STANDARD
FORM
83
SUPPORTING
STATEMENT
ICR
NO.
2044.01
­­
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS:
PLASTIC
PARTS
AND
PRODUCTS
SURFACE
COATING
(
40
CFR
PART
63,
SUBPART
PPPP)

U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
North
Carolina
27711
August
2001
1
PART
A
OF
THE
SUPPORTING
STATEMENT:
JUSTIFICATIONS
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collected
The
title
of
this
information
collection
request
(
ICR)
is
"
Recordkeeping
and
Reporting
Requirements
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP):
Plastic
Parts
and
Products
Surface
Coating."
This
is
a
new
ICR
that
has
been
assigned
Environmental
Protection
Agency
(
EPA)
ICR
No.

2044.01.

(
b)
Short
characterization/
abstract
The
proposed
standards
would
regulate
organic
hazardous
air
pollutants
(
HAP)
emissions
resulting
from
the
surface
coating
of
plastic
parts
and
products.
The
majority
of
organic
HAP
emissions
from
a
facility
engaged
in
plastic
parts
and
products
surface
coating
operations
can
be
attributed
to
the
application
of
the
coating,
drying,
and
curing.
The
organic
HAP
that
are
used
in
coatings
as
solvents
and
carriers
are
volatilized
and
emitted
during
the
coating
application
process
and
while
the
coated
parts
are
drying
and
curing
in
flash­
off,
drying,
and
curing
areas.

Each
owner
or
operator
of
a
source
affected
by
the
proposed
standards
would
be
required
to
submit
an
initial
notification
that
the
source
is
subject
to
the
standard.
Each
respondent
would
submit
semiannual
compliance
reports.
Additional
records
and
notifications
would
depend
on
how
the
owner
or
operator
chooses
to
comply
with
the
standards.
The
owner
or
operator
of
a
plastic
parts
and
products
surface
coating
operation
that
is
subject
to
these
proposed
standards
would
be
required
to
control
organic
HAP
by
either
limiting
the
organic
HAP
content
of
every
individual
material
used
in
the
coating
operations
(
compliant
2
material
option),
demonstrating
that
the
source­
wide
organic
HAP
emissions
meet
the
emission
limit
(
emission
rate
without
add­
on
controls
option),
or
by
using
an
emission
capture
and
control
system
to
demonstrate
that
the
source­
wide
emissions
meet
the
emission
limitation
(
emission
rate
with
add­
on
controls
option).

The
EPA
expects
that
20
percent
of
respondents
would
be
able
to
comply
by
limiting
the
organic
HAP
content
of
every
material
used
in
the
surface
coating
operations
(
compliant
material
option).
These
respondents
would
keep
records
of
the
materials
used
and
their
HAP
content
to
demonstrate
compliance.
The
EPA
expects
that
80
percent
of
respondents
would
comply
by
demonstrating
that
the
source­
wide
HAP
emissions
meet
the
emission
limitation
(
emission
rate
without
add­
on
controls
option
or
emission
rate
with
add­
on
controls
option).
Respondents
would
monitor
and
record
(
typically
in
a
spreadsheet)
the
monthly
consumption
of
materials,
and
their
HAP
contents,
and
calculate
the
weighted­
average
organic
HAP
emissions
over
the
most
recent
12
months.

Nineteen
of
these
existing
facilities
(
about
10%
of
facilities)
already
have
add­
on
controls
and
would
use
the
emission
rate
with
add­
on
controls
option.
They
would
keep
the
same
records
as
respondents
using
the
emission
rate
without
addon
controls
option.

In
addition,
respondents
who
choose
to
use
an
emission
capture
and
control
system
would
be
required
to
develop
a
startup
shutdown,
and
malfunction
plan
and
a
work
practice
plan
and
submit
a
notification
for
and
conduct
the
initial
add­
on
control
device
performance
test.
The
EPA
expects
one
new
facility
will
start
up
per
year
and
will
comply
by
using
the
emission
rate
without
add­
on
controls
option.

All
facilities
would
be
required
to
submit
notifications
and
reports
to
demonstrate
compliance
with
the
rule.
These
include
3
one­
time
reporting
such
as
the
notification
of
compliance
status
and
semi­
annual
compliance
reports.

2.
Need
for
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
EPA
needs
this
information
to
ensure
that
HAP
emissions
are
reduced
in
plastic
parts
and
products
surface
coating
operations.
The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA)
to
regulate
emissions
of
the
HAP
listed
in
section
112(
b)
of
the
CAA.
The
major
HAP
identified
by
EPA
as
being
emitted
from
these
operations
include
toluene,
methyl
ethyl
ketone
(
MEK),
xylenes,
and
methyl
isobutyl
ketone
(
MIBK).

