  SEQ CHAPTER \h \r 1 	SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS FOR SURFACE COATING OF PLASTIC PARTS FOR BUSINESS MACHINES (40 CFR
PART 60, SUBPART TTT) 

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR
Part 60, Subpart TTT) 

	1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) for Surface Coating of
Plastic Parts for Business Machines (40 CFR part 60, subpart TTT) 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.

	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
two 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 United States Environmental Protection
Agency (EPA) Regional Office.

	Approximately 10 sources are currently subject to the standard, and the
number of sources subject to the regulation is expected to either remain
the same or to slightly decrease during the next three years.  These
figures are based on estimates from the most recently approved
Information Collection Request (ICR) renewal.  The information
collection will involve 10 respondents, 978 (rounded) burden hours, and
$92,296 (rounded) in labor costs.

	OMB approved the currently active ICR without any “Terms of
Clearance.”

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 (VOC)
emissions 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, the NSPS
were promulgated for this source category at 40 CFR part 60, 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 VOCs 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 notifications
required in the applicable regulations 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
standards are 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 performance test may also be
observed.  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 at the
source, as a check on source operation and maintenance, and for
compliance determinations.

 

	The information generated by the monitoring, recordkeeping 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, recordkeeping, and
reporting are necessary to ensure compliance with these standards, as
required by the Clean Air Act.  The information collected from
recordkeeping 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 requested recordkeeping and reporting are required under 40 CFR
part 60, subpart TTT.

	3(a)  Nonduplication

	 If the subject standards have not been delegated the information is
sent directly to the appropriate EPA Regional Office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar regulation to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, 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 July 8, 2009 (74 FR 32580).  No
comments were received on the burden published in the Federal Register.

	

	

3(c)  Consultations

	For this information collection, the previous ICR renewal was used to
obtain burden estimates since this ICR renewal was processed under the
“Expedited Approach” option.  Per this guidance, all data and
assumptions from the previous ICR renewal were used as the basis for
estimating the hourly and cost burdens associated with this renewal.  

The Agency has consulted industry experts and internal data sources to
project the number of affected facilities and industry growth over the
next three years.  In a previous ICR renewal, EPA’s Office of Air
Quality Planning and Standards (OAQPS) conducted an extensive review of
and consultations with industry during development of the National
Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface
Coating of Plastic Parts and Products.  Approximately 10 respondents
will be subject to the standard over the three year period covered by
this ICR.

	It is our policy to respond after a thorough review of comments
received since the last ICR renewal as well as those submitted in
response to the first Federal Register notice.  In this case, no
comments were received.  

	

3(d)  Effects of Less Frequent Collection

	Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the required standards.
 Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

	3(e)  General Guidelines

	These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

	3(f)  Confidentiality

	The required information has been determined not to be confidential. 
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

	The reporting or recordkeeping requirements in the standard do not
contain sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/NAICS Codes

	The respondents of the recordkeeping and reporting requirements are
industrial coating operations that apply surface coatings to plastic
parts for business machines that commenced construction, modification,
or reconstruction after January 8, 1986.  The SIC codes for the
respondents affected by the standards are SIC (United States Standard
Industrial Classification) 2851, 3079, 3471, 3573, 3574, 3579, 3661, and
3861 which correspond to the NAICS (The North American Industry
Classification System) 32551, 332813, 339942, 334518, 333313, 33421,
334418, 333315, and 325992.  The broad range of SIC codes covered by the
standards 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
NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR
part 60 subpart TTT).

	A source must make the following reports:

		

Reports for NSPS subpart TTT

Notification of construction/reconstruction	60.7(a)(1)

Notification of actual startup	60.7(a)(3)

Initial performance test results	60.8(a)

Initial performance test	60.8(d)

Notification of physical or operational change	60.7(a)(4)

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

Excess emissions / noncompliance (quarterly)	60.724(b)(1)



	

A source must maintain the following records:

Recordkeeping for NSPS subpart TTT

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative 	60.7(b)

Monthly performance test measures and calculations 	60.724(a)

Records are required to be retained for two 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.



Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site. 

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

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 Air Facility System (AFS)
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 the 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 AFS for tracking air pollution compliance and
enforcement by local and State regulatory agencies, and EPA Regional
Offices, and EPA 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

	A majority of the affected facilities are small entities (e.g., small
businesses).  The recordkeeping 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 entities
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
time-consuming as for larger sources which may use a much wider variety
of coating types and application equipment of variable transfer
efficiencies, etc.  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
entities.

