STANDARD
FORM
83­
I
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
1951.02
INFORMATION
COLLECTION
REQUEST
FOR
THE
PAPER
AND
OTHER
WEB
COATING
SOURCE
CATEGORY
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
March
14,
2002
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection.

This
Supporting
Statement
was
prepared
for
"
Recordkeeping
and
Reporting
Requirements
for
the
Information
Collection
Request
(
ICR)
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Paper
and
Other
Web
Coating."
This
is
a
new
information
collection
request
and
the
tracking
number
is
EPA
ICR
No.
1951.02
1(
b)
Short
Characterization.

This
Supporting
Statement
was
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
being
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
the
CAA).
The
final
rulemaking
amends
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
Subpart
JJJJ­­
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP):
Paper
and
Other
Web
Coating
(
hereafter,
this
subpart
is
referred
to
as
the
"
POWC
NESHAP").
The
POWC
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP).
Respondents
are
owners
or
operators
of
affected
sources
regulated
under
the
POWC
NESHAP.

The
subject
ICR
is
for
HAP
emission
sources
in
the
POWC
source
category.
This
source
category
consists
of
an
estimated
429
facilities
nationwide.
Of
these
facilities,
203
were
estimated
to
be
major
sources
subject
to
the
provisions
specified
under
the
POWC
NESHAP
(
hereafter,

these
sources
are
referred
to
as
affected
sources).
An
estimated
226
facilities
are
not
major
sources
and
will
not
be
subject
to
the
provisions
specified
under
the
POWC
NESHAP.

All
existing
affected
sources
must
be
in
compliance
with
the
requirements
of
the
POWC
NESHAP
within
three
years
of
the
effective
date
(
the
effective
date
is
the
promulgation
date)
of
standards
for
an
affected
source.
All
new
and
reconstructed
affected
sources
must
be
in
compliance
with
the
requirements
of
the
POWC
NESHAP
on
the
date
of
startup
or
the
effective
date,
whichever
is
later.

The
analysis
for
this
Supporting
Statement
included
203
POWC
facilities
that
we
anticipate
will
conduct
all
monitoring,
recordkeeping,
and
reporting
(
MRR)
requirements,
2
including
testing
activities.
The
annual
average
MRR
burden
per
facility
to
conduct
all
MRR
activities
was
estimated
to
be
94
labor
hours
and
$
6,639
in
capital
and
operating
and
maintenance
(
O&
M)
expenses.
The
226
facilities
that
are
not
affected
sources
are
expected
to
read
the
rule.

The
estimated
costs
for
this
one
activity
was
$
351
per
facility.
Total
estimated
MRR
costs
are
$
9,363,235
for
the
POWC
source
category
over
the
first
three
years
of
compliance
activities.

Projected
total
capital/
startup
and
O&
M
costs
over
the
first
three
years
of
implementation
are
$
8,782,787.
See
Section
6
for
more
details.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection.

We
have
been
directed
by
section
112
of
the
CAA
to
regulate
the
emission
of
HAP
from
stationary
sources.
The
POWC
source
category
contains
major
sources
of
HAP
emissions
and
is
included
on
our
list
of
categories
scheduled
for
regulation.

Section
114
of
the
CAA
gives
us
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
(
1)
identify
existing
and
new
paper
and
other
web
coating
affected
sources
and
(
2)
ensure
that
the
requirements
specified
for
an
affected
source
are
being
achieved.

2(
b)
Use/
Users
of
the
Data.

The
information
will
be
used
by
our
enforcement
personnel
to
(
1)
identify
existing
and
new
HAP
emission
points
subject
to
the
POWC
NESHAP,
(
2)
identify
the
emission
control
devices
and
methodologies
(
e.
g.,
product
substitution
and/
or
reformulation)
being
applied,
and
(
3)
ensure
that
the
emission
control
devices
and
methodologies
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Records
and
reports
are
necessary
to
enable
us
to
identify
facilities
subject
to
the
POWC
NESHAP
that
may
not
be
in
compliance.
Based
on
reported
information,
we
can
decide
whether
to
inspect
a
facility
and
which
records
or
processes
to
inspect.
The
records
that
facilities
maintain
must
indicate
to
us
whether
facility
personnel
are
operating
and
maintaining
emission
control
devices
and
methodologies
properly.
3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication.

