**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW)**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal), EPA I CR Number 1976.06 , OMB Control Number 2060

- 0509

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composites Production were proposed on August 2, 2001 , promulgated on April 21, 2003, and amended on August 25, 2005 . These regulations apply to existing and new facilities with reinforced plastic composites (RPC) production operations and processes. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart WWWW

. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five 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 United States Environmental Protection Agency (EPA) regional office. The “Affected Public” is owners and operators of RPC facilities. The burden to the “Affected Public” may

be found in Table 1: Annual Respondent Burden and Cost

– NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal)

. The burden to the “Federal Government” is attributed entirely to work performed by

federal employees or government contractors and can be found in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal)

. Over the next three ye ars, approximately 600 respondents per ye ar will be subject to the standard , and 16 additional respondents per year will become subject to the standard2

The Office of Management and Budget ( OMB ) approv ed 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 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, durin g 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, hazardous air pollutant (HAP) emissions from RPC production facilities either cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP w as promulgated for this source category at 40 CFR Part 63, Subpart WWWW

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in leg al 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 perf ormance 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 standard are used to inform the Agency or d elegated authority when a source becomes subject to the requirements of the regulations. The reviewing3

authority may then inspect the source to check if the pollution control devices are properl y installed and operated , leaks are being detected and repair ed , 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. Nonduplication, Consultations, and Other Collection Criteria** The requested recordkeeping an d reporting are required under 40 CFR Part 63, Subpart WWWW

. **3(a) Nonduplication** If th e subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional 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 simil ar 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 by the Federal standards. Therefore, no duplication exists. **3(b) Public Notice R equired 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 ( 79 FR 30117 ) on May 27, 2014

. One comment was received on the burden published in the Federal Register , and is addressed in section 3(c) below. **3(c) Consultations** The Agency

has consulted i ndustry

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 Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO 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 standard as it was being developed and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. In developing this I CR, we contacted the American Composites Manufacturer’s Association (ACMA) at (703) 682

- 1656 and the University of Delaware Center for Composite Materials at (302) 831

- 8149

. One ACMA member indicated that the additional cost of using nylon

- containing film for sheet molding compound (SMC) enclosure is $450,000 per year, which4

includes a purchase cost of $400,000 per ye ar for nylon v. non

- nylon film, and a disposal cost of $50, 000 per ye ar because the nylon

- containing film is not very recyclable. Using nyl on containing film for SMC enclosure is a work practice standard required under Subpart WWWW Table 4. 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 f irst Federal Register n otice. EPA received one comment in response to the first Federal Register notice, but the comment did not contain any substantive recommendations and did not result in changes to this I CR. **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 recordk eeping 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 frequentl y, the proper operation and maintenance of contro l 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. 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 ye ar records retention re quirement is consistent with the Part 70 permit program and the five ye ar statute of limitations on which the permit program is based. The retention of records for five years allow s EPA to establish the compliance history of a source , any pattern of non - c ompliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confi dentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 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 sensitive5

questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are owners or operators of RPC manufacturing facilities . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards and their corresponding North American Industry Classification Sy stem (NAI CS ) codes are listed below

.
**Standard (40 CFR**  **P art 63,**  **S ubpart** 

**WWWW )**  **SIC Codes NAICS Codes**  Custom Compounding of Purchased Plastics Resins 3087 325991 Plastics Pipe and Pipe Fitting Manufacturing 3084, 3089 326122 Plastics Plumbing Fixture Manufacturing 3088 326191 All Other Plastics Product Manufacturing 3999, 3089 326199 Cut Stone and Stone Product Manufacturing 3281 327991 Motor Vehicle Body Manufacturing 3711, 3713, 3714 336211 Motor Home Manufacturing 3716 336213 Travel Trailer and Camper Manufacturing 3792, 3799 336214 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW). A source must make the following reports:

**Notification s**  General references for notification requirements 63.5905(a), Table 13, Table 15 Initial notification requirements 63.9(b)(1), 63.9(b)( 2 ) , 63.9(b)(4), 63.9(b)(5)6
**Notification s**  Notification of compliance status when a source becomes subject to the standard 63.9(h), Notification that source is subject to special compliance requirements, if applicable 63.9(d) Notification of performance test 63.7(b) (1) , 63.9(e), Rescheduled of performance test 63.7(b)(2) Notification of performance evaluation, if using CMS 63 .8(e)(2) Demonstration of continuous monitoring sy stem , if using CMS 63.9(g) Change in information already provided 63.5905(b), 63.9(j) Request for an extension of compliance with relevant standard 63.9(c) Notification and one