	The number of small entities potentially subject to the requirements of
this information collection request is estimated to be 88 percent of the
respondent universe, or 9 plants.  This estimate is based on the percent
of plants in this industry that were classified as small plants during
the development of this rule.  

	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 -
NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR
part 60, subpart TTT).

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 for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

	6(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated at 978
(rounded) person-hours (Total Labor Hours from Table 1).  These hours
are based on an Agency review of the industry during development of the
NESHAP for Surface Coating of Plastic Parts and Products which are
standards that apply to the same industry, Agency studies and background
documents from the development of the regulation, Agency knowledge and
experience with the NSPS program, and the previously approved ICR.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial	$115.40 ($54.95 + 110%)   

Technical	$97.88 ($46.61 + 110%)

Clerical	$48.38 ($23.04 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, June 2009, ”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 and Operation 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/startup or operation 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
recordkeeping 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.

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

	The only type of industry costs associated with the information
collection activity in the regulations are labor costs.  There are no
capital/startup or operation and maintenance costs.

		

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis
of the reported information.  Publication and distribution of the
information are part of the AFS 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 Agency cost during the three years of the ICR is
estimated to be $3,860 (Table 2: Annual Agency Burden and Cost - NSPS
for the Surface Coating of Plastic Parts for Business Machines (40 CFR
part 60, subpart TTT)).  

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

           Managerial	$61.36 (GS-13, Step 5, $38.35 + 60%) 

           Technical	$45.52 (GS-12, Step 1, $28.45 + 60%)

           Clerical		$24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM), 2009
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60% to account for the benefit packages available to
government employees.  Details upon which this estimate is based appear
in the attached Table 2: Annual Agency Burden and Cost - NSPS for the
Surface Coating of Plastic Parts for Business Machines (40 CFR part 60,
subpart TTT).

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

	Approximately 10 sources are currently subject to the regulation, and
the number of sources subject to the regulation is expected to either
remain the same or to slightly decrease during the next three years.

	Respondent Universe and Average Number of Responses Per Year

Regulation Citation	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources

	(F)

Number of Respondents that keep records but do not submit reports	(E)

Total Annual Responses

(AxB)+

(CxD)+F

NSPS, 40 CFR part 60, subpart TTT	0	4	10

2	2 (semiannual)

4 (quarterly)	0	28



	The number of total respondents is 10.  This number is the sum of
column A and column C of the Respondent Universe and Number of Responses
Per Year table.  This represents the number of existing sources plus the
number of new sources averaged over the three-year period (i.e., the
total of the number of new respondents over the three-year period
divided by three years).  

	The total annual response is 28.  This number is in column E of the
Respondent Universe and Number of Responses Per Year table above.  

	The total annual labor costs are $92,296 (rounded).  Details upon which
this estimate is based appear in Table 1: Annual Respondent Burden and
Cost - NSPS for the Surface Coating of Plastic Parts for Business
Machines (40 CFR part 60, subpart TTT).

	Note that the total annual capital and O&M costs to the regulated
entity are $0.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

	6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

	The bottom line burden hours and cost tables for both the Agency and
the respondents are attached in Tables 1 and 2, respectively, and
summarized below.

(i) Respondent Tally

The total annual labor hours are 978, with annual labor costs of
$92,296.  Details regarding these estimates may be found in Table 1. 
Annual Respondent Burden and Cost - NSPS for the Surface Coating of
Plastic Parts for Business Machines (40 CFR part 60, subpart TTT)
(attached).  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 35
hours per response.

There are no annual capital/startup and O&M costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 74 labor hours at a labor cost of $3,285.  The average
annual travel expenses over the next three years cost $575.  Thus, the
total average annual Agency burden is estimated to cost $3,860.  See
Table 2.  Annual Agency Burden and Cost - NSPS for the Surface Coating
of Plastic Parts for Business Machines (40 CFR part 60, subpart TTT)
(attached).

	6(f)  Reasons for Change in Burden

	There is no change in the labor hours or cost to the respondents in
this ICR compared to the previous ICR.  This is due to two
considerations.  First, the regulations have not changed over the past
three years and are not anticipated to change over the next three years.
 Secondly, the growth rate for the respondents is very low, negative, or
non-existent.  Therefore, the labor hours and cost figures in the
previous ICR reflect the current burden to the respondents and are
reiterated in this ICR. 

	However, there is a decrease estimated burden currently identified in
the OMB Inventory of Approved ICR Burdens.  This decrease was due to a
change in the adjustments to the estimates to correct a mathematical
error. 

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 35 (rounded) hours per
response.  Burden means the total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency.  This includes the time
needed to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.

  An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
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-2009-0417.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1927.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0417 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.

