**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) (Renewal), EPA I CR Number 2044.05 , OMB Control Number 2060

- 0537 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Plastic Parts and Products Surface Coating (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 in order to clarify the applicability of the rule and to correct certain errors in the regulatory

text; there was no associated change in either monitoring or recordkeeping requirements. These regulations apply to both new and existing 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 g allons of HAP

- containing coatings annuall y. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart PPPP

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

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunctio n in the operation of an affected facility, or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to th e delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an aver age of 83 2 respondents per ye ar will be subject to the se standard s , with one additional respondent per ye ar becom ing subject to the se same standard s
.2

The active (previous) IC R had the following Terms of Clearance (TOC): When this I CR is renewed, E PA shoul d review the respondent burden, universe, response number, labor rates, and capital costs and if necessary , update these estimates. EPA has addressed each item of concern in the TOC by consulting with industry representatives. EPA has reviewed and updated all estimates using the most recentl y available information. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Plastic Parts and Products Surface Coating (40 CF R Part 63, Subpart PPPP) (Renewal). The burden to the Federal Government is attributed entirel y to work performed b y either F ederal employees or government contractors , and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Pla stic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

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

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

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certification s in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from facilities that perform surface coating of plastic parts and products cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category

at 40 CFR part 63, subpart PPPP

.3

**2(b) Practical Utility/Users of the Data** The recordkeep ing and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the perform ance test , a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or d elegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired , and the standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart PPPP

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (77 FR 63813) on October 17, 2012. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data4

sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported by industry , in compliance with the record

keeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA’s database for the collection, maintenance, and retrieval of all compl iance data. The growth rate for the industry

is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard s as they were being developed and the standard s have previously been reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted : 1) the American Coatings Association (ACA) , at (202) 462

- 6272 ; and 2) the Molded Fiber Glass Companies , at (440) 813

- 1188

. 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 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. I f 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 les s 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. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. Th e retention of records for five ye ars allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submi tted to the Agency for which a claim of confidentiality is made5

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

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1 , 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
The reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are facilities that perform surface coating of plastic parts and products . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards and corresponding North American Industry Classification System (NAI CS ) code are in the following table.

**Standard (** **40 CFR P**  **art 63, S**  **ubpart PPPP )**  **SIC Codes NAICS Codes**  Office Furniture (except Wood) Manufacturing 2522 337214 Polystyr ene Foam Product Manufacturing 3086 32614, 32615 All Other Plastics Product Manufacturing 3089, 3999 326199 Office Machinery Manufacturing 3578, 3579 333313 Radio and Television Broadcasting and Wireless Communications Equipment Manufacturing 3663, 3679 33422 All Other Motor Vehicle Parts Manufacturing 3429, 3519, 3599,3714,3799 336399 All Other Transportation Equipment Manufacturing 3799 336999 Laboratory

Apparatus and Furniture Manufacturing 2599, 3821, 3841 339111, 339112 Sporting and Athletic Goods Manufacturing 3949, 3069 33992 Sign Manufacturing 3993 33995 All Other Miscellaneous Manufacturing 2499, 3634, 3999 3399996

**4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required by the NESHAP for Plastic Parts and Products Surface Coating (Renewal)

. A source must make the following reports:

**Notification s**  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 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)
**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

- ye ar 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)7 **Recordkeeping** 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 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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or temperature, for gas flow, or for pressure drop for oxidizer, carbon absorber, condenser, concentrator, or capture system. Perform initial performance test, Reference Method s 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 D147 5

- 98, D2697

- 86, D6093

- 97 test, and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above.8 **Respondent Activities** Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden asso ciated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and9

for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 indus trial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. Both EPA and its delegated Authorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **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 at least 21 percent of the total affected 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 fl exibility 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 own er 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 mo nth 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 compl yi ng with the emission limits since small entities are more likel y 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. **5(d) Collection Schedule** The specific frequency

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

– NESHAP for Plastic Parts and10

Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)

. **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for both the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these record

keeping and reporting requirement s is estimated to be 322, 467 hours ( Total L abor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and exp erience with the NESHAP program, the previously

- approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121.44 ($ 57.83 + 110%) Technical $ 100.23 ($ 47.73 + 110%) Clerical $ 50.51 ($ 24.05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total comp ensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

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

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor s and other costs such as photocop yi ng and postage.11 **(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs.**  **Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (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 $1,200 208 **1** $249,6 00 **1** Estimated 25 percent of existing facilities use add

