 55.68 2.78 5.56 $3,734.71

Semiannual reports of compliance g 0.43 2 0.87 10 8.6 0.43 0.86 $576.90

TOTAL ANNUAL BURDEN and COST (rounded) 74 $4,312

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 $62.27 (GS-13, Step 5, $38.92 + 60%); Technical $46.21 (GS-12, Step 1, $28.88 + 60%); and Clerical 

$25.01 (GS-6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2012 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 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.