SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

NSPS FOR SURFACE COATING OF PLASTIC PARTS FOR BUSINESS MACHINES 

(40 CFR PART 60, SUBPART TTT) 

1. Identification of the Information Collection 

 1(a) Title of the Information Collection

 NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR Part 60, 

Subpart TTT) 

 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 apply to the following facilities in industrial 

surface coating operations that apply coatings to plastic parts for use in the manufacture of 

business machines: each spray booth that applies prime coats, color coats, texture coats or touchup coats. The standards apply to those facilities that commenced construction, modification or 

reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR part 60, subpart TTT. 

 In general, all NSPS standards require initial notifications, performance tests, and 

periodic reports. Owners or operators 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, in general, of all sources 

subject to NSPS. 

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

measurements, and retain the file for at least two years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated State or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) Regional Office. 

 Approximately 10 sources are currently subject to the standard, and the number of 

sources subject to the regulation is expected to either remain the 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 (rounded) 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 the Clean Air Act, as amended, to establish 

standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l). 

 The Agency refers to this charge as selecting the best demonstrated technology (BDT). 

Section 111 also requires that the Administrator review and, if appropriate, revise such standards 

every four years. 

 In addition, Section 114(a) states that the Administrator may require any owner or 

operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with section 114(a)(3); and 

(G) provide such other information as the Administrator may 

reasonably require. 

 In the Administrator's judgment, volatile organic compounds (VOC) emissions from the 

surface coating of plastic parts for business machines cause or contribute to air pollution that 

may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were 

promulgated for this source category at 40 CFR part 60, subpart TTT. 

 

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 VOCs from facilities subject to 
subpart TTT are the result of operation of the industrial surface coating operations that apply 

coatings to plastic parts for use in the manufacture of business machines: each spray booth that 

applies prime coats, color coats, texture coats or touch-up coats. The notifications required in the 

applicable regulations are used to inform the 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. Performance 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 emissions to no more than 1.5 kilograms of VOCs per 

liter of coating solids applied for prime and color coats, and to no more than 2.3 kilograms of 

VOCs per liter of coating solids applied for texture and touch-up coats. The quarterly and 

semiannual reports are used for problem identification at the source, as a check on source 

operation and maintenance, and for compliance determinations. 

 

 The information generated by the monitoring, 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 recordkeeping and reporting requirements is also used for 

targeting inspections, and is of sufficient quality 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 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 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 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 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 previous ICR renewal was used to obtain burden 

estimates since this ICR renewal was processed 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 and internal data sources to project the 

number of affected facilities and industry 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 received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received. 

 

3(d) Effects of Less Frequent Collection

 Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the required standards. Requirements for information gathering 

and recordkeeping are useful techniques to ensure that good operation and maintenance practices 

are applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely. 

3(e) General Guidelines

 These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5. 

3(f) Confidentiality

 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 Agency 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 recordkeeping requirements in the standard do not contain sensitive 

questions. 

4. The Respondents and the Information Requested 

 4(a) Respondents/NAICS Codes

 The respondents of the recordkeeping and reporting requirements are industrial coating 

operations that apply surface coatings to plastic parts for business machines that commenced 

construction, modification, or reconstruction after January 8, 1986. The SIC codes for the 

respondents affected by the standards are SIC (United States Standard 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 manufacturers are highly integrated and perform the 

actual spray coating of plastic parts on-site, while others purchase plastic parts that have already 

been coated at a specialized coating facility. 

4(b) Information Requested

 (i) Data Items

 All data in this ICR that is recorded and/or reported is required by NSPS for Surface 

Coating of Plastic Parts for Business Machines (40 CFR part 60 subpart TTT). 

 A source must make the following reports: 

 

Reports for NSPS subpart TTT

Notification of construction/reconstruction 60.7(a)(1) 

Notification of actual startup 60.7(a)(3) 

Initial performance test results 60.8(a) 

Initial performance test 60.8(d) 

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

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

Excess emissions / noncompliance (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 

necessary. 

Write the notifications and reports listed above. 