- time exemption request status if 100 tpy threshold exceeded 63.5805(e)

- (f) , 63.5910(f)
**Reports** General references for reporting requirements 63.5910(a), Table 14, Table 15 Application for approval of the construction or reconstruction of a new major affected source, or reconstruction of a major affected source 63.5(d) (2)

- (4) Annual organic HAP emissions 63.5799(b)(2) and (c) Performance test results 63.10(d)(2), 63.5850(e)(4)(ii) Report of performance evaluation, if using CMS 63.8(e)(5)(i) Additional reporting requirements for CMS 63.10(e)(1)

- (3) Startup, shutdown and malfunction plan 63.6(e)(3), Periodic startup, shutdown and malfunction reports 63.10(d)(5)(i), 63.5910(c)(4) Immediate startup, shutdown and malfunction reports 63.10(d)(5)(ii), 63.5910(a) and Table 14 Progress reports for compliance extension (if applicable) 63.10(d)(4) Semiannual compliance reports 63. 5910(c)

- (i) A source must keep the following records: **Recordkeeping** General references for re cordkeep ing requirements 63.5865, 63.5895, 63.5915, Tables 10, 11, 12 and 15 Startup, shutdown and malfunction plan 63.6(e)(3) ,7 **Recordkeeping** 63.5915(a)(2) All reports and notifications and Documentation of initial notifications 63.10(b)(1) , 63.10(b)(2)(xiv), 63.5915(a) (1) Records of startup, shutdown, and malfunction of process equipment 63.10(b)(2)(i), (iv, v) Records of malfunctions of air pollution control equipment 63.10(b)(2)(ii) Any applicability

determination that demonstrates why owner or operator believes source is unaffected 63.1(b)(3), 63.10(b)(3) Records of maintenance of air pollution control equipment 63.10(b)(2)(iii) CMS records, records of flow monitoring , data on performance tests, CMS performance evaluations, measurements to determine performance test conditions, , calibrations, and adjustments 63.10(b)(2)(vi, vii, viii, ix, x, and xi), 63.10(c) , 63.5915(a)(3) Documentation required for waiver of recordkeeping or reporting requirements (if applicable) 63.10(b) (2)(xii) Five

- ye ar retention of records 63.10(b)(1), 6 3.5764(b) If using add

- on control device retain the monitoring records required in Part 63 Subpart SS 63.5895(a) , 63.5915(b) , 63.998 Collect and keep records of resin and gel co at use, organic HAP content, and operation 63.5895(c), (d) , 63.586 5, Tables10, 11and 12 Record all times that wet area enclosures doors or covers are open, and that there i s resin in the bath, for each pultrusion machine 63.5895 (e) All data, assumptions and calculations used to determine organic HAP emission factors or content 63.5 9 1 5 (c) Certified statement of compliance with work practices 63.5 9 1 5 (d) Records showing compliance with percent reduction or lbs/ton requirements for continuous lamination/ca sting operations 63.5 9 1 5 (e)(1)

- (4) Annual controlled and

/or uncontrolled HAP emissions (as applicable) 63.5865 , Table s 10, 11and 12 Destruction efficiency

of add

- on control device (if applicable) 63.5865(a) and Table s 1 0 and 12 Capture efficiency

of area enclosure (if applicable) 63.5865 , Table s 1 0 , 11 and 12 Annual organic HAP emissions that escape the enclosure 63.5865, Table 11 Inlet and outlet organic HAP emissions (if applicable) 63.5865, Tables 10 and 12 Enclosure meets Method 204 for a PTE ( if applicable) 63.5865, Tables 10, 11 and 128

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

. 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 sy stems for the purpose of collecting, validating, and verifying infor mation. 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. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.

