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 ICR Number 1976.05, OMB Control Number 2060-0509

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Reinforced Plastic Composites Production (40 CFR part 63, subpart WWWW) were proposed on 

August 2, 2001 (66 FR 40323), promulgated on April 21, 2003 (68 FR 19375), and amended on 

August 25, 2005 (70 FR 50117). These regulations apply to existing facilities 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 system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain 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 U. S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 552 respondents per year will be subject to the 

standard, and 16 additional respondents per year will become subject to the standard. 

The active ICR had the following Terms of Clearance (TOC):

When this ICR is renewed, EPA should review the respondent 

burden, universe, response number, labor rates, and capital 

costs and ensure these estimates have been updated.

 EPA has addressed each item of concern in the TOC. The respondent burden, universe, 

response number, labor rates, and capital cost have been thoroughly checked and all estimates 
2

updated.

The “Affected Public” is owners and operators of RPC facilities. The burden to the 

“Affected Public” 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). The burden to the “Federal Government” is attributed entirely to work performed 

either by Federal employees or government contractors, and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Reinforced Plastic Composites 

Production (40 CFR Part 63, Subpart WWWW) (Renewal). 

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, 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, 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 were 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 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 
3

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 

The notifications required in the 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, leaks are being detected and repaired, and the standard is 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 63, subpart

WWWW.

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, 

no duplication exists.

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 (76 FR 26900) on May 9, 2011. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

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. 
4

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. In developing 

this ICR, we contacted: 1) the American Composites Manufacturer’s Association, at (703) 682-

1656; and 2) the University of Delaware Center for Composite Materials, at (302) 831-8149. 

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 to occur.

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 either the 

destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

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

questions.
5

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 U. S. Standard Industrial Classification (SIC) codes for the 

respondents affected by the standard and the corresponding North American Industry

Classification System (NAICS) codes are listed below.

Standard (40 CFR Part 63, Subpart 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 by NESHAP for 

Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW).

A source must make the following reports:

Notification Reports

Initial notification requirements 63.9(b)(1)

Notification of compliance status when a source becomes subject to 

the standard

63.9(h), 63.5755(a)

Notification that source is subject to special compliance 

requirements, if applicable

63.9(d)

Notification of performance test 63.7(b), 63.5755(a)

Rescheduled of performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g), 63.5755(a)

Change in information already provided 63.9(j)

Request for an extension of compliance with relevant standard 63.9(c)
6

Reports

Application for approval of the construction or reconstruction of a 

new major affected source, or reconstruction of a major affected 

source

63.5(6)(d)

Performance test results 63.10(d)(2), 63.5755

Startup, shutdown and malfunction plan 63.6(e)(3), 63.5758(d)

Periodic startup, shutdown and malfunction reports 63.10(d)(5)(i), 63.5758

Progress reports for compliance extension (if applicable) 63.6(i)

Semiannual compliance reports 63.5758(b-c)

A source must keep the following records:

Recordkeeping

Startup, shutdown and malfunction plan 63.6(e)(3)

All reports and notifications 63.10(b)(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

63.10(b)(3)

Records of maintenance of air pollution control equipment 63.10(b)(2)(iii)

Records of flow monitoring system performance evaluations, 

malfunctions, calibrations, and adjustments

63.10(b)(2)(vi, vii, viii, 

ix, x, and xi), 63.10(c)

Documentation required for waiver of recordkeeping or reporting 

requirements (if applicable)

63.10(b)(2)(xii)

Documentation of initial notifications 63.10(b)(2)(xiv)

Five-year retention of records 63.10(b)(1), 63.5764(b)

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.
7

(ii) Respondent Activities

Respondent Activities

Read instructions.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

systems for 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. 
8

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 

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. 

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

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

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, 

the impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Reinforced Plastic 

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 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 19,312 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NESHAP program, the previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

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

September 2011, “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 type 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 capital/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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent 1

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Response 2

(F)

Number of 

Responses 

(G)

Total O&M,

(E X F)

N/A 0 0 0 $20.13 1,173 23,612

Total 23,612

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 
10

postage is estimated at $7.63 per response for mailing to regulatory agencies.

 

The total capital/startup costs for this ICR are zero. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $23,612. 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 ICR is estimated to be $23,612. These are the 

recordkeeping 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 

$158,749. 

