SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63, subpart PPPP) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63, subpart PPPP).

1(b) Short Characterization/Abstract

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

Parts and Products Surface Coating published at 40 CFR part 63, subpart PPPP were proposed on 

December 4, 2002, and promulgated on April 19, 2004. The regulations were revised on April 

24, 2007 to clarify applicability of the rule and correct certain errors in the regulatory text; there 

was no associated change in the monitoring or recordkeeping requirements. These regulations 

apply to existing facilities and new facilities that perform surface coating of plastic parts and

products where the total Hazardous Air Pollutants (HAPs) emitted are greater than or equal to 10 

tons per year of any one HAP, or where the total HAPs emitted are greater than or equal to 25 

tons per year of any combination of HAPs, that use at least 100 gallons of HAP-containing 

coatings annually. New facilities include those that commenced construction, or reconstruction 

after the date of the proposal. This information is being collected to ensure compliance with 40 

CFR part 63, subpart PPPP.

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

periodic reports by the owners/operators of the affected facilities. They also are 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 or operator subject to the provisions of this part shall maintain a file of these 

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

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

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

States Environmental Protection Agency (EPA) regional office.

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

affected facility at each plant site, and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Approximately 827 sources currently are subject to the standard, and it is estimated that 
2

one additional source per year will become subject to the regulation in the next three years.

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

Collection Request (ICR) without any “Terms of Clearance.”

The burden to the “Affected Public” may be found in Table 1: Annual Respondent 

Burden and Cost, NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63, 

subpart PPPP). The burden to the “Federal Government” is attributed entirely to work 

performed by Federal employees or government contractors; this burden may be found in Table 

2: Average Annual EPA Burden, NESHAP for Plastic Parts and Products Surface Coating (40 

CFR part 63, subpart PPPP).

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, 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, hazardous air pollutant (HAP) emissions from plastic 

parts and products surface coating facilities cause or contribute to air pollution that may

reasonably be anticipated to endanger public health or welfare. Therefore, NESHAP for this 

source category were promulgated at 40 CFR part 63, subpart PPPP.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations that were promulgated in accordance with the Clean Air Act. The 

collected information also is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability
3

to comply with the emission standards. Continuous emission monitors are used to ensure 

compliance with the standards at all times.

The notifications required in the standards 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, that leaks are being detected and repaired and that the standards are being 

met. The performance test also may 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 recordkeeping and reporting requested are required under 40 CFR part 63, subpart 

PPPP.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent 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 Office of Management and 

Budget

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

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

burden published in the Federal Register.

3(c) Consultations

Any comments received since the last ICR renewal, including those submitted in response 

to the first Federal Register notice announcing the renewal of this ICR, must be reviewed. In this 

case, no comments were received. The Agency’s industry experts have been consulted during 

prior renewals. The Agency’s internal data sources and any projections of industry growth over 

the next three years have been considered.

The Agency’s primary source of information as reported by industry is the AFS (Air 

Facility System), which is operated and maintained by the EPA Office of Compliance. AFS is 

the EPA database for the collection, maintenance, and retrieval of all compliance data. Prior 
4

consultations with Agency industry experts regarding the growth rate for the industry indicated 

that one additional respondent per year will become subject to the regulation over the next three 

years.

Estimates of growth rate and burden were developed with extensive participation and 

consultation with plastic parts surface coating industry representatives during prior rulemaking 

for 40 CFR part 63, subpart PPPP. EPA believes that these estimates remain valid, and are the 

best information available. 

For this renewal, EPA contacted a representative industry trade organization to request a 

voluntary opinion as to the accuracy of the burden estimates associated with this ICR and 

whether there is any way to reduce the burden. EPA contacted The National Paint and Coatings 

Association (NPCA) (David Darling, email: ddarling@paint.org). Mr. Darling stated that they

have no comments regarding whether there is any way to reduce the burden, and no recent 

concerns have been expressed regarding the current burden estimations associated with 

recordkeeping and reporting under the rule.

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 likelihood of detecting poor operation and maintenance of control 

equipment and noncompliance would decrease.

3(e) General Guidelines

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

established by OMB at 5 CFR part 1320, section 1320.5.