- on controls. The total capital/startup costs for this I CR are $16,000. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $249,600. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry

over the next three years of the IC R is estimated to be $ 265,600

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents , periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cos t during the three years of the ICR is estimated to be $ 1,4 70 , 160

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 2012 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to governm ent employees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)

.12

**6(d) Estimating the Respondent Universe and Total Burden and Costs**  Based on our research for this I CR, on average over the next three ye ars, initially 831 existing respondents will be subject to the standard s
. Inaddition, i t is estimated that an additional respondent will become subj ect each ye ar of the three

- ye ar period

. O verall , the average number of respondents, as shown in the table below , is 832 per ye ar. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 1 830 0 0 831
2 1 831 0 0 832 3 1 832 0 0 833 Average 1 831 0 0 832 1 New respondent include sources with constructed, reconstructed and modified affected facilities

.

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 832

. The total number of annual responses per ye ar 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

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 .2 Report of performance test 1 1.2 0 1 .213 **Total Annual Responses** Semiannual report 831 2 0 1,662 Excess emissions report 831 2 0 1,662 Startup, shutdown, malfunction report 208 1 0 208
Total 3,53 8.4 The number of Total Annual Responses is 3,53 8 responses (rounded)

. The total annual labor costs are $ 31, 223,994

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

– NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detail ed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 322, 467 at a cost of $31,223,994

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)

. 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/startup and O&M costs to the regulated entity are $265,600

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 32, 623 labor hours at a cost of $1, 470,160 . See Table 2 below : Average Annual EPA Burden and Cost

– NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63, Subpart PPPP) (Renewal)

. **6(f) Reasons for Change in Burden** There is an increase in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens. The adjustment increase in burden from the most recentl y14

approved ICR is due to an increase in the number of sources subject to the NESHAP , as well as an adjustment increase in labor rates. This ICR used the most recent labor rates in calculating all burden costs. The growth in the respondent universe also results in a corresponding increase in the total O&M costs. **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 b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwi se disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has esta blished a public docket for this I CR under Docket ID Number EPA

–HQ

–OECA

–2012

–0688

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this do cument. 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 i s (202) 566

- 1 752

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

- 20 12

- 0688 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) (Renewal)**

Burden Item (A) Person hours per occurrence (B)

Number of occurrences per year (C)

Person hrs per respondent per year (C=AxB) (D)

Respondents per year a (E)

Technical person hrs per year (E=CxD) (F)

Manage ment person hrs per year (F=Ex0.05) (G)

Clerical person hrs per year (G=Ex0.1) (H)

Cost per year ($) b

1. Reporting requirements a. Read rule and instructions 4 1 4 83 2 3,32 8 166. 4 332. 8 $370,137. 79 b. Process/review information 4 4 16 83 2 13, 312 665.6 1, 331.2 $1,48 2 , 331

. 13 c. Write reports i. Initial notification 2 1 2 1 2 0.1 0.2 $222.71 ii. Notification of compliance status 2 1 2 1 2 0.1 0.2 $222.71 iii. Notification of construction/ reconstruction 2 1 2 1 2 0.1 0.2 $222.71

iv. Notification of actual startup 2 1 2 1 2 0.1 0.2 $222.71 v. Notification of performance test 2 1.2 2.4 1 2 0.12 0.24 $267.25 vi. Report of performance test 10 1.2 12 1 12 0.6 1.2 $1,336.2 3 vii. Semiannual report c 6 2 12 83 2 9,9 84 499.2 998.4 $1,11 1 , 748

. 35 viii. Excess emissions report 2 2 4 83 2 3,32 8 166. 4 332. 8 $370, 582

. 79 ix. Startup, shutdown, malfunction report d 2 1 2 208 416 20.8 41.6 $46,322.85 **Subtotal for**  **Reporting Requirements**  **34, 948.96**  2. Recordkeeping requirements a. Read rule and instructions 4 1 4 83 2 3,32 8 166. 4 332. 8 $370, 582

. 79 b. Plan activities 12 1 12 83 2 9,9 84 499.2 998.4 $1,11 1 , 748

. 35 c. Implement activities 12 1 12 83 2 9,9 84 499.2 998.4 $1,11 1 , 748

. 35 d. Maintain record system for material used 20 1 20 83 2 16,6 4 0 83 2 1 , 66 4 $1,85 2 , 913