In
the
Administrator's
judgment,
HAP
emissions
from
plastic
parts
and
products
surface
coating
operations
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Consequently,
NESHAP
for
this
source
category
has
been
developed
and
are
being
proposed.

Section
114
of
the
CAA
allows
the
Administrator
to
require
inspections,
monitoring,
and
entry
into
facilities
to
ensure
compliance
with
a
section
112
emission
standard.

Section
114(
a)(
1)
specifically
states:

"
The
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source...
who
is
subject
to
any
requirement
of
this
Act...
on
a
one­
time,
periodic
or
continuous
basis
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;

(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
4
(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require."

Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
sources
subject
to
the
standard
and
to
ensure
that
the
standard,
which
is
based
on
a
maximum
achievable
control
technology
(
MACT),
is
being
achieved.

(
b)
Practical
Utility/
Users
of
Collected
Information
The
information
would
be
used
by
EPA
to
ensure
that
the
requirements
of
the
proposed
plastic
parts
and
products
surface
coating
NESHAP
are
implemented
and
are
complied
with
on
a
continuous
basis.
Records
and
reports
would
be
necessary
to
enable
EPA
to
identify
facilities
that
may
not
be
in
compliance
with
the
proposed
emission
limitations.
Based
on
reported
information,
EPA
would
decide
which
plastic
parts
and
products
surface
coating
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected.
The
records
would
indicate
to
EPA
whether
owners
and
operators
are
correctly
performing
the
required
calculations
to
demonstrate
compliance.
If
owners
or
operators
use
an
add­
on
control
device,
the
records
will
also
indicate
whether
the
add­
on
control
device
is
being
properly
operated
and
maintained.

To
minimize
burdens,
much
of
the
information
EPA
would
need
to
determine
compliance
would
be
recorded
and
retained
on­
site
at
the
facility.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
not
need
to
be
routinely
reported
to
EPA.
In
addition,
in
many
cases
EPA
has
selected
parameters
for
monitoring
that
are
readily
available
or
are
already
monitored
by
the
industry
for
other
purposes.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
5
(
a)
Nonduplication
Facilities
that
are
subject
to
the
NSPS
for
Surface
Coating
of
Plastic
Parts
for
Business
Machines
(
40
CFR
part
60,

subpart
TTT)
will
be
subject
to
the
requirements
of
both
the
subpart
TTT
NSPS
and
the
proposed
plastic
parts
and
products
surface
coating
NESHAP,
but
they
will
not
be
subject
to
conflicting
requirements
between
the
two
standards.
Subpart
TTT
applies
to
sources
constructed
after
January
8,
1986
that
coat
plastic
parts
for
use
in
the
manufacture
of
business
machines.

Subpart
TTT
establishes
volatile
organic
compound
(
VOC)
emission
limitations
for
specific
types
of
coatings
(
e.
g.,
prime
coats,

color
coats,
texture
coats),
whereas
the
proposed
plastic
parts
and
products
surface
coating
NESHAP
will
regulate
HAP
emissions.

The
burden
requested
for
this
NESHAP
requires
similar
information
as
subpart
TTT
NSPS.
Facilities
complying
with
the
NSPS
are
required
to
calculate
the
mass
of
VOC
emitted
per
volume
of
coating
solids
applied
for
each
type
of
coating
used
(
i.
e.,

prime
coats,
color
coats,
texture
coats)
on
a
monthly
basis.
To
do
this,
facilities
must
determine
the
composition
of
each
coating
either
by
testing
or
by
using
information
provided
by
the
supplier
or
manufacturer.
Similar
information
is
required
by
this
proposed
NESHAP.
Thus,
facilities
that
are
complying
with
both
standards
will
be
able
to
streamline
their
testing
and
recordkeeping
requirements.
In
addition,
both
the
NSPS
and
the
proposed
plastic
parts
and
products
surface
coating
NESHAP
require
reporting
on
a
semiannual
basis.
Facilities
can
submit
a
single
report
with
the
necessary
information
to
demonstrate
compliance
with
both
standards.