A
search
of
our
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts
with
the
exception
of
the
following
New
Source
Performance
Standards
(
NSPS):
Graphic
Arts
Industry
Publication
Rotogravure
Printing
(
40
CFR
Part
60,

subpart
QQ),
Pressure
Sensitive
Tape
and
Labels
(
40
CFR
Part
60,
subpart
RR),
and
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
Part
60,
subpart
FFF).
The
NSPS
and
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standard
(
e.
g.,
records
of
performance
tests).
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
in
lieu
of,
or
as
a
part
of,
the
report
required
by
the
POWC
NESHAP.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
the
Office
of
Management
and
Budget.

Since
this
is
a
rule­
related
ICR,
it
was
not
necessary
to
solicit
public
comments
prior
to
submittal
of
this
Supporting
Statement
to
the
Office
of
Management
and
Budget
(
OMB).

3(
c)
Consultations.

OMB
regulations
require
periodic
consultation
with
respondents
and
data
users
such
as
members
of
industry,
as
well
as
State
and
local
governments.
Consultations
with
numerous
representatives
of
companies
involved
with
paper
and
other
web
coating
operations
were
conducted
throughout
the
NESHAP
development
process.
Table
1
presents
a
list
of
the
names,

affiliations,
and
telephone
numbers
of
persons
that
were
consulted
during
the
rule
development.

3(
d)
Effects
of
Less
Frequent
Collection.

If
the
requirement
to
submit
compliance
demonstrations
was
on
a
less
frequent
basis,
we
would
not
be
reasonably
assured
that
an
affected
source
is
in
compliance
with
the
NESHAP.
In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.

Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
we
and
the
regulated
community
benefit
from
preservation
of
our
administrative
powers.
4
Table
1.
Paper
and
Other
Web
Coating
Consultations
NAME
AFFILIATION
TELEPHONE
NUMBER
Paul
Narog
3M
Company
(
612)
778­
5380
Roberta
Smith
Allied
Signal
(
804)
520­
3070
Rob
Kaufmann
American
Forest
and
Paper
Association
(
AF&
PA)
(
202)
463­
2588
Steve
Young
Association
of
Independent
Corrugated
Converters
(
AICC)
(
703)
836­
2422
Craig
Shepard
Association
of
Industrial
Metallizers,
Coaters,
and
Laminators
(
AIMCAL)
(
803)
802­
7820
Colleen
Liederbach
AIMCAL
(
216)
573­
3773
Charles
Ayres
Champion
International
(
203)
358­
7117
Susan
Young
Chemical
Fabrics
&
Film
Association
(
CFFA)
(
216)
241­
7333
Robert
Romano
American
Chemistry
Council
(
ACC)
(
703)
741­
5619
Carol
Niemi
Chemical
Manufacturers
Association­
Solvents
Council
(
CMA
Solvents
Council)
(
517)
631­
4923
Barbara
Francis
ACC
(
703)
741­
5609
Howard
Hofmeister
Curwood­
Bemis
(
920)
303­
7417
Steve
Byrne
Cytec
(
973)
425­
8406
Loren
Durfee
Dow
Corning
Corporation
(
517)
496­
8822
Raymond
Coss
Dow
Corning
Corporation
(
517)
496­
4084
Mark
Nuzzaco
Environmental
Conservation
Board
of
Graphic
Communications
Industry
(
EC­
GCI)
(
703)
648­
3218
Leonardo
Ceron
EPA
Region
IV
(
404)
562­
9129
Sarah
Miller
EPA
Region
V
(
312)
886­
6812
Brent
Marable
EPA
Region
V
(
312)
886­
6088
Janet
Bowen
EPA
Region
I
(
617)
565­
3595
Mary
Opfer
Fibre
Box
Association
(
FBA)
(
847)
364­
9635
Table
1.
Paper
and
Other
Web
Coating
Consultations
(
cont.)

