SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Reinforced Plastic Composites Production (40 CFR part 63,
subpart WWWW) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Reinforced Plastic Composites Production (40 CFR part 63,
subpart WWWW) (Renewal), EPA ICR Number 1976.04, OMB Control Number
2060-0509

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Reinforced Plastic Composites (RPC) Production Operations and
Processes were proposed on August 2, 2001 (66 FR 40323), and promulgated
on April 21, 2003 (68 FR 19375).  These standards regulate fugitive
emissions from reinforced plastic composites (RPC) production operations
and processes resulting from hazardous air pollutants (HAPs) evaporating
from the resins, gel coats, and cleaning solvents.  The owner or
operator of a RPC manufacturing facility must control HAPs emissions by
either limiting the HAP content of materials used and using non-atomized
spray application in the manufacturing processes or by using an
enclosure and add-on control device.  This information is being
collected to assure compliance with 40 CFR part 63, subpart WWWW.

Owners and operators of affected sources are subject to the monitoring,
recordkeeping and reporting requirements of 40 CFR part 63, subpart A,
the General Provisions, unless specified otherwise in the regulation. 
This rule requires sources to submit initial notifications, conduct
performance tests if source is using an add-on control device, and
submit periodic compliance reports.  In addition, sources are required
to maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation if using an add-on control
device; any period during which the monitoring system is inoperative;
parametric monitoring data; system maintenance and calibration; and work
practices to demonstrate initial and ongoing compliance with the
regulation.

We have determined that there is approximately an average of 504
respondents (i.e., 488 existing and 16 new RPC manufacturing facilities)
subject to NESHAP, subpart WWWW.  In the previous ICR renewal, this
information was confirmed with the rule lead addressing this source
category at the Office of Air Quality Planning and Standards,
information available in the active ICR, and existing background
industry information gathered during the development of the rule and on
EPA databases.

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The Clean Air Act (ACT) provides authority to the Agency to establish
standards to control air pollution and to ensure compliance with
promulgated regulations through adequate recordkeeping and reporting by
the affected industries (i.e., respondents).  The regulations include:
the New Source Performance Standards (NSPS) under section 111 of the
Act; the National Emission Standards for Hazardous Air Pollutants
(NESHAP) which includes the original NESHAP standards and the more
recent Maximum Achievable Control Technology (MACT) or NESHAP-MACT
standards under section 112 of the Act; and the emission guidelines for
the designated types of incinerators under section 129 of the Act.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) are used
by regulatory agencies, the public and the regulated community for a
variety of reasons including the determination of the respondent’s
compliance status, analytical studies to demonstrate compliance trends,
and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting are also used to: 1) certify
compliance with the regulations; 2) determine the respondent’s
compliance with the designated emission limitation(s); 3) notify
regulatory agencies when a standard is violated; 4) evaluate continuous
compliance through the use of emission or operational parameter
monitors; and 5) ensure that plant personnel are following the required
procedures and are periodically trained as indicated.

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

3(a)  Non-duplication

The standards do not require the duplication in the collection and
reporting of information.  If the subject standards have not been
delegated, the information is sent directly to the appropriate
Environmental Protection Agency (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.

 

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 (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The estimated number of sources and assumptions for each category were
based on a review of the standard, information available in the active
ICR, existing industry information gathered during the development of
the rule and on EPA databases, and consultation with Keith Barnett, the
rule lead addressing this source category at the Office of Air Quality
Planning and Standards (OAQPS).

Any pertinent comments received since the last ICR renewal including
those submitted in response to the first federal register notice
announcing the renewal of this ICR, have been reviewed.  In this case,
no comments were received.  It has been determined that no further
consultations with industry are necessary to calculate the burden for
this renewal.  It should be noted that the Agency involved RPC
manufacturers, including 17 small firms, and their trade association in
the development of this NESHAP and the associated recordkeeping and
reporting requirements.

3(d)  Effects of Less Frequent Collection

The effect of less frequent collection would be a decrease in the margin
of assurance that facilities are achieving the emission reductions
mandated by the Clean Air Act through the promulgation of the applicable
regulations.  In addition, the likelihood of detecting the poor
operation and maintenance of control equipment decreases and the
detection of noncompliance becomes problematic.