In
addition,
some
facilities
that
are
subject
to
the
Aerospace
Manufacturing
and
Rework
Facilities
NESHAP
(
40
CFR
part
60,
subpart
GG)
will
be
subject
to
the
requirements
of
both
the
subpart
GG
NESHAP
and
the
proposed
plastic
parts
and
products
surface
coating
NESHAP.
The
aerospace
NESHAP
establishes
HAP
and
6
VOC
emission
limitations
for
aerospace
manufacturing
and
rework
facilities
that
produce
or
repair
aerospace
vehicles
(
e.
g.,

airplanes,
helicopters,
space
vehicles)
or
vehicle
parts.
The
aerospace
NESHAP
applies
only
to
parts
and
assemblies
that
are
critical
to
the
aerospace
vehicle's
structural
integrity
or
flight
performance.
Therefore,
the
possibility
exists
that
some
facilities
who
coat
both
aerospace
vehicle
parts
and
other
plastic
parts
will
be
subject
to
the
requirements
of
both
the
aerospace
NESHAP
and
the
plastic
parts
and
products
surface
coating
NESHAP.

The
burden
requested
for
this
NESHAP
requires
similar
information
as
subpart
GG.
Facilities
complying
with
subpart
GG
are
required
to
demonstrate
that
the
mass
of
HAP
per
volume
of
coating
is
below
the
coating­
specific
limits.
To
do
this,

facilities
will
be
able
to
use
coating
composition
information
required
by
this
proposed
NESHAP.
Therefore,
facilities
that
are
complying
with
both
standards
will
be
able
to
streamline
their
gathering
of
coating
data.
Furthermore,
both
subpart
GG
and
the
proposed
plastic
parts
and
products
surface
coating
NESHAP
require
semiannual
reporting
so
that
facilities
can
submit
one
report
to
demonstrate
compliance
with
both
standards.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,

a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
the
Office
of
Management
and
Budget
The
EPA
solicited
public
comments
on
the
need
for
this
information,
the
accuracy
of
the
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden
in
the
proposed
rule
announced
in
the
Federal
Register.
In
the
final
7
rule
EPA
will
respond
to
any
comments
from
the
public
on
these
information
collection
requirements.

(
c)
Consultations
The
EPA
has
minimized
the
impact
of
the
proposed
rule
on
small
entities
throughout
the
rule
development
process.

Representatives
of
small
entities
have
participated
in
stakeholder
meetings
held
during
the
last
three
years.
Further,

EPA
is
applying
the
minimum
level
of
control
to
affected
sources
allowed
by
the
Clean
Air
Act.
The
EPA
is
proposing
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
low­

HAP
coatings
(
i.
e.,
pollution
prevention)
that
meet
the
proposed
standards
instead
of
using
add­
on
capture
and
control
systems.

This
method
of
compliance
can
be
demonstrated
with
minimum
burden
by
using
purchase
and
usage
records.
No
testing
of
materials
would
be
required,
as
the
facility
owner
could
show
that
the
coatings
meet
the
emission
limits
by
providing
formulation
data
supplied
by
the
manufacturer,
which
is
typically
already
available
to
facilities.

(
d)
Effects
of
Less
Frequent
Collection
Failure
to
require
periodic
reporting
of
HAP
emissions
would
prevent
the
Administrator
from
determining
if
a
source
is
in
compliance
with
the
NESHAP.
If
the
reports
and
data
parameters
were
collected
less
frequently,
EPA
would
not
be
able
to
identify
potential
compliance
problems
in
a
timely
fashion.
Semiannual
reports
are
required
so
that
EPA
can
ensure
that
timely
corrective
action
is
being
taken.

Respondents
who
choose
to
use
an
emission
capture
and
control
system
would
submit
a
control
system
performance
test
report,
including
operating
limits
for
enclosure
volumetric
8
flowrate
and
enclosure
opening
pressure
drop
across
the
enclosure
openings.
The
operating
limits
ensure
that
the
system
maintains
a
constant
capture
efficiency.
Respondents
would
also
be
required
to
establish
operating
limits,
monitor,
and
keep
records
of
specific
operating
parameters
for
each
control
device
to
ensure
the
control
device
continues
to
be
well­
operated
to
achieve
HAP
reduction,
and
report
any
deviations
from
these
operating
parameters.
If
this
information
were
collected
less
frequently,
the
main
consequence
could
be
decreased
performance
of
emission
control
measures
due
to
lack
of
regular
inspection,

which
could
result
in
increased
HAP
emissions.

(
e)
General
Guidelines
This
information
collection
meets
the
Office
of
Management
and
Budget's
(
OMB)
general
guidelines
for
information
collections
and
therefore
does
not
require
justification
for
any
deviation
from
OMB's
general
guidelines.