**5. The Information Collected: Agency Activities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

.9 **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 Integrated Compliance Information System (I CI S) and ECHO. **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 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.
In formation contained in the reports is reported b y state and local governments in the 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 f acilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y 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 reco rds required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** We estimate that 82 percent of respondents are small businesses. The impact on small entities (i.e., small businesses) was taken into c onsideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entitie s. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall bu rden will be reduced. **5(d) Collection Schedule** The specific frequency

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

– NESHAP for Reinforced Plastic10

Composites Production (40 CFR Part 63, Subpart WWWW) (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 IC R. 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** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 20, 900 ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program , the previously approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 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 ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The cap ital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**11

**Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device 1 (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Response (F)

Number of Responses / Sources (G)

Total O&M, (E X F)
N/A 2 0 0 0 $20.13 1, 297 $ 26,109 SMC enclosure 3 $450,000 1 $450,000
**Total (Rounded)**  **476 ,**  **000**

1 This ICR assumes all existing sources are in compliance with initial rule requirements and that the monitoring devices are integral parts of the control devices necessary to determine whether these sources are operating properly 2 We have estimated that file storage and photocopying costs per response cost one hour of clerical labor at $12.50. First class postage is estimated at $7.63 per response for mailing to regulatory agencies. The total cost for this item is based on the number of responses calculated in Section 6(d). 3 Based on consultation conducted during the renewal of this ICR, an ACMA member indicated that the cost of MACT

- mandated use of nylon

- containing film for sheet molding compound (SMC) enclosure for its large SMC facility is approximately $450,000/yr. This is comprised of an added purchase cost of $400,000/yr and a disposal cost of $50,000/yr compare to non

nylon film (nylon

- containing film is not very recyclable). ACMA further indicated this cost estimate applies to no more than 5 percent of the industry. EPA is including the cost for this one facility, but note it may apply to additional facilities with o pen molding operations. Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. The total capital/startup costs for this I CR are zero . This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 476 , 000

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 476 , 000

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost**  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 in spection 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 $ 165, 000

. This cost is based on the average hourl y labor rate as follo ws:12
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 4 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 Cos t

– NESHAP for Reinforced Plastics Composites Production (40 CFR Part 63, Subpart WWWW) (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, approximately 584 existing respondents will be subject to the standard. It is estimated that an additional 16 respondents per ye ar will become subject. The overall average number o f respondents, as shown in the table below, is 600 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 16 568 0 0 584
2 16 584 0 0 600
3 16 600 0 0 616 Average 16 584 0 0 600 1 New respondents include sources with constructed and reconstructed

. 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 600

. The total number of annual responses per ye ar is calculated using the following table:13 **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 compliance status 16 1 0 16 Notification/application of construction 16 1 0 16 Notification of actual startup 16 1 0 16 Notification of performance test and test plan 2 1.2 0 2.4 Report of performance test results 2 1.2 0 2.4 Report of exceedances 1 20 2 0 240 Report of no exceedances 4 80 2 0 960 Report of startup, shutdown, malfunction 22 1 0 44 **Total** 1, 297 (rounded) Note: We assume 20% of initial performance test will fail and require a repeat test. There are 2 new facilities per year with add

- on control which are required to conduct performance testing. Also, we assume 20% of the 600 respondents will have emission ex ceedances. The number of Total Annual Responses is 1 , 297. The total annual labor costs are $2,100, 000

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

– NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (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 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 20, 900

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

– NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (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 16 ho urs per response
. The total annual capital/startup and O&M costs to the regulated entity are $ 476 , 000

. The14

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 3,68 0 labor hours at a cost of $165, 000 . See Table 2: Average Annual EPA Burden and Cost

– NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW ) (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. **6(f) Reasons for Change in Burden** There is an increase in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. The change in the burden and cost estimates occurred because the total number of respondents has increased, after accounting for anticipated industry growth over three years. The increase in O&M costs is due to the inclusion of the MACT compliance standard for SMC enclosure for one large facility , based on comment received from industry consultation. We have also updated the labor cost estimates to use more updated labor rates. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 16 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, processing 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 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 thi s 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 under15

Docket ID Number EPA

- HQ

- O ECA

- 2014

- 0081

. 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 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 fr om 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

- 1927

. Also, you can send comments to the Office of In form ation 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

- 2014

- 008 1 and OMB Control Number 2060

- 0509 in any correspondence

. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.16

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

**– NESHAP for Reinforced Plastic**  **Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal)** 

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=AxB) Respondents

per year a Technical

person hours per year (E=CxD) Management

person hours per year (Ex0.05) Clerical

person hours per year (Ex0.1) Cost, $ b

1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Systems N/A 4. Reporting Requirements A. Familiarization with the regulatory requirement : i. Facilities with 4 groups of operations 12 1 12 14.88 178.56 8.93 17.86 $20,649.66 ii. Facilities with 5 groups of operations 13 1 13 1.12 14.56 0.73 1.46 $1,683.80 B. Required activities: Sources with add