3(e)  General Guidelines

The reporting and the recordkeeping requirements do not violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR part 1320, section 1320.5.  However, most NESHAP standards and a few
NSPS standards require records to be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the Permit
Program at 40 CFR part 70, 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 the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. 
If records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting non-compliance.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, chapter 1, part 2, Subpart B -
Confidentiality of Business Information (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 recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents SIC and NAICS Codes

Respondents are owners or operators of RPC manufacturing facilities. 
The following processes and operations constitute RPC manufacturing:
closed mold and open mold fiberglass manufacturing; resin and gel coat
mixing; resin and gel coat application equipment cleaning; and resin and
gel coat storage.  The Standard Industrial Classification (SIC) code(s)
and corresponding North American Industry Classification System (NAICS)
for the respondents are listed below.



Category	SIC 

code	NAICS code	Examples of regulated entities

Industry

	3087

3084

3089

3088

3089

3999

3281

3713

3716

3792	325991

326122

326191

326199

327991

336211

336213

336214	Reinforced plastic composites production facilities that
manufacture and/or repair intermediate and/or final products using HAP
containing thermoset resins and gel coats.

Federal Government



	Federally owned facilities that manufacture and/or repair intermediate
and/or final products using HAP containing thermoset resins and gel

coats.



 	This table is not meant to be exhaustive, but rather provides a guide
for readers regarding the entities likely to be regulated by this
standard.  To determine whether the standard applies to a particular
entity, review the applicability provisions in the standard.

4(b)  Information Requested

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Wet-Formed Fiberglass Mat Production (40 CFR part 63, subpart
WWWW).

	A source must make the following reports:

Notification Reports

Initial notification requirements	63.9(b)(1)

Notification of compliance status when a source becomes subject to the
standard	63.9(h), 63.5755(a)

Notification that source is subject to special compliance requirements,
if applicable	63.9(d)

Notification of performance test   SEQ CHAPTER \h \r 1 	63.7(b),
63.5755(a)

Rescheduled of performance test	63.7(b)(2)

Demonstration of continuous monitoring system	63.9(g), 63.5755(a)

Change in information already provided	63.9(j)

Request for an extension of compliance with relevant standard	63.9(c)



Reports

Application for approval of the construction or reconstruction of a new
major affected source, or reconstruction of a major affected source
63.5(6)(d)

Performance test results	63.10(d)(2),

63.5755

Startup, shutdown and malfunction plan	63.6(e)(3), 63.5758(d)

Periodic startup, shutdown and malfunction reports	63.10(d)(5)(i),
63.5758

Progress reports for compliance extension (if applicable)	63.6(i)  SEQ
CHAPTER \h \r 1 

Semiannual compliance reports 	63.5758(b-c)



	A source must keep the following records:

Recordkeeping

Startup, shutdown and malfunction plan	63.6(e)(3)

All reports and notifications	63.10(b)(1)

Records of startup, shutdown, and malfunction of process equipment
63.10(b)(2)(i), (iv), (v)

Records of malfunctions of air pollution control equipment
63.10(b)(2)(ii)

Any applicability determination that demonstrates why owner or operator
believes source is unaffected	63.10(b)(3)

Records of maintenance of air pollution control equipment
63.10(b)(2)(iii)

Records of flow monitoring system performance evaluations, malfunctions,
calibrations, and adjustments	63.10(b)(2)(vi), (vii), (viii), (ix), (x),
(xi), 63.10(c)

Documentation required for waiver of recordkeeping or reporting
requirements (if applicable)	63.10(b)(2)(xii)

Documentation of initial notifications	63.10(b)(2)(xiv)

Five-year retention of records	63.10(b)(1),   SEQ CHAPTER \h \r 1 

63.5764(b)



	Electronic Reporting

At the present, many respondents to Clean Air Act standards use
monitoring equipment that automatically records parameter data. 
Although personnel at the affected facility must evaluate the data, this
internal automation has significantly reduced the burden associated with
monitoring and recordkeeping at the 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.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

Adjust the existing ways to comply with any previously applicable
instructions and requirements.

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

Transmit, or otherwise disclose the information.