(
f)
Confidentiality
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
EPA
policies
in
40
CFR
part
2,
subpart
B,
Confidentiality
of
Business
Information.

(
g)
Sensitive
questions
This
information
collection
does
not
request
any
information
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.

4.
The
Respondents
and
the
Information
Requested
9
(
a)
Respondents/
North
American
Industrial
Classification
System
and
Standard
Industrial
Classification
Codes
The
proposed
source
category
definition
includes
facilities
that
apply
coatings
to
plastic
parts
and
products.
In
general,

facilities
that
coat
plastic
parts
and
products
are
covered
under
the
Standard
Industrial
Classification
(
SIC)
and
North
American
Industrial
Classification
System
(
NAICS)
codes
listed
in
the
following
table.

REGULATED
CATEGORIES
AND
ENTITIES
Category
SIC
NAICS
Examples
of
potentially
regulated
entities
Industrial
2522
337214
Office
furniture,
except
wood
3086
32614,
32615
Plastic
foam
products
(
e.
g.
pool
floats,
wrestling
mats,
life
jackets)

3089
326199
Plastic
products
not
elsewhere
classified
(
e.
g.,
name
plates,
coin
holders,
storage
boxes,
license
plate
housings,
cosmetic
caps,
cup
holders)

3579
333313
Office
machines
3663
33422
Radio
and
television
broadcasting
and
communications
equipment
(
e.
g.,
cellular
telephones)

3714
336399
Motor
vehicle
parts
and
accessories
3799
336999
Transportation
equipment
not
elsewhere
classified
(
e.
g.,
snowmobile
hoods,
running
boards,
tractor
body
panels,
personal
watercraft
parts)

3841
339111,
339112
Medical
equipment
and
supplies
3949
33992
Sporting
and
athletic
goods
3993
33995
Signs
and
advertising
specialties
Category
SIC
NAICS
Examples
of
potentially
regulated
entities
10
3999
339999
Manufacturing
industries
not
elsewhere
classified
(
e.
g.,
bezels,
consoles,
panels,
lenses)

Federal,
State,
and
Local
Governments
Government
owned
or
operated
facilities
that
perform
plastic
parts
and
products
surface
coating
(
b)
Information
Requested
(
i)
Data
items,
including
recordkeeping
requirements:

Test
report.
Facilities
using
an
add­
on
control
device
will
be
required
to
establish
the
operating
range
for
monitored
parameters;
prepare
a
start­
up,
shutdown,
and
malfunction
plan;

and
submit
a
notification
of
performance
tests
and
an
initial
add­
on
control
device
performance
test
report.

Notification
reports.
The
owner
or
operator
of
each
facility
would
be
required
to
submit
an
initial
notification
report
that
the
source
is
subject
to
the
standard.
The
owner
or
operator
of
each
new
facility
would
be
required
to
submit
notifications
of
intent
to
construct,
construction
start
date,

anticipated
start­
up
date,
and
actual
start­
up
date.
All
new
and
existing
facilities
would
be
required
to
submit
a
notification
of
compliance
status
including
their
initial
compliance
demonstration.

Compliance
reports.
The
owner
or
operator
of
each
facility
would
be
required
to
submit
semiannual
compliance
reports.

Sources
with
deviations
would
be
required
to
provide
additional
detail
in
the
semi­
annual
compliance
report.

Work
practice
plan.
Facilities
using
an
add­
on
control
device
would
be
required
to
develop
a
work
practice
plan.
The
plan
would
include
site­
specific
requirements
such
as
storing
coatings
in
closed
containers,
transferring
materials
in
closed
systems,
minimizing
spills,
and
using
closed
mixing
vessels.
11
Records
and
Calculations.
Facilities
complying
with
the
emission
limitations
using
the
compliant
material
option
or
the
emission
rate(
with
or
without
add­
on
controls)
option
will
develop
a
recordkeeping
system
(
typically
a
spreadsheet)
and
enter
information
into
the
system.
The
EPA
expects
that
to
determine
HAP
content,
facilities
will
have
manufacturer's
formulation
data
for
materials
used
and
would
obtain
usage
data
from
purchasing
records.
Facilities
will
track
the
materials
used,
review
the
manufacturer's
formulation
data,
and
enter
information
from
the
formulation
data
into
the
spreadsheet.
In
addition,
the
facilities
using
the
emission
rate
(
with
or
without
add­
on
controls)
option
will
set
up,
run,
and
check
the
spreadsheet
calculations
used
to
determine
the
source­
wide
emission
rate.

