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 ICR 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 

gallons of HAP-containing coatings annually. 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, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

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

and are required of all affected facilities subject to NESHAP. 

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

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

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

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

Environmental Protection Agency (EPA) regional office.

 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 years, an average of 832 respondents per year will be subject to these

standards, with one additional respondent per year becoming subject to these same standards.
2

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

When this ICR is renewed, EPA should review the respondent

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

and 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 recently 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 CFR Part 63, 

Subpart PPPP) (Renewal). The burden to the Federal Government is attributed entirely to work 

performed by either Federal employees or government contractors, and may be found 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). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from facilities that perform surface 

coating of plastic parts and products cause or contribute to air pollution that may reasonably be 

anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for 

this source category at 40 CFR part 63, subpart PPPP.
3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

the applicable regulations which where promulgated in accordance with the Clean Air Act. The 

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

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

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

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

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

determine compliance in place of a continuous emission monitor. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

PPPP.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

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 ICR 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 data 
4

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

The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System 

(OTIS) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s 

database for the collection, maintenance, and retrieval of all compliance data. The growth rate 

for the industry is based on our consultations with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standards as they were being developed and the 

standards 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. 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.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent the 

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

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

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 (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 (SIC) codes for the respondents affected by the standards and corresponding

North American Industry Classification System (NAICS) code are in the following table.

Standard (40 CFR Part 63, Subpart PPPP) SIC Codes NAICS Codes

Office Furniture (except Wood) Manufacturing 2522 337214

Polystyrene 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 339999

 
6

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:

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

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-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)
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 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.

(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 Methods 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 information required to be recorded above.
8

Respondent Activities

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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping.

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source 

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

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 
9

for compliance determinations.

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

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

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

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

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

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

years.

5(c) Small Entity Flexibility

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 

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.

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 and 
10

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 ICR. The 

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

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

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

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

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

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 322,467 hours (Total Labor Hours from 

Table 1 below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($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 compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitors and other costs such as photocopying and postage.
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(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 2081$249,600

 1

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

The total capital/startup costs for this ICR are $16,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR 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 analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as 

the examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$1,470,160. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 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 government 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 ICR, on average over the next three years, initially 831 

existing respondents will be subject to the standards. In addition, it is estimated that an 

additional respondent will become subject each year of the three-year period. Overall, the

average number of respondents, as shown in the table below, is 832 per year. 

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

years covered by this ICR. 

Number of Respondents

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 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.

.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 832. 

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

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 1.2
13

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 3,538.4

The number of Total Annual Responses is 3,538 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 detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, 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 recently 
14

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 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 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–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 system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2012-0688 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) 

Management 

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 4 832 3,328 166.4 332.8 $370,137.79

b. Process/review information 4 4 16 832 13,312 665.6 1,331.2 $1,482,331.13 

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 $1,336.23

vii. Semiannual report c6 2 12 832 9,984 499.2 998.4 $1,111,748.35

viii. Excess emissions report 2 2 4 832 3,328 166.4 332.8 $370,582.79

ix. Startup, shutdown, malfunction 

report d2 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 4 832 3,328 166.4 332.8 $370,582.79

b. Plan activities 12 1 12 832 9,984 499.2 998.4 $1,111,748.35

c. Implement activities 12 1 12 832 9,984 499.2 998.4 $1,111,748.35

d. Maintain record system for material 

used 20 1 20 832 16,640 832 1,664 $1,852,913.92
16

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) 

Management 

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 e0.5 365 182.5 832 151,840 7,592 15,184 $16,907,839.52

ii. Compliance calculation f2 12 24 832 19,968 998.4 1,996.8 $2,223,496.71

f. Time to train personnel 10 1 10 832 8,320 416 832 $926,456.96

g. Store, file, and maintain records g2 12 24 832 19,968 998.4 1,996.8 $2,223,496.71

h. Retrieve records/reports 1 12 12 832 9,984 499.2 998.4 $1,111,748.35

Subtotal for Recordkeeping Requirements 287,518.40

Total Annual Burden and Cost (rounded) 322,467 $31,223,994

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 $121.44 ($57.83 + 110%), Technical $100.23 ($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 hours.

c

 We assume that each respondent will take 6 hours two time per year to write semiannual report.

d

 It is estimated that 25 percent of facilities use add-on controls submit startup, shutdown, and malfunction report once per year.

e We assumed that each respondent will take 0.5 hours each day to enter daily 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) 

Management 

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 compliance 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 24 832 19,968 998.4 1,996.8 $1,034,831.62

h. Excess emissions report 4 2 8 832 6,656 332.8 665.6 $344,946.12

i. Startup, shutdown, malfunction report 8 1 8 208 1,664 83.2 166.4 $86,235.96

Total Burden (rounded) 32,623 $1,470,160

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), 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 government employees. This ICR assumes that Clerical hours 

are 10% of Technical hours and Managerial hours 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.