Regulatory agencies, to the extent possible, are relying more on
automated techniques such as electronic submissions of reports, and are
improving their tracking systems and database systems to enhance the use
of these techniques.  However, electronic reporting systems are still 

not widely used.  At this time, it is estimated that approximately 10
percent of the respondents use electronic reporting.

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

5(a)  Agency Activities 

EPA conducts one or more of the following activities in connection with
the acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).



5(b)  Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a
partial compliance evaluation, full compliance evaluation or inspection,
or through an off-site review of compliance monitoring records and
reports.  Evaluation reports and inspection results are maintained by
the Agency or delegated authority.

The results of these evaluations are entered into the AIRS Facility
Subsystem (AFS) which is operated and maintained by EPA's Office of
Compliance.  AFS is EPA’s database for the collection, maintenance,
and retrieval of compliance data for approximately 125,000 industrial
and government-owned facilities.  EPA uses the AFS for tracking air
pollution compliance and enforcement by local and state regulatory
agencies, EPA regional offices and EPA headquarters.  The EPA and its
delegated authorities can retrieve and analyze the data.

5(c)  Small Entity Flexibility

The majority of the existing facilities subject to this NESHAP are
classified as small businesses under the Small Business Administration
definition (750 or fewer company employees.)  However, the impact on
small businesses was accounted for in the development of the regulation.
 In the final rule, EPA has provided the maximum degree of flexibility
to minimize impacts on small businesses by providing several different
compliance options, several of which require a minimum amount of
recordkeeping and reporting requirements.  Small entities that would be
subject to the regulation would not be systematically impacted more than
larger entities.  Although the recordkeeping requirements are the same
for small and large businesses, EPA considers these requirements the
minimum needed to ensure compliance and, therefore, cannot reduce them
further for small businesses.  Thus, EPA does not expect that any
affected source, including small businesses, will experience adverse
impacts due to the reporting and recordkeeping requirements of this
rule. In the Economic Impact Analysis of the Final Reinforced Plastics
NESHAP, 78 percent of the parent companies affected by proposed action
were estimated to be small entities as defined by the Small Business
Administration. The Agency assumes that 78 percent of the 504 facilities
affected by this ICR, or 393 facilities, are small entities.

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 Reinforced Plastic Composites Production (40 CFR Part 63,
Subpart WWWW) (Renewal), attached.

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. 
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 respondent burden is shown in Table 1.  The labor hours in Table 1
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	$97.46   ($46.41 + 110%)

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 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% to
account for the benefit packages available to those employed by private
industry.

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

The only costs to the regulated industry resulting from information
collection activity required by the subject standard are operating and
maintenance and labor costs.  There are no capital/startup costs.  The
capital/startup costs are one-time costs when a facility becomes subject
to the regulation.  This is based on the assumption that all existing
sources are in compliance with initial rule requirements and the
assumption that the monitoring devices are integral parts of the control
devices necessary to determine whether these are operating properly. 
The annual operation and maintenance (O&M) costs are the ongoing costs
to maintain the continuous emission monitors and other costs such as
file storage, photocopying and postage.  

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

The total annualized operation and maintenance cost to industry over the
three-year period of this ICR is $22,000 (rounded).  Based on the
assumptions discussed above, the only costs to industry result from
other types of operation and maintenance costs, not related to operation
of the monitoring equipment, which include file storage, photocopying
and postage.  We have estimated that file storage and photocopying costs
per response are estimated at $12.50 per hour of clerical labor.  First
class postage is estimated at $7.63 per response for mailing to
regulatory agencies.  The estimated operation, maintenance, and purchase
of services costs averaged over the first 3 years are expected to be
$22,000 (rounded) based on 1,077 responses and an average of one hour of
clerical work per response for storage and photocopying.

6(c)  Estimating Agency Burden and Costs

The only costs to the Agency are those 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 and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $125,414 (rounded).  This cost is based on the average
hourly labor rate as follows:

Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Annual Burden and Cost
to The Federal Government:  NESHAP for Reinforced Plastic Composites
Production (40 CFR Part 63, Subpart WWWW) (Renewal), attached.

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

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 Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	16	488	0	0	488

2	16	504	0	0	504

3	16	520	0	0	520

Average	16	504	0	0	504

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 504.

