SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
Subpart
TTT
Surface
Coating
of
Plastic
Parts
for
Business
Machines
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
New
Source
Performance
Standards
(
NSPS),
Subpart
TTT,

Surface
Coating
of
Plastic
Parts
for
Business
Machines.

1(
b)
Short
Characterization/
Abstract
In
general
all
NSPS
standards
require
initial
notifications,

performance
tests,
and
periodic
reports.
Owners
or
operators
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,
in
general,
of
all
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
2
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
EPA
Regional
Office.

The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
TTT,

Surface
Coating
of
Plastic
Parts
for
Business
Machines,
were
proposed
on
January
8,
1986
and
were
promulgated
on
January
29,

1988.
These
standards
apply
to
the
following
facilities
in
industrial
surface
coating
operations
that
apply
coatings
to
plastic
parts
for
use
in
the
manufacture
of
business
machines:

each
spray
booth
that
applies
prime
coats,
color
coats,
texture
coats
or
touch­
up
coats.
The
standards
apply
to
those
facilities
that
commenced
construction,
modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
TTT.

Approximately
40
sources
are
currently
subject
to
the
standard,
and
an
additional
1
source
per
year
will
become
subject
to
the
standard
during
the
next
three
years.
This
estimate
is
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standard
Agency
knowledge
and
experience
with
this
industry,
the
previously
approved
ICR,
and
any
comments
received.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act,

as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,

or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
111(
a)(
l)].

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

.
.
.
(
A)
establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
volatile
organic
compounds
(
VOCs)
from
the
surface
coating
of
plastic
parts
for
business
machines
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
(
60,61,63)
Subpart
TTT.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
VOCs
from
the
surface
coating
of
plastic
parts
for
business
machines
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC'S
from
facilities
subject
to
Subpart
TTT
are
the
result
of
operation
of
the
industrial
surface
coating
operations
that
apply
coatings
to
plastic
parts
for
use
in
the
manufacture
of
business
machines:
each
spray
booth
that
applies
prime
coats,
color
coats,

texture
coats
or
touch­
up
coats.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
standard
is
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
standards
restrict
emissions
to
no
more
than
1.5
kilograms
of
VOCs
per
liter
of
coating
solids
applied
for
prime
and
color
coats,
and
to
no
more
than
2.3
kilograms
of
VOCs
per
liter
of
coating
solids
applied
for
texture
and
touch­
up
coats.
The
quarterly,
and
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

The
information
generated
by
the
monitoring,
record
keeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
achieve
compliance
with
the
regulation.
Adequate
monitoring,

record
keeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
record
keeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
record
keeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
TTT.

3(
a)
Nonduplication
If
the
standard
has
not
been
delegated
the
information
is
sent
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
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
Standard.
Therefore,
no
duplication
exists.

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
on
January
21,

2000.
This
Federal
Register
notice
solicited
comments
to:

(
i)
evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
agency,
including
whether
the
information
will
have
practical
utility;

(
ii)
evaluate
the
accuracy
of
the
agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,

including
the
validity
of
the
methodology
and
assumptions
used;

(
iii)
enhance
the
quality,
utility,
and
clarity
of
the
information
to
be
collected;
and
(
iv)
minimize
the
burden
of
the
collection
of
information
on
those
who
are
to
respond,
including
through
the
use
of
appropriate
automated
electronic,

mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology,

e.
g.,
permitting
electronic
submission
of
responses.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
record
keeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
record
keeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.

However,
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
(
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
None
of
the
reporting
or
record
keeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
record
keeping
and
reporting
requirements
are
industrial
coating
operations
that
apply
surface
coatings
to
plastic
parts
for
business
machines
(
SIC
Codes
2851,

3079,
3471,
3573,
3574,
3579,
3661,
and
3861)
that
commenced
construction,
modification,
or
reconstruction
after
January
8,

1986.
The
broad
range
of
SIC
codes
covered
by
this
standard
reflects
the
fact
that
some
business
machine
manufacturers
are
highly
integrated
and
perform
the
actual
spray
coating
of
plastic
parts
on­
site,
while
others
purchase
plastic
parts
that
have
already
been
coated
at
a
specialized
coating
facility.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60
Subpart
TTT.