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), 2011 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 – NESHAP for 

Reinforced Plastic 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 ICR, on average over the next three years, approximately

520 existing respondents will be subject to the standard. It is estimated that an additional 16 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below is 552 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

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 16 520 0 0 536

2 16 536 0 0 552

3 16 552 0 0 568

Average 16 536 0 0 552

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 552. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of 

Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total 

Annual 

Response

s 

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 110.4 2 0 220.8

Report of no exceedances 441.6 2 0 883.2

Report of startup, shutdown, malfunction 16 1 0 16

Total 1,172.8

The number of Total Annual Responses is 1,173 (rounded).

The total annual labor costs are $1,850,478. 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).
12

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 19,312 at a cost of $1,850,478. 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). 

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

information is estimated to average 16 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $23,612. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

3,523 labor hours at a cost of $158,749. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart 

WWWW) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in burden hours to the both the respondents and the Agency as 

compared to the most recently approved ICR. The increase is due to industry growth in the 

past three years, resulting in additional number of respondents that are subject to this standard. 

The growth in respondent universe also results in an increase in the total O&M costs. 

In addition, there is an increase in burden costs to both the respondent and the Agency

due to an adjustment in labor rates. This ICR uses the most recent labor rates from the Bureau 

of Labor Statistics in calculating the labor costs. 

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 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 
13

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-2011-0257. 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-2011-0257 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.
14

Table 1: Annual Respondent Burden and Cost – NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, 

Subpart WWWW) (Renewal)

Burden item

(A) 

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

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. Read instructions:

 i. Facilities with 4 groups of operations 12 1 12 14.88 178.56 8.93 17.86 $19,675.88

 ii. Facilities with 5 groups of operations 13 1 13 1.12 14.56 0.73 1.46 $1,604.40

B. Required activities: Sources with add-on 

controls

 i. Initial performance test c  320 1 320 2 640 32 64 $70,522.88

 ii. Repeat of performance test 320 1 320 0.40 128 6.4 12.8 $14,104.58

iii. Operation, maintenance, monitoring plan 40 1 40 2 80 4 8 $8,815.36

iv. Startup, shutdown, malfunction plan 20 1 20 2 40 2 4 $4,407.68

v. Monitoring of operating parameters and 

equipment d

Included in 5E

C. Gather Existing Information Included in 5D, 5E

D. Write report a, c 

 i. Notification of compliance status 4 1 4 16 64 3.2 6.4 $7,052.29

 ii. Notification of construction/ 

reconstruction a

2 1 2 16 32 1.6 3.2 $3,526.14

iii. Notification of actual startup 2 1 2 16 32 1.6 3.2 $3,526.14
15

Burden item

(A) 

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

Cost, $ b

 iv. Notification of performance test 2 1 2 2 4 0.2 0.4 $440.77

 v. Reports of performance test results Included in 4B

vii. Report of exceedances f 16 2 32 110.40 3,532.80 176.64 353.28 $389,286.30

viii. Report of no exceedances 8 2 16 441.60 7,065.6 353.28 706.56 $778,572.60

 ix. Startup, shutdown, malfunction report g2 1 2 16 32 1.6 3.2 $3,526.14

Reporting Subtotal 13,620.05 $1,305,061.16

5. Recordkeeping Requirements

A. Read instructions Included in 4A

B. Plan activities Included in 4B

 C. Implement activities Included in 4B

D. Develop record system (spreadsheets): h

 i. System for low HAP resin 4 14 14 56 2.8 5.6 $6,170.75

 ii. System for work practices 1 11 16 16 0.8 1.6 $1,763.07

iii. System for add-on control devices 2 12 2 4 0.2 0.4 $440.77

E. Time to enter and transmit all information 

into record system h

 i. Enter information on low HAP resin 10 1 10 438 4,380 219 438 $482,640.96

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 $17,630.72

 G. Time to train personnel:

 i. Small facilities (less than 100 employees) 2 1 2 13.12 26.24 1.31 2.62 $2,891.44

0.4 1 0.4 452.64 181.06 9.05 18.11 $19,950.92
16

Burden item

(A) 