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

Notification of compliance status	16	1	0	16

Notification/application of construction	16	1	0	16

Notification of actual startup 	16	1	0	16

Notification of performance test and test plan	2	1.2	0	2.4

Report of performance test results 	2	1.2	0	2.4

Report of exceedances	100.8	2	0	201.6

Report of no exceedances	403.2	2	0	806.4

Report of startup, shutdown, malfunction 	16	1	0	16

Total



1,076.8



The number of Total Annual Responses, 1,077 (rounded), is shown in
column E.

The total annual labor hours are 17,740 (rounded).  The total annual
labor cost may be found in Table 1: Annual Respondent Burden and Cost:
NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63,
Subpart WWWW) (Renewal), attached.

The average annual Agency burden and cost over next three years is shown
in Table 2: Annual Burden and Cost to the Federal/State Government:
NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63,
Subpart WWWW) (Renewal).

6(e)  Bottom Line Burden Hours 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.

(i) Respondent Tally

The total annual labor costs are $1,432,143 (rounded).  Details
regarding these estimates may be found in Table 1: Annual Respondent
Burden and Cost: NESHAP for Reinforced Plastic Composites Production (40
CFR Part 63, Subpart WWWW) (Renewal).  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 16 hours per response.

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup
vs. Operation and Maintenance (O&M) Cost.

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years is
shown in Table 2: Annual Burden and Cost to the Federal/State
Government: NESHAP for Reinforced Plastic Composites Production (40 CFR
Part 63, Subpart WWWW) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in burden from the most recently approved ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 16 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, disclose, or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; to 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; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
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’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2008-0432. 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
Enforcement and Compliance Docket and Information Center Docket is (202)
566-1514.  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 Office for EPA. Please include
the EPA Docket ID Number EPA-HQ-OECA-2008-0432 and OMB Control Number
2060-0509 in any correspondence.

Part B of the Supporting Statement

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

Table 1:  Annual Respondent Burden and Cost:  NESHAP for Reinforced
Plastic Composites Production 

(40 CFR Part 63, Subpart WWWW) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A







	

2.  Survey and Studies	

N/A







	

3.  Acquisition, Installation,         and Utilization of  Technology
and  Systems	

/A	

	

	

	

	

	

	





4.  Reporting Requirements











  A.  Read instructions:











     i.  Facilities with 4 groups of           operations	

12	

1	

12	

14.9	

178.8	

8.94	

17.9	

$16,600.29

  

     ii.  Facilities with 5 groups of          operations             	

13	

1	

13	

1.1	

14.3	

0.72	

1.43	

1,328.05



   B.  Required activities:











   Sources with add-on controls











     i.  Initial performance test  c    	

320	

1	

320	

2	

640.0	

32.0	

64.0	

59,416.32



     ii.  Repeat of performance test	

320	

1	

320	

0.4	

128.0	

6.4	

12.8	

11,883.26



     iii.  Operation, maintenance,          monitoring plan	

40	

1	

40	

2	

80.0	

4.0	

8.0	

7,427.04



     iv.  Startup, shutdown,                   malfunction plan	

20	

1	

20	

2	

40.0	

2.0	

4.0	

$3,713.52

  

     v.  Monitoring of operating            parameters and equipment:  d


Included in 5E









  C.  Gather Existing Information	

Included in 5D, 5E









  D.  Write report  a, c 











     i.  Notification of compliance        status  	

4	

1	

4	

16	

64.0	

3.2	

6.4	

$5,941.63



     ii.  Notification of                          construction/
reconstruction  a	

2	

1	

2	

16	

32.0	

1.6	

3.2	

$2,970.82



     iii.  Notification of actual               startup	

2	

1	

2	

16	

32.0	

1.6	

3.2	

$2,970.82



     iv.  Notification of                         performance test 	

2	

1	

2	

2	

4	

0.2	

0.4	

$371.35



     v.  Reports of performance            test results	

Included in 4B









     vii.  Report of exceedances  f     	

16	

2	

32	

100.8	

3,225.6	

161.3	

322.6	

$299,461.90



     viii.  Report of no exceedances	

8	

2	

16	

403.2	

6,451.2	

322.6	

645.1	

$598,919.55



     ix.  Startup, shutdown,           

     malfunction report  g	

2	

1	

2	

16	

32.0	

1.6	

3.2	

$2,970.82



5.  Recordkeeping Requirements











  A.  Read instructions	

Included in 4A









  B.  Plan activities	

Included in 4B









  C.  Implement activities	

Included in 4B









  D.  Develop record system                (spreadsheets):  h

	 

