SUPPORTING STATEMENT

ENVIRONMENTAL PR OTECTION AGENCY

NSPS FOR SURFACE COATING OF PLAS TIC PARTS FOR BUSINESS MACHINES (40 CFR PART 60, SUBPART TTT)

1. Identification of th e Information Collection

1(a) Title of the Information Collection

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

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Surface Coating of Plastic Parts for Business Machines (40 CFR part 60, subpart TTT) were proposed on January 8, 1986, and were promulgated on January 29, 1988. These standards a pply to the following fa cilities in industrial surface coating operations that apply coatings to plastic parts for use in the manufacture of business machines: each spray booth that applies prim e coats, color coats, texture coats or touchup coats. The standards apply to those faciliti es that commenced cons truction, modification or

reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart TTT.

In general, all NSPS standa rds require initial notificati ons, performance tests, and periodic reports. Owners or operators are also required to maintain reco rds 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 i noperative. These notifications, reports, and records are essential in determining compliance; and are required, in ge neral, of all sources subject to NSPS.

Any owner or operator subject to the provisions of this part sh all maintain a file of these measurements, and retain the file for at least tw o years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated St ate 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.

Approximately 10 sources are currently subj ect to the standard, and the number of sources subject to the regulation is expected to either remain th e same or to slightly decrease during the next three years. These figures are based on estimates from the most recently approved Information Collection Request (ICR) renewal. The information collection will involve 10 respondents, 978 (rounde d) burden hours, and $92,296 (rounded) in labor costs.

OMB approved the currently active ICR without any “Terms of Clearance.”2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of th e Clean Air Act, as amended, to establish standards of performance for new st ationary sources that reflect:

. . . application of the best te chnological system of continuous emissions reduction which (taking in to consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the

Administrator determines has b een adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selec ting 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) st ates that the Administrato r may require any owner or operator subject to any requirement of this Act to:

(A) Establish and maintain such re cords; (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 peri ods, and in such manner as the Administrator shall prescribe) ; (E) keep records on control equipment parameters, production vari ables or other indirect data when direct monitoring of emi ssions is impractical; (F) submit compliance certifications in accordance with section 114(a)(3); and (G) provide such other informa tion as the Administrator may reasonably require.

In the Administrator's judgment, volatile organic compounds (VOC) emissions from the surface coating of plastic parts for business mach ines cause or contribute to air pollution that may reasonably be anticipated to endanger public h ealth 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 control of emissions of VOCs from the surface coating of plastic parts for business machines requires not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. Emissions of VOC s from facilities subject tosubpart TTT are the result of opera tion of the industrial surface coating operations that apply coatings to plastic parts for use in the manufact ure of business machines: each spray booth that applies prime coats, color coats, texture coats or touch-up coats. The notifications required in the applicable regulations are used to inform th e Agency or delegated authority when a source becomes subject to the standard. The reviewing authority may then inspect the source to check if the standards are being met. Pe rformance test reports are needed as these are the Agency's record of a source's initial capability to comply with the emission standard, and serve as a record of the operating conditions under which compliance was achieved. The performance test may

also be observed. The standards restrict emi ssions to no more than 1.5 kilograms of VOCs per liter of coating solids applied for prime and colo r coats, and to no more than 2.3 kilograms of VOCs per liter of coating solids applied for te xture and touch-up coats. The quarterly and semiannual reports are used for problem identif ication at the source, as a check on source operation and maintenance, and for compliance determinations.

The information generated by the monitori ng, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities affected by the NSPS continue to achieve compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with these standards, as required by the Clean Air Act. The information collected from recordkeep ing and reporting requirements is also used for targeting inspections, and is of sufficient qua lity to be used as evidence in court.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart

TTT.

3(a) Nonduplication

If the subject standards have not been dele gated 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 st ate or local agency has adopted its own similar regulation 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 Fe deral standards. Therefore, no duplication exists.

3(b) Public Notice Required Pr ior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published

in the Federal Register on July 8, 2009 (74 FR 32580). No comments were received on the burden published in the Federal Register

.3(c) Consultations

For this information collection, the previ ous ICR renewal was us ed to obtain burden estimates since this ICR renewal was proces sed under the “Expedited Approach” option. Per this guidance, all data and assumptions from the previous ICR renewal were used as the basis for estimating the hourly and cost burdens associated with this renewal.

The Agency has consulted industry experts a nd internal data sour ces to project the

number of affected facilities and indu stry growth over the next three years. In a previous ICR renewal, EPA’s Office of Air Quality Planning and Standards (OAQPS) conducted an extensive review of and consultations with industry during development of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Plastic Parts and Products. Approximately 10 respondents will be subject to the standard over the three year period covered by this ICR.