These standards require affected facilities 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 with 

the part 70 permit program and the five-year statute of limitations on which the permit program 

is based. In addition, the retention of records for five years would allow EPA to establish the 

compliance history of a source and any pattern of compliance for purposes of determining the 

appropriate level of enforcement action. Historically, EPA has found that the most flagrant 

violators frequently have violations extending beyond the five years. EPA would be prevented 

from pursuing the worst violators due to the destruction, or nonexistence of records if records 

were retained for less than five years.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 
5

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 do not contain sensitive questions.

4. The Respondents and the Information Requested 

4(a) Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are plastic parts and 

products surface coating facilities. The United States Standard Industrial Classification (SIC) 

codes for the respondents affected by the standards, which correspond to the North American 

Industry Classification System (NAICS) codes, are listed below for source category descriptions.

Standard SIC Codes NAICS Codes

40 CFR part 63, subpart PPPP 2522 337214

3086 32614, 32615

3089, 3999 326199

3578, 3579 333313

3663, 3679 33422

3429, 3519, 3599, 3714, 3799 336399

3799 336999

2599, 3821, 3841 339111, 339112

3949, 3069 33992

3993 33995

2499, 3634, 3999 339999

4(b) Information Requested

(i) Data Items

All data in this ICR that are recorded and/or reported are required by 40 CFR part 63, 

subpart PPPP.

A source must make the following reports:

Notifications

Initial notification 63.4510(b), 63.5(d), 63.9(b)

Notification of compliance status 63.4510(c), 63.9(h)

Notification of construction or reconstruction 63.4510(a), 63.5
6

Notifications

Notification of actual startup 63.4510(a), 63.9(b)

Notification of performance test 63.4510(a), 63.7(b), 63.8(e), 63.9(e)

Notification Reports

Semiannual report 63.4520(a)

Excess emissions report 63.4520(a)(4-7)

Report of performance test 63.4720(b)

Startup, shutdown, malfunction report 63.4720(c)

A source must keep the following records:

Recordkeeping

Five-year retention of records 63.4531(b), 63.10(b)

Material formulation data 63.4530(b)

Records of HAP content calculations 63.4530(c)

Copies of notifications and reports 63.4530(a)

Records of names of materials used 63.4530(d)

HAP fractions in each material used 63.4530(e)

Coating solids fraction in each material used 63.4530(f)

Density of materials used 63.4530(b)

Documentation of waste material shipped offsite 63.4530(g)

Documentation of deviations 63.4530(h)

Startup, shutdown, and malfunction plan/records 63.4530(i), 63.6(e)

Records of continuous compliance with operating limits 63.4530(i)

Documentation of capture system efficiency determination 63.4530(i)

Documentation of add-on control device destruction or removal 

efficiency determination 63.4530(i)

Documentation of control device performance tests 63.4530(i), 63.10(b)

Determination of capture system and add-on control operating limits 63.4530(i)

Work practice plan/records 63.4530(i)

Electronic Reporting

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way, e.g., inlet and outlet concentrations when determining percent efficiency. 

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. 

In addition, some regulatory agencies are setting up electronic reporting systems to allow sources 

to report electronically which is reducing the reporting burden. However, electronic reporting 

systems are still not widely used by the regulatory agencies. It is estimated that approximately 10 

percent of the respondents use electronic reporting.
7

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate continuous monitoring system (CMS) for temperature, 

for gas flow, or for pressure drop for oxidizer, carbon adsorber, condenser, concentrator, or 

capture system.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, #A, 3B, 

4, 24, 25, 25A, 204, 204A, 204B, 204C, 204D, 204E, 204F, 311, or ASTM Method D1475-98, 

D2697-86, D6093-97 test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter required recordkeeping information detailed 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.

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

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities

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

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

startup, shutdown, malfunction plan, and quality control plan for CMS required to be 

submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to 
8

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply

with the emission standard. Data and records maintained by the respondents are tabulated and 

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

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

determinations.

Information contained in the reports is entered into the AFS which is operated and 

maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, 

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

government-owned facilities. EPA uses the AFS 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 or operator for five 

years.