     i.  System for low HAP resin	4	1	

4	

14	

56.0	

2.8	

5.6	

$5,198.93

   

     ii.  System for work practices	1	1	

1	

16	

16.0	

0.8	

1.6	

$1,485.41

   

     iii.  System for add-on control       devices	2	1	

2	

2	

4.0	

0.2	

0.4	

$371.35



  E.  Time to enter and transmit all   information into record system  h

	  

     i.  Enter information on low           HAP resin	

10	

1	

10	

396	

3,960	

198.0	

396.0	

$367,638.48



     ii.  Enter information on work        practices and operating      
           parameters	

N/A







  F.  Develop operator training         course and keep records of      
     operators taken it	

10	

1	

10	

16	

160	

8.0	

16.0	

$14,854.08



  G.  Time to train personnel:	



   

     i.  Small facilities (less than           100 employees)	

2	

1	

2	

13.1	

26.2	

1.3	

2.6	

$2,430.53

	

0.4	

1	

0.4	

413.3	

165.3	

8.3	

16.6	

$15,348.26

  

     ii.  Medium facilities (100-250      employees)	

4	

1	

4	

1.8	

7.2	

0.4	

0.7	

$671.48

	

0.8	

1	

0.8	

55.4	

44.32	

2.2	

4.4	

$4,109.98

   

     iii.  Large facilities (more than       250 employees)	

8	

1	

8	

1.1	

8.8	

0.4	

0.8	

$813.93

	

1.6	

1	

1.6	

35.3	

56.5	

2.8	

5.7	

$5,245.04



  H. Time for audits	

N/A	

	

	











TOTAL LABOR  BURDEN AND COST  	

	

	

	

	

15,426.2	

771.3	

1,542.6	

$1,432,142.83



TOTAL LABOR HOURS (Rounded)	

	

	

	

	

17,740	

$1,432,143



Assumptions:

a  There is an average of 488 existing reinforced plastic composites
facilities (or RPC) subject to NESHAP subpart WWWW.  We have assumed
that there will be an average of 16 new RPC facilities each year over
the three year period of this ICR of which 93 percent (ir 14.9) will
consist of facilities with 4 groups of operations and 7 percent of
facilities with 5 groups of operations.  There is an average of 504
existing respondents per year over the next three year period of this
ICR.  

b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 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% to
account for the benefit packages available to those employed by private
industry.

c    SEQ CHAPTER \h \r 1 New respondents have to comply with the initial
rule requirements including notifications and performance tests.  We
have assumed that two new respondents per year will install add-on
controls equipment and therefore, will be require to conduct an initial
performance test.  We have assumed that performance tests are repeated
by 20 percent of the respondents.

d Monitoring and recordkeeping of operations for respondents with
enclosures and add-on control devices include: 1) specific operating
parameters for each control device established during the performance
test, 2) start-up, shutdown, and malfunctions of equipment,  and 3) work
practices.

e Monitoring and recordkeeping of operations for respondents that comply
by limiting the HAP content of their raw materials include: 1)
monitoring and recording in a spreadsheet the monthly consumption of
material and the weighted-average HAP content over the past 12 months,
and 2) work practices.  However, if all the materials in an operation
meet the HAP content limit, then each respondent would need only to
record HAP content and would not need to track monthly consumption or
record the computations.    SEQ CHAPTER \h \r 1 For open molding and
centrifugal casting operations, respondents would also have the option
of averaging among thirteen different processes (open molding) and two
different processes (centrifugal casting to calculate the monthly
average of the actual and allowable emissions for the combined open
molding and centrifugal casting operations.  

f  We have assumed that approximately 80 percent of the 504 existing
respondents (403.2) will report no excess emissions twice a year and
approximately 20 percent (100.8) will report no excess emissions twice a
year.  

g  We have assumed that  all RPC facilities with add-on controls (12
existing and 2 new each year or an average of 16) will have at least one
startup, shutdown or malfunction (SSM) that is not managed according to
the SSM plan.