NAME
AFFILIATION
TELEPHONE
NUMBER
5
Mark
Wygonik
Flexible
Packaging
Association
(
FPA)
(
202)
842­
3880
Doreen
Monteleone
Flexographic
Technical
Association
(
FTA)
(
516)
737­
6026
Gary
Jones
Graphic
Arts
Technical
Foundation
(
GATF)
(
412)
741­
6860
Greg
Tyszka
Gravure
Association
of
America
(
GAA)
(
716)
436­
2150
Peter
Mayberry
Healthcare
Compliance
Packaging
Council
(
HCPC)
and
INDA,
the
Association
of
the
Non­
Woven
Fabric
Industry
(
202)
828­
2329
Chris
Romaine
Illinois
EPA
(
217)
785­
1715
Hank
Naour
Illinois
EPA
(
217)
785­
1716
Holly
Evans
Institute
of
Interconnecting
and
Packaging
Electronic
Circuits
(
IPC)
(
202)
638­
6219
Ed
Campobenedetto
Institute
of
Clean
Air
Companies
(
ICAC)
(
202)
457­
0911
George
Carter
Laminating
Materials
Association
(
LMA)
(
201)
664­
2700
Dennis
Coil
Lawson
Mardon
Packaging
USA
Incorporated
(
708)
649­
3872
Bill
Judd
Madico
(
781)
756­
4135
Tommy
Carroll
Mebane
Packaging
Group
(
919)
563­
3516
OnSoon
Berglund
Minnesota
Pollution
Control
Agency
(
612)
296­
7595
John
Pinkerton
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvements
(
NCASI)
(
919)
558­
1992
George
Fuchs
National
Association
of
Printing
Ink
Manufacturers
(
NAPIM)
(
201)
288­
9454
Tom
Dufficy
National
Association
of
Photographic
Manufacturers
(
NAPM)
(
914)
698­
7603
Richard
Lamondier
National
Electrical
Manufacturers
Association
(
NEMA)
(
703)
841­
3237
John
Bradfield
National
Particleboard
Association
(
NPA)
(
301)
670­
0604
Table
1.
Paper
and
Other
Web
Coating
Consultations
(
cont.)

NAME
AFFILIATION
TELEPHONE
NUMBER
6
Bob
Nelson
National
Paint
and
Coating
Association
(
NPCA)
(
202)
462­
6272
Jennifer
Griffith
Northeast
Waste
Management
Officials
Association
(
NEWMOA)
(
617)
367­
8558
X303
Bernette
Schilling
NY
Dept.
Of
Environmental
Conservation
(
716)
226­
2466
Peter
Eberle
Paperboard
Packaging
Council
(
PBPC)
(
703)
836­
3300
Nicole
Miller
Pressure
Sensitive
Tape
Council
(
PSTC)
(
312)
644­
6610
Ann
Pantle
Quebcor
Printing
USA
Corporation
(
312)
645­
4600
Dale
Kalina
R.
R.
Donnelley
&
Sons
Company
(
630)
322­
6709
Alex
Ross
RADTECH,
Incorporated
(
703)
534­
9313
Gordon
Miller
Rexam
Incorporated
(
704)
551­
1549
Tracey
Norberg
Rubber
Manufacturers
Association
(
RMA)
(
202)
682­
4839
Matthew
Maik
State
and
Territorial
Air
Pollution
Program
Administrators
(
STAPPA)
Chicago
Department
of
the
Environment
(
312)
744­
7311
Dan
Johnston
STAPPA
­
Wisconsin
DNR
(
608)
267­
9500
Bill
Franek
STAPPA
­
Cook
County,
Illinois
(
708)
865­
6182
Joseph
Zborovsky
Sun
Chemical
Corporation
(
201)
933­
4500
X1285
Bud
Gray
Tag
and
Labels
Manufacturers
Institute
(
TLMI)
(
630)
357­
9222
Alan
Davis
Technical
Association
of
Pulp
and
Paper
Industry
(
TAPPI)
(
630)
213­
6559
Hector
Garcia
Texas
Natural
Resource
Conservation
Committee
(
TNRCC)
(
512)
239­
5760
Emil
Studinka
Wilsonart
International
Incorporated
(
817)
778­
2711
Charlie
Carter
Womble
Carlyle
Sandridge
&
Rice
(
919)
755­
2167
7
3(
e)
General
Guidelines.