(
ii)
Respondent
activities:
To
assemble,
submit,
and
store
the
data
items
necessary
to
submit
the
reports,
an
entity
would
typically
develop
a
spreadsheet
system
for
keeping
records.
The
EPA
expects
that
entities
will
gather
information
that
is
already
available.

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
A
list
of
Agency
activities
is
provided
in
tables
5
through
7
(
see
attachment
3).

(
b)
Collection
Methodology
and
Management
This
collection
of
information
does
not
require
the
use
of
automated
collection
techniques
because
of
the
relatively
small
number
of
respondents
affected.

(
c)
Small
Entity
Flexibility
12
The
EPA
does
not
expect
the
proposed
rule
to
adversely
affect
small
entities.
In
developing
the
proposed
regulation,

EPA
has
provided
the
maximum
degree
of
flexibility
to
minimize
impacts
on
small
businesses
by
providing
different
compliance
options,
including
options
that
require
a
minimum
amount
of
recordkeeping
and
reporting
requirements.

The
EPA
has
determined
that
50
of
the
131
firms,
or
38
percent
of
the
total,
affected
by
the
proposed
rule
may
be
small.
While
the
number
of
small
firms
appears
to
be
a
large
proportion
of
the
total
number
of
affected
firms,
the
small
firms
only
experience
11
percent
of
the
total
national
compliance
cost
of
$
13
million.
Of
the
50
affected
small
firms,
only
three
firms
are
estimated
to
have
compliance
costs
that
exceed
one
percent
of
their
revenues.
In
addition,
only
one
small
firm
is
estimated
to
have
compliance
costs
that
exceed
three
percent
of
its
revenues,

and
the
amount
of
the
exceedance
is
only
0.02
percent.
Finally,

while
there
is
a
difference
between
the
median
compliance
cost­
to­
sales
estimates
for
the
affected
small
and
large
firms
(
0.09
percent
compared
to
0.01
percent
for
the
large
firms),
no
adverse
economic
impacts
are
expected
for
either
small
or
large
firms
affected
by
the
rule.
Therefore,
the
affected
small
firms
are
not
disproportionately
affected
by
this
rule
as
compared
to
the
affected
large
firms.

Although
this
proposed
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities,
EPA
has
tried
to
reduce
the
impact
of
this
rule
on
small
entities
throughout
the
rule
development
process.
Representatives
of
small
entities
have
participated
in
stakeholder
meetings
held
during
the
3
years.
Further,
the
Agency
is
applying
the
minimum
level
of
control
to
affected
sources
allowed
by
the
CAA.
We
are
proposing
compliance
options
which
give
small
entities
flexibility
in
choosing
the
most
cost
effective
and
least
burdensome
alternative
for
their
operation.
For
example,
a
13
facility
could
purchase
and
use
low­
HAP
coatings
(
i.
e.,
pollution
prevention)
that
meet
the
proposed
standards
instead
of
using
add­
on
capture
and
control
systems.
This
method
of
compliance
can
be
demonstrated
with
minimum
burden
by
using
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.

For
purposes
of
assessing
the
impacts
of
the
plastic
parts
and
products
surface
coating
rule
on
small
entities,
small
entity
is
defined
as:
(
1)
a
small
business
that
has
less
than
500
or
1,000
employees,
depending
on
the
size
definition
for
the
affected
Standard
Industrial
Classification
(
SIC)
Code;
(
2)
a
small
governmental
jurisdiction
that
is
a
government
of
a
city,

county,
town,
school
district
or
special
district
with
a
population
of
less
than
50,000;
and
(
3)
a
small
organization
that
is
any
not­
for­
profit
enterprise
which
is
independently
owned
and
operated
and
is
not
dominant
in
its
field.
It
should
be
noted
that
companies
classified
under
24
different
SIC
codes
are
affected
by
the
proposed
rule,
and
the
small
business
definition
applied
to
each
industry
by
SIC
code
is
listed
in
the
Small
Business
Administration
(
SBA)
size
standards
(
13
CFR
121).
For
more
information
on
size
standards
for
particular
industries,

refer
to
the
economic
impact
analysis
memorandum
in
the
docket
(
Docket
No.
A­
99­
12).