. 9216

Burden Item (A) Person hours per occurrence (B)

Number of occurrences per year (C)

Person hrs per respondent per year (C=AxB) (D)

Respondents per year a (E)

Technical person hrs per year (E=CxD) (F)

Manage ment person hrs per year (F=Ex0.05) (G)

Clerical person hrs per year (G=Ex0.1) (H)

Cost per year ($) b

e. Time to enter information i. Material usage e 0.5 365 182.5 83 2 151, 840 7, 592 15,1 84 $16, 907 , 839

. 52 ii. Compliance calculation f 2 12 24 83 2 19,9 68 99 8

. 4 1,99 6

. 8 $2,22 3 , 496

. 71 f. Time to train personnel 10 1 10 83 2 8,3 20 41 6 83 2 $92 6 , 456

. 96 g. Store, file, and maintain records g 2 12 24 832 19,9 68 99 8

. 4 1,99 6

. 8 $2,22 3 , 496

. 71 h. Retrieve records/reports 1 12 12 83 2 9,9 84 499.2 99 8

. 4 $1,11 1 , 748

. 35 **Subtotal for**  **Recordkeeping Requirements**  **287, 518**  **. 40**  **Total Annual**  **Burden and Cost**  **(rounded) 322,**  **467 $31,**  **223 ,**  **99 4** 

**Assu mptions**  **:** a We have assumed that there are approximately 832 respondents, with one additional new source becoming subject to the rule over the next three years of this ICR. b This ICR uses the following labor rates: Managerial $121.44 ($57.83 + 110%), Technical $100.2 3 ($47.73 + 110%), and Clerical $50.51 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “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. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical h ours. c We assume that each respondent will take 6 hours two time per year to w rite semiannual report. d It is e stimated that 25 percent of facilities use add

- on controls submit startup, shutdown, and malfunction report once per year.
e We assumed th at each respondent will take 0.5 hours each day to enter d aily records of mass fraction of organic HAP for each coating, thinner, or cleaning material, and mass fraction of coating solids for each coating. f We have assumed that each respondent will take 2 hours once per month to enter compliance calculation. g We have assumed that each respondent will take 2 hours once per month to store, file and maintain records. h We have assumed that each respondent will take I hour once per month to retrieve records/reports.17

**Table 2: Average Annual EPA Burden and Cost**

**– NESHAP for Plastic Parts and Products Surface Coating (40 CFR Part 63,**  **Subpart PPPP) (Renewal)** 

Burden Item (A) EPA Person hours per occurrence (B)

Number of occurrences per year (C) EPA

Person hrs per plant per year (C=AxB) (D)

Plants per year (E)

Technical person hrs per year (E=CxD) (F)

Manage

ment person hrs per year (F=Ex0.05) (G)

Clerical person hrs per year (G=Ex0.1) (H) Cost per

year ($)

1. Initial performance test 24 1 24 1 24 1.2 2.4 $1,243.79 1. Repeat performance test 24 0.2 4.8 1 4.8 0.24 0.48 $248.76 3. Report review a. Initial notification 8 1 8 1 8 0.4 0.8 $414.60 b. Notification of com

pliance status 8 1 8 1 8 0.4 0.8 $414.60 c. Notification of construction/reconstruction 8 1 8 1 8 0.4 0.8 $414.60 d. Notification of actual startup 8 1 8 1 8 0.4 0.8 $414.60 e. Notification of performance test 8 1.2 9.6 1 9.6 0.48 0.96 $497.52 f. Report of performance test 8 1.2 9.6 1 9.6 0.48 0.96 $497.52 g. Semiannual report 12 2 24 83 2 19,9 68 998.4 1, 996.8 $1, 034,831.62 h. Excess emissions report 4 2 8 83 2 6,6 56 332. 8 66 5

. 6 $344, 946.12 i. Startup, shutdown, malfunction report 8 1 8 208 1,664 83.2 166.4 $86,235.9 6 **Total Burden (rounded) 32,6**  **23 $1,4**  **70 ,**  **160 Assumptions:**  a We have assumed that there are approximately 832 respondents, with one additional new source becoming subject to the rule over the next three years of this ICR. b This ICR uses the following labor rates: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) , Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%), and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 20 12 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial ho urs are 5% of Technical hours.
c We have assumed that each respondent will take 12 hours two times per year to review semiannual report. d We have assumed that each respondent will take 4 hours two times per year to review the excess emissions report.