It is our policy to respond after a thorough review of comments rece ived since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection woul d decrease the margin of assurance that facilities are continuing to meet the required stan dards. Requirements for information gathering and recordkeeping are useful techniques to ensu re 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 viol ations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requireme nts do not violate any of the regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

The required information has been determined not to be confidential. However, any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agen cy policies set forth in Title 40, Chapter 1, part 2, subpart B - Confidentiality of Business Information (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 recordkeepi ng requirements in the standa rd do not contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

The respondents of the reco rdkeeping and reporting requireme nts are indust rial coating operations that apply surface coatings to plasti c parts for business machines that commenced construction, modification, or reconstruction after January 8, 1986. The SIC codes for the respondents affected by the standard s are SIC (United States Standa rd Industrial Classification) 2851, 3079, 3471, 3573, 3574, 3579, 3661, and 3861 which correspond to the NAICS (The North American Industry Classification System) 32551, 332813, 339942, 334518, 333313, 33421, 334418, 333315, and 325992. The broad range of SIC codes covered by the standards

reflects the fact that some business machine ma nufacturers are highly inte grated and perform the actual spray coating of plastic part s on-site, while others purchase plastic parts that have already been coated at a specia lized coating facility.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded a nd/or reported is required by NSPS for Surface Coating of Plastic Parts for Business M achines (40 CFR part 60 subpart TTT).

A source must make the following reports:

Reports for NSPS subpart TTT

Notification of constructi on/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)

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

Excess emissions / noncomplia nce (quarterly) 60.724(b)(1)A source must maintain the following records:

Recordkeeping for NSPS subpart TTT

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)

(ii) Respondent Activities

Respondent Activities

Read instructions

Perform initial performance test, Reference Method 24 test, and repeat performance tests if

necessar y

. Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquirin g, installing, and uti lizing technology and

s y stems for the p ur p ose of collectin g , validatin g , and verif y in g information.

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

maintainin g information.

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

p rovidin g information.

Adjust the existing ways to comply with a ny previously applicable instructions and

re q uirements.

Train personnel to be able to res pond to a collection of information.

Transmit, or otherwise disclose the information.

Some of the respondents are using monitori ng equipment that au tomatically records parameter data. Although personnel at the affected facility must st ill evaluate the data, internalautomation has significantly reduced the burden a ssociated with monitoring and recordkeeping at a plant site.

Also, regulatory agencies in cooperation w ith the respondents, c ontinue to create reporting systems to transmit data electronically. However, electronic reporting systems are still not widely used. At this time, it is estimate d that approximately 10 pe rcent of the respondents use electronic reporting.

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 re peat performance tests if necessary.

Review notifications and repor ts, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in th e Air Facility System (AFS) database.

5(b) Collection Methodology and Management

Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard, and to not e the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. Th e quarterly and 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 en tered into the AFS which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses A FS for tracking air po llution compliance and enforcement by local and State regulatory ag encies, and 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 owne r or operator for twoyears.

5(c) Small Entity Flexibility

A majority of the affected facilities are small entities (e.g., small businesses). The recordkeeping and reporting requirements were sele cted within the context of a small collection of process equipment and reflect the burden on small businesses. The impact on small entities was accounted for in the regulation development. The requirements reflect the burden on small businesses. For the most part, smaller faciliti es will be using the same type of coating each month, and using the same spray application equipm ent. Consequently, the calculations for the monthly performance tests will be fairly repetit ive and not as time-consuming as for larger sources which may use a much wider variety of coating types and appl ication equipment of variable transfer efficiencies, et c. 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, therefor e, cannot reduce them

further for small entities.

The number of small entities po tentially subject to the requirements of this information collection request is estimated to be 88 percent of the respondent universe, or 9 plants. This estimate is based on the percent of plants in this industry that were cla ssified 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 in Table 1: Annual Respondent Burden and Cost - NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR part 60, subpart TTT).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of i ndividual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed un der standardized headings believ ed to be consis tent with the concept of burden under the Paperwork Reduction Ac t. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated at 978 (rounded) person-hours (Tot al Labor Hours from Table 1). These hours are based on an Agency re view of the industry during development of the NESHAP for Surface Coating of Plastic Parts and Products which are standards that apply to the same industry, Agency studies and background documents from the development of theregulation, Agency knowledge and experience w ith the NSPS program, and the previously approved ICR.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $115.40 ($54.95 + 110%) Technical $97.88 ($46.61 + 110%) Clerical $48.38 ($23.04 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2009, ”Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, ”Total compensation.” The rates ha ve been increased by 110% to account for the benefit packages available to t hose employed by private industry.

(ii) Estimating Capital and Operation and Maintenance Costs

The only type of industry costs associated w ith the information colle ction activity in the standards are labor costs. There are no capital/sta rtup or operation and maintenance costs. There is no requirement for the installa tion of continuous monitoring equi pment, or specialized testing devices. Monthly performance tests involve calcul ations only, and rely on data that is either readily available or routinely co llected as part of normal operati ons. Most of the measurements and calculations required for monthly performance tests under this standard are consistent with the respondents’ normal recordkeep ing practices. Semiannual reports are essentially a statement that all performance tests showed the source to be in compliance with the emissions limitations. Quarterly reports are required only of those s ources found to be in violation of the emission standards, and are required only during the par ticular quarter in which a performance test

indicated a violation.