5(c) Small Entity Flexibility

According to the Final Rule notice published in the Federal Register on April 19, 2004 

(75 FR 20968), approximately 51 percent of the total number of firms affected by this rule are 

small entities. While the number of small firms appears to be a large proportion of the total 

number of affected firms, the small firms experience 21 percent of the total national compliance 

cost. Therefore, this ICR assumes 21 percent of the total affected facilities, or 174 facilities, are 

owned by small entities.

Although the Final Rule will not have a significant economic impact on a substantial 

number of small entities, EPA nonetheless has worked aggressively to minimize the impact of 

the final rule on small entities. EPA solicited input from small entities during the data-gathering 

phase of the rulemaking. EPA promulgated compliance options that give small entities 

flexibility in choosing the most cost-effective and least burdensome alternative for their 

operation. For example, a facility could purchase and use lower or non-HAP coatings, thinners, 

and cleaning materials (i.e., pollution prevention) that meet the Final Rule rather than being 

required to purchase add-on control systems. The lower or non-HAP option can be demonstrated 

with minimum burden by using already-maintained purchase and usage records. No testing of 

materials would be required as the facility owner could show that their coatings meet the 

emission limits by providing formulation data supplied by the manufacturer. 

EPA also provides one option that allows compliance demonstrations to be conducted on 

a rolling 12-month basis, meaning that each month the facility would calculate a 12-month 

organic HAP emission rate for the previous 12 months to determine compliance. This gives 

affected small entities extra flexibility in complying with the emission limits since small entities 

are more likely to use lower monthly volumes and/or a limited number of materials. 

Furthermore, EPA has promulgated the minimum monitoring, recordkeeping and reporting 

requirements needed for enforcement and compliance assurance.
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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, NESHAP for Plastic Parts and Products 

Surface Coating (40 CFR part 63, subpart PPPP).

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.

The Agency may not conduct, or sponsor, and a person is not required to respond to, a 

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

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 320,917 (Total Labor Hours from Table 1). These 

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

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

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $100.99 ($48.09 + 110%)

Technical $87.97 ($41.89 + 110%)

Clerical $43.81 ($20.86 + 110%)

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

December 2005, “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 and Operations and Maintenance Costs

This section covers the costs associated with all types of continuous monitoring 

equipment [e.g., continuous emissions monitoring systems (CEMS) and continuous parameter 
10

monitors]. The types of industry costs associated with the information collection activity in the 

subject standards 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 monitors and other costs, such as photocopying and postage.

(iii) Capital/Startup vs. Operating 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

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost

(B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

CEMS $16,000 1 $16,000 $1,200 2071$248,400

 1

Estimated 25 percent of existing facilities use add-on controls.

The total Capital/Start-up costs for this ICR are $16,000.

The total Operating and Maintenance (O&M) Costs for this ICR are $248,400.

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 $264,400. The continuous 

monitoring costs that are included in this section consist only of those capital/startup and O&M 

costs that a source incurs as a result of the standard. Some continuous monitoring costs are not 

included in this section. For instance, if a particular industry typically utilizes a control device 

that must have a continuous monitor (e.g., temperature, pressure drop, etc.) to function properly, 

and the recordation of additional measurements beyond the minimum are required by the 

standard, then there is no capital/startup or O&M cost, but there is a labor cost to record the 

additional readings. Such a cost would not appear in this section, but in the industry burden 

Section 6(d) below.

6(c) Estimating Agency Burden and Cost

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

information. The EPA 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 

$1,344,013 (see Table 2).

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

Managerial $57.20 (GS-13, Step 5, $35.75 x 1.6) 
11

Technical $42.45 (GS-12, Step 1, $26.53 x 1.6)

Clerical $22.96 (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006 General Schedule”, 

which excludes locality rates of pay. Details upon which this estimate is based appear in Table 2:

Annual Agency Burden and Cost, NESHAP for Plastic Parts and Products Surface Coating (40 

CFR part 63, subpart PPPP).

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

Based on our research for this ICR, there are approximately 827 existing sources 

currently subject to the standard. It is estimated that one additional source will become subject to 

the regulation in each of the next three years.

The number of respondents is calculated using the following table, which addresses the 

three years covered by this ICR.

