Kyle
Pitsor
Vice
President,
Government
Relations
National
Electrical
Manufacturers
Association
1300
North
17th
Street,
Suite
1847
Rosslyn,
Virginia
22209
Dear
Mr.
Pitsor:

This
letter
is
in
response
to
your
May
6,
2005,
letter
to
the
United
States
Environmental
Protection
Agency's
(
EPA)
Docket
Center
concerning
a
March
8,
2005,
Federal
Register
comment
request
for
the
proposed
information
collection
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Surface
Coating
of
Miscellaneous
Plastic
Parts
at
40
CFR
Part
63,
Subpart
MMMM
(
Subpart
MMMM).
See
70
FR
11239.

Leonard
Lazarus
of
my
staff
discussed
your
letter
in
May
25,
2005,
and
June
6,
2005,
telephone
conversations
with
Richard
LaLumondier
of
the
National
Electrical
Manufacturers
Association
and
Everett
Scherrer
of
Rea
Magnet
Wire.
We
appreciate
your
letter
and
the
discussions,
which
clarified
the
unique
burdens
and
costs
experienced
by
magnet
wire
facilities
complying
with
Subpart
MMMM.
In
response
to
your
concerns,
we
have
incorporated
additional
costs
into
our
information
collection
request
(
ICR),
EPA
ICR
Number
2056.02.
These
costs
include
capital/
startup
costs
of
$
500,000
incurred
over
a
three
year
period
by
each
magnet
wire
facility
to
install
a
compliance
parameter
monitoring
system
(
CPMS),
as
well
as
a
$
50,000
per
year
cost
for
maintenance
of
the
system.
We
have
also
adjusted
burden
for
each
magnet
wire
facility
to
be
twenty
times
the
typical
industry
burden
in
order
to
monitor
and
inspect
equipment
and
gather,
process,
compile
and
review
data
needed
to
prepare
reports.

Your
letter
suggests
that
the
40
CFR
Section
63.10(
e)(
3)(
ii)(
A)
reference
to
quarterly
submittal
of
excess
emissions
and
continuous
monitoring
system
performance
reports
may
require
quarterly
reporting
of
the
rolling
12­
month
organic
hazardous
air
pollutant
(
HAP)
emission
rate
calculated
by
each
facility.
However,
as
explained
in
the
May
25,
2005,
telephone
conversation
with
Mr.
Lazarus,
40
CFR
Section
63.10(
e)(
3)(
i)
calls
for
semiannual
submission
of
compliance
reports
unless
more
frequent
reporting
is
specifically
required
by
the
standard,
or
by
the
Administrator
as
determined
on
a
case­
by­
case
basis.
To
my
knowledge,
the
Administrator
has
not
requested
quarterly
reports
from
any
magnet
wire
facility.
Therefore,
such
facilities
only
need
to
submit
the
required
semiannual
reports
as
specified
at
40
CFR
Section
63.3920(
a).
2
You
also
requested
that
magnet
wire
facilities
be
permitted
to
reduce
the
reporting
of
startup/
shutdown
and
malfunction
(
SSM)
events
and
excess
emissions
events,
keeping
the
same
records
they
do
now,
but
submitting
reports
of
routine
SSM
without
significant
hazardous
air
pollutant
(
HAP)
emissions
only
upon
state
or
EPA
regional
office
request.
SSM
and
excess
emissions
reporting
are
required
for
all
NESHAP­
regulated
facilities
under
40
CFR
Sections
63.10(
d)(
5)
and
63.10(
e)(
3)
of
the
General
Provisions.
Although
the
reporting
activities
may
be
characterized
as
routine,
the
semiannual
reports
are
an
important
tool
allowing
regulatory
authorities
to
evaluate
the
continuous
compliance
status
of
a
facility.
Many
magnet
wire
facilities
record
data
electronically
using
automatic
process
monitoring
which
can
be
submitted
electronically
to
regulatory
agencies.
As
Mr.
Lazarus
suggested,
you
should
discuss
the
possibility
of
utilizing
electronic
submittals
with
your
state
and/
or
EPA
regional
office
contacts
to
reduce
the
reporting
burden.

It
may
be
possible
for
a
magnet
wire
facility
to
further
reduce
its
burden
through
alternative
reporting.
To
request
alternative
reporting
approval,
the
facility
should
demonstrate
to
its
EPA
regional
office
how
it
proposes
to
meet
the
NESHAP
requirements
through
reporting
in
an
alternative
format.
Approval
of
an
alternative
reporting
request
would
be
on
a
case­
by­
case
basis.

Any
change
in
the
reporting
requirements
contained
in
Subpart
MMMM
would
require
an
amendment
of
the
standard.
The
Office
of
Air
Quality
Planning
and
Standards
develops
NESHAPs
for
EPA
and
is
the
appropriate
contact
for
discussion
of
rule
amendments.
To
petition
for
such
a
change,
contact
Ms.
Kim
Teal
at
the
EPA
Office
of
Air
Quality
Planning
and
Standards,
Coatings
and
Consumer
Products
Group,
Emission
Standards
Division
(
C539
 
03),
Research
Triangle
Park,
North
Carolina
27711,
or
at
telephone
number
(
919)
541
 
5580,
or
by
email
at
teal.
kim@
epa.
gov.

Finally,
we
agree
that
HAP
emissions
are
calculated
for
total
organic
HAPs
rather
than
for
each
individual
HAP.
40
CFR
Section
63.3890
establishes
limits
on
organic
HAP
emissions.
These
limits
are
specified
as
kilograms
(
pounds)
organic
HAP
per
liter
(
gallon)
coating
solids
used
during
a
12­
month
compliance
period.
The
limits
apply
to
total
organic
HAP
emissions
from
the
affected
source.

If
you
have
any
further
questions,
please
contact
Leonard
Lazarus
at
(
202)
564­
6369,
or
by
email
at
lazarus.
leonard@
epa.
gov.

Very
truly
yours,

Michael
S.
Alushin,
Director
Compliance
Assessment
and
Media
Programs
Division
Office
of
Compliance
cc:
EDocket
OECA­
2005­
0003