- on controls i. Initial performance test c 320 1 320 2 640 32 64 $74,013.12 ii. Repeat of performance test 320 1 320 0.4 128 6.4 12.8 $14,802.62 iii. Operation, maintenance, monitoring plan 40 1 40 2 80 4 8 $9,251.64 iv. Startup, shutdown, malfunction plan 20 1 20 2 40 2 4 $4,625.82 v. Monitoring of operating parameters and equipment d See 5E C. Gather Existing Information See 5D, 5E D. Write report a, c i. Notification of compliance status 4 1 4 16 64 3.2 6.4 $7,401.31 ii. Notification of construction/ reconstruction a 2 1 2 16 32 1.6 3.2 $3,700.66 iii. Notification of actual startup 2 1 2 16 32 1.6 3.2 $3,700.66 iv. Notification of performance test 2 1 2 2 4 0.2 0.4 $462.5817

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=AxB) Respondents

per year a Technical

person hours per year (E=CxD) Management

person hours per year (Ex0.05) Clerical

person hours per year (Ex0.1) Cost, $ b

v. Reports of performance test results See 4B vii. Report of exceedances f 16 2 32 120 3840 192 384 $444,078.72 viii. Report of no exceedances 8 2 16 480 7680 384 768 $888,157.44 ix. Startup, shutdown, malfunction report g 2 1 2 22 44 2.2 4.4 $5,088.40 **Subtotal for Reporting Requirements 14,694**  **$1,477,616.43** 5. Recordkeeping Requirements A. Familiarization with the regulatory requirements See 4A B. Plan activities See 4B C. Implement activities See 4B D. Develop record system (spreadsheets): h i. System for low

HAP resin 4 1 4 14 56 2.8 5.6 $6,476.15 ii. System for work practices 1 1 1 16 16 0.8 1.6 $1,850.33 iii. System for add

- on control devices 2 1 2 2 4 0.2 0.4 $462.58 E. Time to enter and transmit all information into record system h i. Enter information on low HAP resin 10 1 10 480 4800 240 480 $555,098.40 ii. Enter information on work practices and operating parameters N/A F. Develop operator training course and keep records of operators taken it 10 1 10 16 160 8 16 $18,503.28 G. Time to train personnel: i. Small facilities (less than 100 employees) 2 1 2 13.12 26.24 1.312 2.624 $3,034.54 0.4 1 0.4 478.88 191.55 9.58 19.16 $22,152.13 ii. Medium facilities (100

- 250 employees) 4 1 4 1.76 7.04 0.35 0.70 $814.14 0.8 1 0.8 64.24 51.39 2.57 5.14 $5,943.2518

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=AxB) Respondents

per year a Technical

person hours per year (E=CxD) Management

person hours per year (Ex0.05) Clerical

person hours per year (Ex0.1) Cost, $ b

iii. Large facilities (more than 250 employees) 8 1 8 1.12 8.96 0.45 0.90 $1,036.18 1.6 1 1.6 40.88 65.41 3.27 6.54 $7,564.14 H. Time for audits N/A **Subtotal for Recordkeeping Requirements 6,195**  **$622,935.13 TOTAL LABOR BURDEN AND COST**  **(Rounded): 20,900**  **$ 2,100,**  **000 Capital and O&M Cost (see Section 6(b0(iii)):**  $ 47 6, 000 **TOTAL COST: $2,**  **5 80**  **, 000**  **Note:** Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.
**Assu mptions:** 
a There is an average of 584 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We hav e assumed that there will be an average of 16 new

RPC facilities each year over the three year period of this ICR of which 93 per cent (or 14.88) will consist of facilities with 4 groups of operations and 7 percent (or 1.12) of facilities with 5 groups of operations. There is an average of 600 total respondents p er year over the next three year period of this ICR. b This ICR use s the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor St atistics, 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% to account for the benefit packages available to those employed by private indus try.

c New respondents have to comply with the initial rule requirements including notifications and performance tests. We have ass umed that two new respondents per year will install add

- on controls equipment and therefore, will be require to conduct an initial performance test. We have assumed that performance tests are repeated by 20 percent of the respondents.
d Monitoring and recordkeeping of operations for respondents with enclosures and add

- on control devices include: 1) specific operating parameters fo r each control device established during the performance test, 2) start

- up, shutdown, and malfunctions of equipment, and 3) work practices.19

e Monitoring and recordkeeping of operations for respondents that comply by limiting the HAP content of their raw materials include: 1) monitoring and recording in a spreadsheet the monthly consumption of material and the weighted