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That Keep 

Records but Do Not 

Submit Reports

(D)

Number of Existing 

Respondents That 

Also Are New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 827 0 0 828

2 1 828 0 0 829

3 1 829 0 0 830

Average 1 828 0 0 829

 1

New respondents include sources with constructed, reconstructed, and modified affected facilities.

To avoid double-counting respondents, column D is subtracted. As shown above, the average 

Number of Respondents over the three-year period of this ICR is 829.

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 

Responses 

E=(BxC)+D
12

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total Annual 

Responses 

E=(BxC)+D

Initial notification 1 1 0 1

Notification of compliance status 1 1 0 1

Notification of 

construction/reconstruction 1 1 0 1

Notification of actual startup 1 1 0 1

Notification of performance test 1 1.2 0 1

Report of performance test 1 1.2 0 1

Semiannual report 828 2 0 1,656

Excess emissions report 828 2 0 1,656

Startup, shutdown, malfunction 

report 207 1 0 207

Total 3,525

The number of Total Annual Responses is 3,525.

Note that the total annual capital and O&M costs to the regulated entity are $264,400.

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents 

appear below. The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 91 hours per response.

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and are summarized below.

(i) Respondent Tally

The total annual labor costs are $27,180,233. Details regarding these estimates may be 

found in Table 1: Annual Respondent Burden and Cost, NESHAP for Plastic Parts and Products 

Surface Coating (40 CFR part 63, subpart PPPP). Furthermore, the annual public reporting and 

recordkeeping burden for this collection of information is estimated to average 91 hours per 

response.

The total annual capital and O&M costs to the regulated entity are $264,400.

(ii) The Agency Tally
13

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

32,467 labor hours at a cost of $1,344,013. See Table 2: Annual Agency Burden and Cost, 

NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63, subpart PPPP).

6(f) Reasons for Change in Burden

The changes in burden from the most recently approved ICR are due to an adjustment. 

Calculation errors in the previous ICR were corrected, resulting in multiple changes to burden 

estimations: a decrease to the calculated respondent burden hours and cost; an increase to the 

calculated Agency cost; a decrease in the number of total responses; and a net increase in the 

hours per response.

In Table 1: Annual Respondent Burden and Cost, NESHAP for Plastic Parts and Products 

Surface Coating (40 CFR part 63, subpart PPPP), person-hours per respondent per year for the 

material usage recordkeeping requirement was previously rounded to a whole number. In 

carrying out the decimal places for the calculation, the calculated burden is reduced by 476 hours, 

and $40,519.

In Table 2: Annual Agency Burden and Cost, NESHAP for Plastic Parts and Products 

Surface Coating (40 CFR part 63, subpart PPPP), correction of a multiplication error resulted in 

an increase in cost of $264.

In calculating the total number of annual responses in Section 6(d), the previous ICR 

presented startup, shutdown, and maintenance reporting as affecting all respondents. However, 

this was not consistent with the stated assumption that approximately 25 percent of respondents 

use add-on control technology and, therefore, are required to submit startup, shutdown, and 

maintenance reports. This error was corrected in this ICR, resulting in the total number of annual 

responses decreasing from 4,146 to 3,525. As a result, there was a net (factoring in the reduction 

in calculated total respondent hour burden) increase in the calculated hours per response, of 77 to 

91 hours.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 91 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.
14

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-2009-0402. 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 Avenue, N.W., Washington, D.C. 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, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the 

EPA Docket ID Number EPA-HQ-OECA-2009-0402 and OMB Control Number 2060-0537 in 

any correspondence. 

Part B of the Supporting Statement

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

information.
15

Table 1: Annual Respondent Burden and Cost, NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63, subpart PPPP)

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

Burden Item

Person hours

per 

occurrence

Number of 

occurrences 

per year

Person hrs 

per 

respondent 

per year

(C=AxB)

Respondents 

per year 

Technical 

person hrs 

per year

(E=CxD)

Management person 

hrs per year 

(F=Ex0.05)

Clerical 

person hrs 

per year

(G=Ex0.1)

Cost per year

($)