The
POWC
NESHAP
will
require
owners
or
operators
of
an
affected
source
to
retain
records
for
five
years,
which
exceeds
the
three­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
five­
year
retention
period
is
consistent
with
the
General
Provisions
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
CAA.
All
subsequent
general
guidelines
have
been
followed
and
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6.

3(
f)
Confidentiality.

All
information
submitted
to
us
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
our
policies
set
forth
in
title
40,
chapter
I,
part
2,
subpart
B,

Confidentiality
of
Business
Information.
See
40
CFR
part
2;
41
FR
36902,
September
1,
1976;

amended
by
43
FR
3999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.
Even
where
we
have
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
part
2,
subpart
B,
we
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
7414
(
C);
40
CFR
2.301
(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
OMB
Circular
108.

3(
g)
Sensitive
Questions.

Information
that
will
be
reported
consists
of
emissions
data,
raw
material
usage
and
composition,
and
other
information
that
are
not
expected
to
be
of
a
sensitive
nature.
Therefore,

this
section
is
not
applicable.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes.

Respondents
are
owners
or
operators
of
all
existing
and
new
HAP­
emitting
affected
sources
in
the
POWC
source
category.
The
source
category
and
affected
sources
regulated
with
the
proposal
of
the
POWC
NESHAP
are
classified
under
the
Standard
Industrial
Classification
(
SIC)
codes
for
industry
activities
likely
to
conduct
paper
and
other
web
coating
and
the
corresponding
North
American
Industrial
Classification
System
(
NAICS)
codes
listed
in
Table
2.
8
Table
2.
Paper
and
Other
Web
Coating
Product
Descriptions
And
Corresponding
SIC
and
NAICS
Codes
Product
Description
1987
SIC
Codea
Equivalent
1997
NAICS
Code(
s)
Equivalent
1997
NAICS
Product
Description
Corrugated
and
solid
fiber
boxes
2653
322211
Corrugated
and
solid
fiber
box
manufacturing
(
pt)

Folding
paper
board
boxes,
including
sanitary
2657
322212
Folding
paperboard
box
manufacturing
Packaging
paper
and
plastics
film,
coated
and
laminated
2671a
Single­
web
paper,
paper
multiweb
laminated
rolls
and
sheets
for
packaging
uses
322221
Coated
and
laminated
packaging
paper
and
plastics
film
manufacturing
Coated
and
laminated
paper,
not
elsewhere
classified
2672
322222
Coated
and
laminated
paper
manufacturing
(
pt)

Plastics,
foil,
and
coated
paper
bags
2673a
Except
all
plastics
322223
Plastics,
foil,
and
coated
paper
bag
manufacturing
Bags:
uncoated
paper
and
multiwall
2674
322224
Uncoated
Paper
and
multiwall
bag
manufacturing
Die­
cut
paper
and
paperboard
and
cardboard
2675a
Pasted,
lined,
laminated,
or
surface­
coated
paperboard
322226
Surface­
coated
paperboard
manufacturing
Die­
cut
paper
and
paperboard
products,
except
office
supplies
and
pasted,
lined,
laminated,
or
surface­
coated
paperboard
322299
All
other
converted
paper
product
manufacturing
(
pt)

Converted
paper
and
paper
board,
not
elsewhere
classified
2679a
Table
2.
Paper
and
Other
Web
Coating
Product
Descriptions
And
Corresponding
SIC
and
NAICS
Codes
(
cont.)