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

Cost, $ b

ii. Medium facilities (100-250 employees) 4 1 4 1.76 7.04 0.35 0.70 $775.75

0.8 1 0.8 60.72 48.58 2.43 4.86 $5,352.69

iii. Large facilities (more than 250 

employees)

8 1 8 1.12 8.96 0.45 0.90 $987.32

1.6 1 1.6 38.64 61.82 3.09 6.18 $6,812.51

 H. Time for audits N/A

Recordkeeping Subtotal 5,692.15 $545,416.90

TOTAL LABOR BURDEN AND COST (Rounded) 19,312 1,850,478

Assumptions:

a

 There is an average of 536 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 of which 93 percent (or 14.9) will consist of facilities with 4 groups of operations and 

7 percent of facilities with 5 groups of operations. There is an average of 552 existing respondents per year over the next three year period of this ICR. 

b

 This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per 

hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, ”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 industry.

c

 New respondents have to comply with the initial rule requirements including notifications and performance tests. We have assumed 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 for each control 

device established during the performance test, 2) start-up, shutdown, and malfunctions of equipment, and 3) work practices.

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 thirteen 

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). 
17

f

 We have assumed that approximately 80 percent of the 552 existing respondents will report no excess emissions twice a year and approximately 20 percent will 

report no excess emissions twice a year. 

g

 We have assumed that all RPC facilities with add-on controls (12 existing and 2 new each year or an average of 16) 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 addition, existing RPC facilities have to record operational data. In general, the following monitoring 

is required: 1) facilities with open molding and/or centrifugal casting operations (396 existing and 14 new each year or an average of 438 per year) would have to 

record for low HAP resins; 2) facilities with add-on controls (12 existing and 2 new or an average of 16 RPCs per year) would have to record add-on control devices 

operating parameters; and 3) all facilities (552) 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 new respondents would be identical to that of the existing PRC universe. Therefore, we have assumed that 82 percent of 

the respondents would be small business (i.e., 452.6 RPCs existing and 13.1 new RPC per year), 11 percent (i.e. 60.7 existing RPCs and 1.8 new RPCs per year), 

would be medium business, and 7 percent (i.e., 38.6 existing RPCs and 1.1 new RPCs) are large business. Furthermore, we have assumed that respondents will be 

providing full training to new employees only. Therefore, it will take existing respondents to train its new employees 20 percent of the time it takes new respondents 

to train all employees, assuming the same size business.
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, 

Subpart WWWW) (Renewal)

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per year 

(Ex0.1)

(H) 

Cost, $ b

Notification of applicability a2 1 2 2 4 0.2 0.4 $207.30

Notification of intent to construct a 

major source and review application

12 1 12 16 192 9.6 19.2 $9,950.30

Notification of start of construction 2 1 2 16 32 1.6 3.2 $1,658.38

Notification of actual startup 2 1 2 16 32 1.6 3.2 $1,658.38

Notification of initial performance test 

and test plan

12 1.2 14.4 2 28.8 1.44 2.88 $1,492.55

Report of performance test results 

including operating parameters 

12 1.2 14.4 2 28.8 1.44 2.88 $1,492.55

Notification of compliance status 2 1 2 16 32 1.6 3.2 $1,658.38

Review reports of excess emissions c4 2 8 110.4 883.2 44.16 88.32 $45,771.40

Review reports of no excess emissions c2 2 4 441.6 1,766.4 88.32 176.64 $91,542.80

Review of startup, shutdown, 

malfunction report d

4 1 4 16 64 3.2 6.4 $3,316.77

TOTAL ANNUAL BURDEN AND COST (rounded) 3,523 $158,749

Assumptions:

a There is an average of 536 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 552 existing 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 facilities and 7 

percent are large facilities. Furthermore, we have assumed that 93 percent of the new 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 which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

Managerial rate of $62.27 (GS-13, Step 5, $35.01 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $25.98 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $14.06 
19

x 1.6). These rates are from the Office of Personnel Management (OPM)”2011 General Schedule“, which excludes locality rates of pay. 

c We have assumed that approximately 80 percent of the respondents will report no excess emissions twice a year and approximately 20 percent will report no 

excess emissions twice a year.

d

 We have assumed that all RPC facilities with add-on controls (12 existing and 2 new each year or an average of 16) will have at least one startup, shutdown, or 

malfunction occurrence that is not managed according to the plan.