A
source
must
make
the
following
reports
Reports
for
NSPS
SUBPART
TTT
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
results
60.8
(
a)

Physical
or
operational
change
60.7(
a)(
4)

Statement
of
compliance
(
semiannual)
60.724(
b)(
2)

Excess
emissions/
non­
compliance
(
quarterly)
60.724(
b)(
1)

Record
keeping
for
NSPS
SUBPART
TTT
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)
Record
keeping
for
NSPS
SUBPART
TTT
Monthly
performance
test
measures
and
calculations
60.724(
a)

Records
are
required
to
be
retained
for
2
Years.
These
records
must
be
kept
onsite
60.724(
d)

(
ii).
Respondent
Activities
Respondent
Activities
Read
instructions
Perform
initial
performance
test,
Reference
Method
24
test,
and
repeat
performance
tests
if
necessary.

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.
5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

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

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database.

5(
b)
Collection
Methodology
and
Management
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,

and
to
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
quarterly,
and
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.

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

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
The
record
keeping
and
reporting
requirements
were
selected
within
the
context
of
a
small
collection
of
process
equipment
and
reflect
the
burden
on
small
businesses.
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
For
the
most
part,
smaller
facilities
will
be
using
the
same
type
of
coating
each
month,
and
using
the
same
spray
application
equipment.
Consequently,
the
calculations
for
the
monthly
performance
tests
will
be
fairly
repetitive
and
not
as
timeconsuming
as
for
larger
sources
which
may
use
a
much
wider
variety
of
coating
types
and
application
equipment
of
variable
transfer
efficiencies,
etc..
Even
though,
the
record
keeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
record
keeping
and
reporting
requirements
applicable
to
the
industry
for
each
of
the
subparts
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
3,639
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
54.94
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
is
from
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead
($
54.94
=
$
26.16
+
110%).

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.

There
are
no
capital
or
operations
and
maintenance
costs.
There
is
no
requirement
for
the
installation
of
continuous
monitoring
equipment,
or
specialized
testing
devices.
Monthly
performance
tests
involve
calculations
only,
and
rely
on
data
that
is
either
readily
available
or
routinely
collected
as
part
of
normal
operations.
Most
of
the
measurements
and
calculations
required
for
monthly
performance
tests
under
this
standard
are
consistent
with
the
respondents'
normal
record
keeping
practices.

Semiannual
reports
are
essentially
a
statement
that
all
performance
tests
showed
the
source
to
be
in
compliance
with
the
emissions
limitations.
Quarterly
reports
are
required
only
of
those
sources
found
to
be
in
violation
of
the
emission
standards,
and
are
required
only
during
the
particular
quarter
in
which
a
performance
test
indicated
a
violation.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
4,673
(
from
table
1).
This
cost
is
based
on
an
average
wage
of
a
(
GS
10
step
1
employee
rate,
($
17.09
hr
+
110%
overhead
=
$
35.89)
This
rate
is
from
OPM's
2000
General
Schedule,
excluding
locality
pay,
basic
rates.

Details
upon
which
this
estimate
is
based
appear
in
Table
1:

Agency
Burden.
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
(
A)
#
new
sources
per
year
(
B)#
of
initial
reports
for
new
sources
(
C)#
existing
sources
(
D)#
of
reports
for
existing
sources
(
E)
total
annual
responses
(
AXB)+(
CXD)

1
1
40
3
121
The
number
of
respondents
is
41.
It
is
shown
on
the
OMB
83­

I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.

The
total
annual
responses
is
121.
This
number
is
in
column
E
of
the
Respondant
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
199,948.

This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
c.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Tables
1
and
2.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
This
increase
in
burden
is
due
to
more
accurate
estimates
of
existing
labor
rates.

6(
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
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,

Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
Washington,
D.
C.
20460;
and
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.
Include
the
EPA
ICR
number
(
1093.05)
and
OMB
control
number
(
2060­
0162)
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