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
businesses
and
large
businesses,
EPA
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

(
d)
Collection
Schedule
14
The
EPA
expects
one
new
facility
to
be
constructed
for
each
of
the
first
3
years.
The
EPA
assumes
that
because
compliance
is
not
required
until
year
3
for
existing
facilities,
existing
facilities
will
wait
until
year
3
to
begin
complying
with
the
requirements.

Year
1
for
new
and
existing
facilities
includes
the
one­
time
activity
of
reading
the
regulation.
It
also
includes
submitting
the
initial
notification
for
existing
sources
that
the
source
is
subject
to
the
standard.

New
major
sources
would
submit
the
following
one­
time
only
notifications:
intent
to
construct,
start
of
construction
date,

anticipated
start­
up
date,
and
actual
start­
up
date.
These
notifications
generally
would
be
submitted
within
60
days
of
the
activity.

In
year
1,
new
facilities
will
begin
training
their
personnel
regarding
the
use
of
low­
HAP
and
compliant
coatings
and
tracking
their
usage.
Existing
facilities
would
train
personnel
in
year
3.
Also
in
year
1,
new
facilities
would
begin
complying
with
the
organic
HAP
emission
limit
requirements,
developing
spreadsheets,
and
entering
data
as
described
in
section
4(
b).

For
the
burden
estimates,
it
is
assumed
that
new
facilities
will
comply
by
using
the
emission
rate
without
add­
on
controls
option.

In
year
2,
the
new
source
from
year
1
will
submit
the
notification
of
compliance
status
and
one
semiannual
report
and
the
new
facility
from
year
2
would
submit
all
initial
notifications.
There
are
no
activities
in
year
2
for
existing
sources.

In
year
3,
the
new
source
from
year
1
will
submit
two
semiannual
reports.
The
new
source
from
year
2
will
submit
the
notification
of
compliance
status
and
one
semiannual
report.
The
new
source
from
year
3
will
submit
all
initial
notifications.
In
year
3,
all
existing
facilities
will
plan
their
compliance
method
and
develop
a
recordkeeping
system
including
spreadsheets.
15
base
labor
rate
x
1.67
=
loaded
wage
rate
Facilities
with
add­
on
controls
would
develop
a
startup,

shutdown,
malfunction
plan
and
a
work
practice
plan;
submit
notification
of
intent
to
conduct
the
performance
test;
and
conduct
the
initial
add­
on
control
device
performance
test.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
EPA
expects
this
regulation
to
affect
202
existing
and
3
new
plastic
parts
and
products
surface
coating
facilities
over
the
first
3
years.
Tables
1
through
3
present
an
itemized
breakdown
of
the
reporting
and
recordkeeping
requirements
for
the
respondents
affected
by
these
standards.

(
b)
Estimating
Respondent
Costs
The
information
collection
activities
for
sources
subject
to
these
requirements
are
presented
in
tables
1
through
3.
The
total
cost
for
each
respondent
activity
includes
labor
costs,

capital/
start­
up
costs,
and
operating
and
maintenance
(
O&
M)

costs.

(
i)
Estimating
Labor
Costs.
Labor
rates,
on
a
per­
hour
basis,
are
taken
from
the
Bureau
of
Labor
Statistics
(
BLS)
web
site
(
http://
stats.
bls.
gov/
ecthome.
htm)
as
posted
for
March
2000.

The
base
labor
rates
are
$
27.38
for
technical,
$
41.64
for
management
personnel,
$
17.31
for
clerical
personnel.
The
labor
rates
include
fringe
benefits,
including
paid
leave,
insurance,

etc.
The
labor
rates
are
also
adjusted
by
an
overhead
and
profit
rate
of
167
percent.
Therefore,
the
total
loaded
wage
rates
are
calculated
by
the
following
equation:
16
Given
the
cost
overhead
adjustments,
the
final
total
loaded
wage
rates
are
$
45.74
for
technical,
$
69.54
for
management
personnel,

and
$
28.91
for
clerical
personnel.

(
ii)
Estimating
Capital/
Start­
up
Costs.
The
EPA
does
not
expect
any
capital/
start­
up
costs
for
facilities
to
add
controls.

There
are
19
existing
facilities
with
add­
on
controls
that
will
comply
with
the
emission
rate
with
add­
on
controls
option.

However,
EPA
does
not
anticipate
any
other
facilities
to
add
controls
to
comply
with
this
subpart.
The
19
existing
facilities
will,
however,
incur
a
capital
cost
of
$
7,000
to
purchase
enclosure
monitoring
equipment.
This
cost
is
based
on
a
vendor
estimate.
The
EPA
assumes
all
other
required
monitoring
devices
will
already
exist
at
these
facilities.
Monitors
for
the
required
control
device
operating
parameters
are
typically
purchased
with
the
control
device
and
would
already
be
in
use
at
existing
facilities.