h    New respondents (16) have to develop a record system.  In addition,
existing RPC facilities have to record operational data.  In general,
the following monitoring is required:  1) facilities with open molding
and/or centrifugal casting operations (354 existing and 14 new each year
or an average of 396 per year) would have to record for low HAP resins;
2) facilities with add-on controls (12 existing and 2 new or an average
of 16 RPCs per year) would have to record add-on control devices
operating parameters; and 3) all facilities (504) need to keep records
of its work practices.  Since operating parameters for control equipment
and standard work practices are already monitored by industry for other
purposes, we are not attributing these burdens to the rule.

i    We have assumed that he amount of time it takes a respondent to
train its employees would vary with the number of employees at its
facility.  We have also   SEQ CHAPTER \h \r 1 assumed that the
distribution in size of the new respondents would be identical to that
of the existing PRC universe.  Therefore, we have assumed that 82
percent of the respondents would be small business (i.e., 413.3 RPCs
existing and 13.1 new RPC per year), 11 percent (i.e. 55.4 existing RPCs
and 1.8 new RPCs per year), would be medium business, and 7 percent
(i.e., 35.3 existing RPCs and 1.1 new RPCs) are large business. 
Furthermore, we have assumed that respondents will be providing full
training to new employees only.  Therefore, it will take existing
respondents to train its new employees 20 percent of the time it takes
new respondents to train all employees, assuming the same size business.
 

Table 2:  Annual Burden and Cost for the Federal Government:  NESHAP for
Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW)
(Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year  a

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



Notification of  applicability  a 	

2	

1	

2	

2	

4.0	

0.2	

0.4	

$186.48



Notification of intent to construct a major source and review
application	

12	

1	

12	

16	

32.0	

10.2	

3.2	

$2,300.04



Notification of start of construction	

2	

1	

2	

16	

32.0	

1.6	

3.2	

$1,491.87



Notification of actual startup 	

2	

1	

2	

16	

32.0	

1.6	

3.2	

$1,491.87



Notification of initial performance test and test plan	

12	

1.2	

14.4	

2	

28.8	

1.4	

2.8	

$1,343.14



Report of performance test results including operating parameters 	

12	

1.2	

14.4	

2	

28.8	

1.4	

2.8	

$1,343.14



Notification of compliance status	

2	

1	

2	

16	

32.0	

1.6	

3.2	

$1,491.87



Review reports of excess emissions  c	

4	

2	

8	

100.8	

806.4	

40.3	

80.6	

                     $37,593.15



Review reports of no excess 

emissions  c	

2	

2	

4	

403.2	

1,612.8	

80.6	

161.3	

$75,188.56



Review of startup, shutdown, malfunction report  d	

4	

1	

4	

16.0	

64.0	

3.2	

6.4	

$2,983.74



Subtotal Burden and Cost	

	

	

	

	

2,672.8	

133.64	

267.3	

$125,413.86



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	

3,082	

$125,414



Assumptions:

a   There is an average of 488 existing reinforced plastic composites
facilities (or RPC) subject to NESHAP subpart WWWW.  We have assumed
that there will be an average of 16 new RPC facilities each year over
the three year period of this ICR.  Therefore, there is an average of
504  existing respondents per year over the next three year period of
this ICR.  We have assumed that 82 percent (or 413.3) of the existing
RPC facilities are small business, 11 percent (or 55.4) are medium size
facilities and 7 percent (or 35.3) are large facilities.  Furthermore,
we have assumed that 93 percent (or 14.9) of the new RPC facilities will
consist of an average of four groups of operations and 7 percent (or
1.1) will consist of five groups of operations.

b   This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) ”2005 General Schedule“ which
excludes locality rates of pay.  

c   We have assumed that approximately 80 percent of the 505 respondents
(or 404) will report no excess emissions twice a year and approximately
20 percent (or 101) will report no excess emissions twice a year.

d   We have assumed that all RPC facilities with add-on controls (12
existing and 2 new each year or an average of 16) will have at least one
startup, shutdown, or malfunction occurrence that is not managed
according to the plan.

  

  Economic Analysis of the Final Reinforced Plastics NESHAP, U.S. EPA,
August 2002, EPA-452/R-02-007

 PAGE  19 