Enter information required to be recorded above. 

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

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. 

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. 

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 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 note the operating conditions under which compliance 

was achieved. Data and records maintained by the respondents are tabulated and published for 

use in compliance and enforcement programs. The 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 entered 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 AFS for tracking air pollution compliance and 

enforcement by local and State regulatory agencies, 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 owner or operator for two 
years. 

 

5(c) Small Entity Flexibility

A majority of the affected facilities are small entities (e.g., small businesses). The 

recordkeeping and reporting requirements were selected within the context of a small collection 

of process equipment and reflect the burden on small businesses. 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 facilities will be using the same type of coating each 

month, and using the same spray application equipment. Consequently, the calculations for the 

monthly performance tests will be fairly repetitive and not as time-consuming as for larger 

sources which may use a much wider variety of coating types and application equipment of 

variable transfer efficiencies, etc. To the extent that larger businesses can use economies of scale 

to reduce their burden, the overall burden will be reduced. The Agency considers these 

requirements the minimum needed to ensure compliance and, therefore, cannot reduce them 

further for small entities. 

 The number of small entities potentially subject to the requirements of this information 

collection request is estimated to be 88 percent of the respondent universe, or 9 plants. This 

estimate is based on the percent of plants in this industry that were classified as small plants 

during the development of this rule. 

 5(d) Collection Schedule

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

shown 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 individual burdens for the recordkeeping and 

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

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

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

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

 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 (Total Labor Hours from 

Table 1). These hours are based on an Agency review 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 the 
regulation, Agency knowledge and experience with 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 have been increased by 110% to account for the 

benefit packages available to those employed by private industry. 

(ii) Estimating Capital and Operation and Maintenance Costs 

 The only type of industry costs associated with the information collection activity in the 

standards are labor costs. There are no capital/startup or operation and maintenance costs. There 

is no requirement for the installation of continuous monitoring equipment, or specialized testing 

devices. Monthly performance tests involve calculations only, and rely on data that is either 

readily available or routinely collected as part of normal operations. Most of the measurements 

and calculations required for monthly performance tests under this standard are consistent with 

the respondents’ normal recordkeeping 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 sources found to be in violation of the emission 

standards, and are required only during the particular 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 with the information collection activity in the 

regulations are labor costs. There are no capital/startup or operation and maintenance costs. 

 

6(c) Estimating Agency Burden and Cost

 The only costs to the Agency are those costs associated with analysis of the reported 

information. Publication and distribution of the 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 three 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 average 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 Personnel Management (OPM), 2009 General Schedule, 

which excludes locality rates of pay. The rates have been increased 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 Machines (40 CFR part 60, subpart TTT). 

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

 Approximately 10 sources are currently subject to the regulation, and the number of 

sources subject to the regulation is expected to either remain the 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 Responses Per Year table. This represents the 

number of existing sources plus the number of new sources averaged over the three-year period 

(i.e., the total of the number of new respondents over the three-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 costs are $92,296 (rounded). Details upon which this estimate is 

based appear in Table 1: Annual Respondent Burden and Cost - NSPS for the Surface Coating of 

Plastic Parts for Business Machines (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), Capital/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 hours are 978, with annual labor costs of $92,296. Details 

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

NSPS for the Surface Coating of Plastic Parts for 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 capital/startup and O&M costs. 

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 74 

labor hours at a labor cost of $3,285. The average 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 considerations. First, the regulations have not changed 

over the past three years and are not anticipated to change 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 previous ICR reflect the current burden to the respondents and are 

reiterated in this ICR. 

 However, there is a decrease estimated burden currently identified in the OMB Inventory 

of Approved ICR Burdens. This decrease was due to a change in the adjustments to the 
estimates 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 generate, maintain, retain, or disclose or provide 

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

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

validating, and verifying information, processing and maintaining information, and disclosing 

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

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. 

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

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

Control Numbers for EPA’s 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-2009-0417. 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) 566-1927. 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-2009-0417 and OMB Control Number 2060-0162 in any 

correspondence. 
Part B of the Supporting Statement

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

information.