For
the
purpose
of
this
subpart,
EPA
assumes
that
each
owner
or
operator
owns
a
computer
with
spreadsheet
software.

(
iii)
Total
O&
M
and
Purchase
of
Service
Costs.
The
total
annual
operating
and
maintenance
costs
were
calculated
based
on
estimated
photocopying
and
postage
costs
for
the
various
reports.

An
estimate
of
$
7.50
per
report
was
applied
to
the
numbers
of
reports
submitted
each
year.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
ICRs
are
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
ICRs.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
additional
operational
costs
would
be
incurred
by
the
Federal
Government.
Examination
of
records
to
be
maintained
by
the
respondents
would
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
17
and
enforcement
program
and,
therefore,
cannot
be
attributable
to
ICRs.

A
list
of
Agency
activities
that
are
attributable
to
this
ICR
is
provided
in
tables
5
through
7
(
see
attachment
3).

Labor
rates
for
the
Federal
employees
are
based
on
the
estimated
hourly
rates
of
$
39.62
for
technical
personnel
(
GS­
12,

Step
5);
$
57.92
for
management
personnel
(
GS­
15,
Step
5);
and
$
29.63
for
clerical
personnel
(
GS­
7,
Step
5).
These
values
include
a
1.67
multiplier
to
account
for
overhead
and
fringe
benefit
costs.

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

The
total
number
of
respondents
is
also
referred
to
as
the
respondent
universe.
The
respondent
universe
for
this
ICR
is
based
on
EPA's
plastic
parts
and
products
surface
coating
database.
The
database
was
populated
using
responses
from
a
section
114
survey
issued
in
1998.
The
industry
burden
is
calculated
for
202
existing
facilities.
Based
on
U.
S.
economic
census
data
for
representative
SIC
codes,
EPA
expects
one
new
facility
will
be
constructed
each
year.
The
EPA
expects
that
each
new
facility
will
comply
by
using
the
emission
rate
without
add­
on
controls
option,
because
this
option
is
more
flexible
than
the
compliant
material
option
and
because
add­
on
controls
are
generally
not
applicable
to
all
types
of
facilities
in
this
source
category.

Each
existing
facility
will
choose
to
comply
by
using
one
of
three
options:
compliant
material
option,
emission
rate
without
add­
on
controls
option,
and
emission
rate
with
add­
on
controls
option.
Of
the
202
existing
facilities,
EPA
expects
20
percent
(
40
facilities)
to
use
the
less
burdensome
compliant
material
option
because
some
of
the
existing
facilities
are
small,
use
fewer
materials,
and
will
be
able
to
use
only
low­
or
non­
HAP
18
materials.
The
remaining
162
existing
facilities
will
choose
the
emission
rate(
with
or
without
add­
on
controls)
option
and
will
develop
a
recordkeeping
system
(
typically
a
spreadsheet)
to
track
material
usages
and
calculate
emissions.
Of
the
162
facilities
using
the
emission
rate
(
with
or
without
add­
on
controls)
option,

EPA
expects
19
to
use
the
emission
rate
with
add­
on
controls
option
because
19
of
the
existing
facilities
already
have
controls
in
place.
The
remaining
143
facilities
will
use
the
emission
rate
without
add­
on
controls
options
to
comply.
Agency
personnel
are
expected
to
observe
the
performance
tests
at
half
the
existing
facilities
with
add­
on
control
devices
(
9
facilities
out
of
19).
No
costs
are
associated
with
repeat
performance
tests
because
facilities
will
not
"
fail"
the
test
since
they
are
simply
setting
a
typical
control
device
and
capture
efficiency
to
use
in
compliance
calculations.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
The
Respondent
Tally.
A
breakdown
for
each
of
the
collection,
reporting,
and
recordkeeping
activities
required
by
the
regulation
is
presented
in
tables
1
through
3.
The
estimate
of
total
annual
hours
requested
from
the
respondents
is
based
on
the
assumptions
outlined
in
section
6(
d)
of
this
supporting
statement.
The
EPA
estimated
the
respondent
burden
by
totaling
the
hours
for
the
first
3
years
after
the
implementation
of
the
regulation
for
technical,
managerial,
and
clerical
staff
at
the
facility.
This
total
was
then
divided
by
3
to
arrive
at
the
average
annualized
burden
in
the
first
3
years
following
promulgation
(
see
table
4).
A
similar
approach
was
taken
for
estimating
average
annual
labor
and
non­
labor
costs.
For
the
first
3
years
after
the
implementation
of
the
regulation,
EPA
estimates
that
industry
would
expend
an
average
of
42,533
hours
annually
at
a
labor
cost
of
$
1,927,249
per
year
to
meet
the
monitoring,
recordkeeping,
and
reporting
requirements.
The
19
average
annual
capital
cost
is
expected
to
be
$
44,333.
The
average
annual
operation
and
maintenance
cost
is
expected
to
be
$
655
(
see
table
4).