- average HAP content over the past 12 months, and 2) work practices. However, if all the materials in an operation meet the HAP content limit, then each respondent would need only to record HAP content and would not need to track monthly consumption or record the computations. For open molding and centrifugal casting operations, respondents would also have the option of averaging among thirt een different processes (open molding) and two different processes (centrifugal casting to calculate the monthly average of the actual and allowable emissions for the combined open molding and centrifugal casting operations).
f We have assumed that approximately 80 percent of the 600 (or 480) existing respondents will report no excess emissions twice a year and approximately 20 percent (or 120) will report excess emissions twice a year.
g We have assumed that all RPC facil ities with add

- on controls (18 existing and 2 new each year or an average of 22) will have at least one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plan. h New respondents (16) have to develop a record system. In ad dition, existing RPC facilities have to record operational data. In general, the following mo nitoring is required: 1) facilities with open molding and/or centrifugal casting operations (452 existing and 14 new each year or an average of 480 per year) wo uld have to record for low HAP resins; 2) facilities with add

- on controls (18 existing and 2 new or an average of 22 RPCs per year) would have to record add

on control devices operating parameters; and 3) all facilities (600) need to keep records of its work practices. Since operating parameters for control equipment and standard work practices are already monitored by industry for other purposes, we are not attributing these burdens to the rule. i We have assumed that he amount of time it takes a respondent to train its employees would vary with the number of employees at its facility. We have also assumed that the distribution in size of the ne w respondents would be identical to that of the existing PRC universe. Theref ore, we have assumed that 82 percent of the respondents would be small business (i.e., 478.88 RPCs existing and 13.12 new RPC per year), 11 percent (i.e. 64.24 ex isting RPCs and 1.76 new RPCs per year), would be medium business, and 7 percent (i.e., 40.88 existing RPCs and 1.12 new RPCs) are large business. Furthermore, we have assumed that respondents will be providing full training to new employees only. Therefore, to train existing respondents, it will take 20 percent of the time it takes to train new em ployees.20

**Table 2: Avera ge Annual EPA Burden and**  **Cost**

**– NESHAP for Reinforced P**  **lastic Composites Production (40 CFR Part 63,**  **Subpart WWWW) (Renewal)**

Burden item (A) (B) (C) (D) (E) (F) (G) (H) Person hours per occurrence No. of

occurrences per respondent per year Person hours

per respondent per year (C=AxB) Respondents

per year a Technical

person hours per year (E=CxD) Management

person hours per year (Ex0.05) Clerical

person hours per year (Ex0.1) Cost, $ b
Notification of applicability a 2 1 2 2 4 0.1 0.4 $203.07 Notification of intent to construct a major source and review

application 12 1 12 16 192 0.8 19.2 $9,495.76
Notification of start of construction 2 1 2 16 32 0.8 3.2 $1,624.56 Notification of actual startup 2 1 2 16 32 0.8 3.2 $1,624.56 Notification of initial performance test and test plan 12 1.2 14.4 2 28.8 0.1 2.88 $1,423.11 Report of performance test results including operating parameters 12 1.2 14.4 2 28.8 0.1 2.88 $1,423.11 Notification of compliance status 2 1 2 16 32 0.8 3.2 $1,624.56 Revie w reports of excess emissions
c 4 2 8 120 960 6 96 $47,604.60 Revie w reports of no excess emissions c 2 2 4 480 1920 24 192 $95,964.00 Revie w of

startup, shutdown, malfunction report d 4 1 4 22 88 1.1 8.8 $4,398.35

**TOTAL ANNUAL BURDEN AND COST (rounded)**  **3,680 $165,**  **000 Note:**  Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. Assumptions:21

a There is an average of 584 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be an average of 16 new

RPC facilities each year over the three year period of this ICR. Therefore, there is an average of 600 total respondents per year over the next three year period of this ICR. We have assumed that 82 percent of the existing RPC facilities are small business, 11 percent are medium size f acilities and 7 percent are large facilities. Furthermore, we have assumed that 93 percent of the ne w RPC facilities will consist of an average of four groups of operations and 7 percent will consist of five groups of operations. b This cost is based on the following labor rates: Managerial rate of $62.90 (GS

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

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

- 6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages availab le to government employees. c We have assumed that approximately 80 percent (or 480) of the respondents will report no excess emissions twice a year and approximately 20 percent (or 120) will report excess emissions twice a year. d We have assumed that all RPC facilities with add

- on controls (18 existing and 2 new each year o r an average of 22) will have at least one startup, shutdown, or malfunction occurrence that is not managed according to the plan.