1. Reporting requirements

a. Read rule and instructions 4 1 4 828 3,312.00 165.60 331.20 322,590.46

b. Process/review information 4 4 16 828 13,248.00 662.40 1,324.80 1,290,361.82

c. Write reports

i. Initial notification 2 1 2 1

1

2.00 0.10 0.20 194.80

ii. Notification of compliance 

status 2 1 2 1

1

2.00 0.10 0.20

iii. Notification of construction/ 

reconstruction 2 1 2 1

1

2.00 0.10 0.20 194.80

iv. Notification of actual startup 2 1 2 1

1

2.00 0.10 0.20 194.80

v. Notification of performance test 2 1.222.4 1

1

2.40 0.12 0.24 233.76

vi. Report of performance test 10 1.2212 1

1

12.00 0.60 1.20 1,168.81

vii. Semiannual report 6 2 12 828 9,936.00 496.80 993.60 967,771.37

viii. Excess emissions report 2 2 4 828 3,312.00 165.60 331.20 322,590.46

ix. Startup, shutdown, malfunction 

report 2 1 2 2073414.00 20.70 41.40 40,323.81

Subtotal Reporting 34,781 2,945,624.88

2. Recordkeeping requirements

a. Read rule and instructions 4 1 4 828 3,312.00 165.60 331.20 322,590.46

b. Plan activities 12 1 12 828 9,936.00 496.80 993.60 967,771.37

c. Implement activities 12 1 12 828 9,936.00 496.80 993.60 967,771.37

d. Maintain record system for material 

used 20 1 20 828 16,560.00 828.00 1,656.00 1,612,952.28

e. Time to enter information

i. Material usage 0.5 3654182.5 828 151,110.00 7,555.50 15,111.00 14,718,189.56

ii. Compliance calculation 2 12 24 828 19,872.00 993.60 1,987.20 1,935,542.74

f. Time to train personnel 10 1 10 828 8,280.00 414.00 828.00 806,476.14

g. Store, file, and maintain records 2 12 24 828 19,872.00 993.60 1,987.20 1,935,542.74
16

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

Burden Item

Person hours

per 

occurrence

Number of 

occurrences 

per year

Person hrs 

per 

respondent 

per year

(C=AxB)

Respondents 

per year 

Technical 

person hrs 

per year

(E=CxD)

Management person 

hrs per year 

(F=Ex0.05)

Clerical 

person hrs 

per year

(G=Ex0.1)

Cost per year

($)

h. Retrieve records/reports 1 12 12 828 9,936.00 496.80 993.60 967,771.37

Subtotal Recordkeeping 286,136 24,234,608.01

Total Burden (rounded) 320,917 $27,180,233

Footnotes:

(1) Applies to new sources only.

(2) Assume 20 percent of facilities retest.

(3) Estimated 25 percent of facilities use add-on controls submit startup, shutdown, malfunction report once per year.

(4) Daily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating.
17

Table 2: Annual Agency Burden and Cost, NESHAP for Plastic Parts and Products Surface Coating (40 CFR part 63, subpart PPPP)

(A) (B) (C) (D) (E) (F) (G)

Burden Item

Person hours 

per 

occurrence

Number of 

occurrences 

per year

Respondents 

per year 

Technical 

person hrs per 

year 

(D=AxBxC)

Management 

person hrs per 

year 

(E=Dx0.05)

Clerical person 

hrs per year 

(F=Dx0.1)

Cost per year

($)

1. Initial performance test 24 1 1 24 1.2 2.4 1,142.54

1. Repeat performance test 24 0.2 1 4.8 0.24 0.48 228.51

3. Report review

a. Initial notification 8 1 1 8 0.4 0.8 380.85

b. Notification of compliance status 8 1 1 8 0.4 0.8 380.85

c. Notification of construction/reconstruction 8 1 1 8 0.4 0.8 380.85

d. Notification of actual startup 8 1 1 8 0.4 0.8 380.85

e. Notification of performance test 8 1.2 1 9.6 0.48 0.96 457.02

f. Report of performance test 8 1.2 1 9.6 0.48 0.96 457.02

g. Semiannual report 12 2 828 19872 993.6 1987.2 946,026.43

h. Excess emissions report 4 2 828 6624 331.2 662.4 315,342.14

i. Startup, shutdown, malfunction report 8 1 207 1656 82.8 165.6 78,835.54

Total Burden (rounded) 32,467 $1,344,013