(
ii)
The
Agency
Tally.
The
bottom
line
agency
burden
hours
and
costs,
presented
in
tables
5
through
7,
are
calculated
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff,
and
by
totaling
the
cost
column.
Table
8
(
attachment
3)
summarizes
the
agency
burden
for
each
of
the
first
3
years
and
calculates
the
average
annual
burden
by
dividing
the
3
year
total
by
3.
The
estimated
average
annual
burden,
over
the
first
3
years,
for
the
Agency
would
be
1,432
hours
at
a
cost
of
$
57,956
per
year.

(
iii)
Variations
in
the
Annual
Bottom
Line.

Calculating
the
average
annual
costs
underestimates
costs
in
a
typical
year
for
a
NESHAP.
Calculating
each
year
individually
provides
a
more
accurate
account
of
how
facilities
will
be
affected
in
the
first
3
years
following
promulgation.

During
years
1
and
2,
there
is
little
burden
for
existing
facilities
because
existing
facilities
are
not
required
to
begin
compliance
until
year
3.
Therefore,
the
year
3
burden
for
industry
and
the
government
is
much
higher
than
years
1
and
2.

(
f)
Reasons
for
Change
in
Burden
This
is
a
new
collection
and
there
is
no
change
in
burden.

(
g)
Burden
Statement
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
20
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.
21
Attachment
1
Source
Data
and
Information
Requirements
Requirement
40
CFR
part
63
RECORDKEEPING
5­
year
retention
of
records
63.4531(
b)

Copy
of
each
notification
and
report
as
submitted
and
associated
documentation
63.4530(
a)

Recordkeeping
relevant
to
start­
up,
shutdown,
and
malfunction
periods
and
continuous
monitoring
system
63.6(
e)(
3)(
iii)
through
(
v)

Copy
of
information,
such
as
manufacturer's
formulation
data,
used
in
calculations
63.4530(
b),
(
e),
(
f),
(
g)

Copy
of
all
emission
rate
calculations
63.4530(
c)

Record
of
all
coatings
used
during
each
compliance
period
63.4530(
d)

Record
of
waste
materials
shipped
off­
site
to
TSDF
63.4530(
h)

Records
of
continuous
compliance
with
operating
limits
for
add­
on
control
63.4530(
k)

Records
of
deviations
63.4530(
j)

General
recordkeeping
63.10(
b)(
1)

REPORTING
Initial
notification
for
existing
sources
63.4510(
b)

Notification
of
intent
to
construct
63.4510(
a)

Notification
of
start
construction
63.4510(
a)

Notification
of
anticipated
start­
up
date
63.4510(
a)
Requirement
40
CFR
part
63
22
Notification
of
actual
startup
date
63.4510(
a)

Notification
of
compliance
status
63.4510(
c)

Notification
of
performance
test
63.4510(
a)

Semi­
annual
compliance
report
63.4520(
a)

Start­
up,
shutdown,
and
malfunction
plan
63.6(
e)(
3)
Attachment
2
TABLES
1,
2,
3,
and
4
Table
1:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Year
1
Table
2:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Year
2
Table
3:
Annual
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Year
3
Table
4:
Summary
of
Respondent
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Years
1
through
3
and
Average
Attachment
3
TABLES
5,
6,
7,
AND
8
Table
5:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
the
Standard
of
Performance
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Year
1
Table
6:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
the
Standard
of
Performance
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Year
2
Table
7:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
the
Standard
of
Performance
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Year
3
Table
8:
Annual
Federal
Government
Burden
and
Cost
of
Recordkeeping
and
Reporting
Requirements
for
the
Standard
of
Performance
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Plastic
Parts
and
Products
Surface
Coating­­
40
CFR
Part
63,
Subpart
PPPP
­
Years
1
through
3
and
Average