Product
Description
1987
SIC
Codea
Equivalent
1997
NAICS
Code(
s)
Equivalent
1997
NAICS
Product
Description
9
Wallpaper
and
gift
wrap
paper
322222
Coated
and
laminated
paper
manufacturing
(
pt)

Other
converted
paper
and
paperboard
products,
such
as
paper
filters,
crepe
paper,
and
laminated
and
tiled
wallboard
322299
All
other
converted
paper
product
manufacturing
(
pt)

Commercial
printing,
gravure
2754
323111
Commercial
gravure
printing
(
pt)

Manifold
business
forms
2761
323116
Manifold
business
forms
printing
(
pt)

Plastic
aseptic
packaging
3074
N/
A
N/
A
Unsupported
plastics
film
and
sheet
3081
326113
Unsupported
plastics
film
and
sheet
(
except
packaging)
manufacturing
Laminated
plastics
plate,
sheet,
and
profile
shapes
3083
32613
Laminated
plastics
plate,
sheet,
and
shape
manufacturing
Abrasive
products
3291
32791
Abrasive
product
manufacturing
Laminated
aluminum
(
metal)
foil
and
leaf,
flexible
packaging
3497a
Laminated
aluminum
foil
rolls/
sheets
for
flexible
packaging
uses
322225
Laminated
aluminum
foil
manufacturing
for
flexible
packaging
uses
a
Note
that
some
SIC
codes
cover
multiple
NAICS
codes.

4(
b)
Information
Requested.

Under
the
final
rule,
affected
sources
can
choose
between
four
emission
limits
to
comply
with
the
emission
standards.
These
limits
are
1)
a
limit
on
the
amount
of
organic
HAP
applied,
2)

a
limit
on
the
mass
of
organic
HAP
applied
as
a
percentage
of
the
mass
of
coatings
applied,
3)
a
limit
on
the
mass
of
organic
HAP
applied
as
a
percentage
of
the
coating
solids
applied,
and
4)
a
10
limit
on
organic
HAP
concentration
in
the
exhaust
stream
of
an
oxidizer.
Each
affected
source
has
the
choice
of
using,
either
individually
or
in
combination,
compliant
coatings
and
add­
on
control
devices
to
comply
with
the
emission
standards.
If
the
affected
source
chooses
to
use
a
solvent
recovery
add­
on
control
device
and
measures
its
performance
by
means
of
a
liquid­
liquid
material
balance,
then
continuous
emission
monitoring
systems
(
CEMS)
are
required.
Continuous
parameter
monitoring
systems
(
CPMS)
are
required
for
all
other
add­
on
control
devices.
For
compliant
coatings,
only
recordkeeping
is
required.

As
discussed
in
Section
1.0,
it
was
estimated
that
there
are
203
existing
major
sources
that
will
be
affected
by
this
rule.
For
the
purposes
of
the
burden
and
cost
estimates
presented
below,

an
estimated
182
of
these
sources
will
comply
through
the
use
of
add­
on
control
devices,
and
23
of
these
will
use
solvent
recovery
systems
that
require
the
use
of
CEMS.
The
remaining
21
facilities
are
expected
to
use
only
compliant
coatings
to
achieve
compliance.

4(
b)(
i)
Data
Items,
Including
Recordkeeping
Requirements.

Respondents
will
be
required
to
submit
one­
time
reports
for
the
(
1)
initial
notification
for
existing
affected
sources,
(
2)
start
of
construction
for
new
facilities,
(
3)
anticipated
and
actual
start­
up
dates
for
new
facilities,
and
(
4)
physical
or
operational
changes
to
existing
facilities.
All
records
will
be
maintained
by
the
facility
for
a
period
of
at
least
five
years.

An
existing
affected
source
must
submit
an
initial
notification
not
later
than
one
year
before
the
compliance
date.
A
new
affected
source
with
an
initial
startup
date
before
the
promulgation
date
of
the
standards
will
have
to
submit
a
one­
time
initial
notification.
This
initial
notification
will
have
to
be
submitted
within
120
days
after
the
promulgation
date
of
the
standards.
A
new
affected
source
with
an
initial
startup
date
on
or
after
the
promulgation
date
of
the
standards
will
have
to
submit
the
initial
notification
within
120
days
after
becoming
subject
to
the
standards.

For
affected
sources
constructed
or
reconstructed
after
the
effective
date
of
the
relevant
standard,
the
General
Provisions
of
40
CFR
part
63
require
that
the
source
submit
an
application
for
approval
of
construction
or
reconstruction.
The
application
is
required
to
contain
information
on
the
air
pollution
control
that
will
be
used
for
each
potential
HAP
emission
point.
11
The
information
in
the
initial
notification
and
the
application
for
construction
or
reconstruction
will
enable
enforcement
personnel
to
identify
the
number
of
sources
subject
to,
or
already
in
compliance
with,
the
standards.