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

The only type of industry costs associated w ith the information colle ction activity in the regulations are labor costs. There are no capit al/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those cost s associated with anal ysis of the reported

information. Publication and distribution of th e information are part of the AFS program. Examination of records to be maintained by the respondents will occur as part of the periodic inspection of sources, which is part of EPA' s overall compliance and enforcement program.The average annual Agency cost during the th ree years of the ICR is estimated to be $3,860 (Table 2: Annual Agency Burden and Cost - NSPS for the Surface Coating of Plastic Parts for Business Machines (40 CFR part 60, subpart TTT)).

This cost is based on the averag e hourly labor rate as follows:

Managerial $61.36 (GS-13, Step 5, $38.35 + 60%) Technical $45.52 (GS-12, Step 1, $28.45 + 60%) Clerical $24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personne l Management (OPM), 2009 General Schedule, which excludes locality rates of pay. The rates have been in creased by 60% to account for the benefit packages available to government employees. Details upon which this estimate is based appear in the attached Table 2: Annual Agency Burden and Cost - NSPS for the Surface Coating

of Plastic Parts for Business Mach ines (40 CFR part 60, subpart TTT).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Approximately 10 sources are currently subj ect to the regulation, and the number of sources subject to the regulation is expected to either remain th e same or to slightly decrease during the next three years.

Respondent Universe and Average Number of Responses Per Year

Regulation

Citation (A) Average

Number of

New Respondents per Year (B)

Number

of Reports

for New

Sources (C)

Number of Existing Respondents (D) Number of Reports for Existing

Sources (F)

Number of Respondents that keep

records but do

not submit

reports (E)

Total

Annual Responses (AxB)+ (CxD)+F

NSPS, 40 CFR part 60, subpart TTT 0 4 10

2 2 (semiannual) 4 (quarterly) 0 28

The number of total respondents is 10. This number is the sum of column A and column C of the Respondent Universe and Number of Res ponses Per Year table. This represents the number of existing sources plus the number of new sources aver aged over the three-year period (i.e., the total of the number of new respondents over the thre e-year period divided by three years).

The total annual response is 28. This number is in column E of the Respondent Universe and Number of Responses Per Year table above.The total annual labor cost s are $92,296 (rounded). Details upon which this estimate is based appear in Table 1: Annual Respondent Burd en and Cost - NSPS for the Surface Coating of

Plastic Parts for Business Machin es (40 CFR part 60, subpart TTT).

Note that the total annual capital and O&M costs to the regulated entity are $0. These costs are detailed in Section 6(b)(iii), Capita l/Startup vs. Operation and Maintenance (O&M)

Costs.

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents are attached in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hour s are 978, with annual labo r costs of $92,296. Details regarding these estimates may be found in Ta ble 1. Annual Respondent Burden and Cost - NSPS for the Surface Coating of Plastic Parts fo r Business Machines (40 CFR part 60, subpart TTT) (attached). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 35 hours per response.

There are no annual capita l/startup and O&M costs.

(ii) The Agency Tally

The average annual Agency burden and cost ove r next three years is estimated to be 74 labor hours at a labor cost of $3,285. The averag e annual travel expenses over the next three years cost $575. Thus, the total average annual Agency burden is estimated to cost $3,860. See Table 2. Annual Agency Burden and Cost - NSPS for the Surface Coating of Plastic Parts for Business Machines (40 CFR part 60, subpart TTT) (attached).

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this ICR compared to the previous ICR. This is due to two consider ations. First, the regulations have not changed over the past three years and are not anticipated to cha nge over the next three years. Secondly, the growth rate for the respondents is very low, negative, or non-existent . Therefore, the labor hours and cost figures in the prev ious ICR reflect the current bu rden to the respondents and are

reiterated in this ICR.

However, there is a decrease estimated burde n currently identified in the OMB Inventory of Approved ICR Burdens. This decrease was due to a change in the adjustments to theestimates to correct a mathematical error.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 35 (rounded) hours per response. Burden means the total time, effort, or financial resources expended by persons to genera te, 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 fo r the purposes of collecting, validating, and verifying information, processi ng and maintaining information, and disclosing and providing information; adjust the existing wa ys 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 a nd 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 currently valid OMB Cont rol Number. The OMB Control Numbers for EPA’s regulations are list ed 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-2009-0417. An electronic version of the public docket is available at http://www.regula tions.gov/ which may be used to obtain a copy of the draft collection of information, submit or view pub lic comments, access the index listing of the contents of the docket, and to access those docum ents in the public docket that are available electronically. When in the syst em, select “search,” then key in the docket ID number identified

in this document. The documents are also avai lable 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, Washingt on, 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 Read ing Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1927. Al so, 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 fo r EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2009-0417 and OM B Control Number 2060-0162 in any correspondence.Part B of the Supporting Statement

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

information.