Affected
sources
subject
to
standards
under
the
POWC
NESHAP
will
have
to
submit
a
semiannual
notification
of
compliance
status.
This
notification
will
have
to
be
signed
by
a
responsible
company
official
who
certifies
its
accuracy
and
that
the
affected
source
has
complied
with
the
relevant
standards,
or
provide
details
of
any
deviations
that
have
occurred
during
the
compliance
period.
Performance
test
result
summaries
(
as
applicable)
will
be
included
as
part
of
the
compliance
status
report.
The
notification
of
compliance
status
will
have
to
be
submitted
within
30
days
after
the
end
of
each
calendar
half.

In
addition,
affected
sources
subject
to
the
POWC
NESHAP
will
be
required
to
maintain
records
of
the
following
for
each
monthly
compliance
period
(
including
all
data,
calculations,
test
results,
and
other
supporting
information),
as
appropriate:
1)
name,
mass,
and
mass
fraction
of
organic
HAP
for
each
coating
and
solvent
material
used,
2)
volume
fraction
of
coating
solids
in
each
coating
material,
3)
overall
control
efficiency
for
each
capture
system
and
control
device,

4)
continuous
records
of
capture
system
and
control
device
operating
parameters,
5)
each
value
of
the
monthly
average
as­
applied
organic
HAP
content
and
organic
HAP
to
coating
solids
ratio
for
each
coating
material,
6)
organic
volatile
matter
collection
and
recovery
efficiencies
for
each
solvent
recovery
device,
7)
total
monthly
organic
HAP
emitted,
8)
mass
of
organic
HAP
emitted
per
mass
of
coating
solids
applied,
9)
mass
of
organic
HAP
applied
per
mass
of
material
applied,

10)
monthly
allowable
organic
HAP
emissions,
and
11)
liquid­
liquid
material
balance
calculations.

Any
exceedences
of
allowed
values
will
have
to
be
reported
in
the
semiannual
compliance
report.

The
General
Provisions
require
owners
or
operators
of
affected
sources
to
develop
startup,
shutdown,
and
malfunction
(
SSM)
plans,
documenting
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.
Reports
demonstrating
the
actions
taken
by
an
owner
or
operator
in
the
event
of
a
SSM
are
required
to
be
submitted.
These
reports
are
required
semiannually
when
actions
taken
are
consistent
with
the
plan.
Immediate
reports
are
required
when
actions
taken
are
inconsistent
with
the
plan.
12
The
POWC
NESHAP
will
require
owners
or
operators
of
an
affected
source
to
retain
records
for
five
years,
which
exceeds
the
three­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
five­
year
retention
period
is
consistent
with
the
General
Provisions
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
title
V
of
the
CAA.

4(
b)(
ii)
Respondent
Activities.

The
respondent
activities
that
will
be
required
by
the
POWC
NESHAP
during
the
first
three
years
after
the
compliance
date
for
existing
affected
sources
are
presented
in
Tables
3a
through
3c.
The
respondent
activities
that
will
be
required
by
the
POWC
NESHAP
for
new
affected
sources
are
presented
in
Tables
3d
through
3f.
The
annual
burden
estimate
for
new
affected
sources
is
based
on
the
assumption
that
there
will
be
18
new
sources
subject
to
the
POWC
NESHAP
in
the
first
three
years
after
promulgation
of
standards
for
these
source
categories
(
Source:
E­
Mail
Correspondence
from
Brooks
N.
Depro,
Research
Triangle
Institute,

to
Larry
Sorrels,
U.
S.
EPA,
Feb,
16,
2000).
It
has
been
further
assumed
that
these
new
sources
will
be
added
evenly
throughout
the
three­
year
period;
that
is,
six
new
sources
added
each
year.

The
labor
hours
for
and
costs
of
MRR
activities
are
summarized
in
Table
4.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities.

A
list
of
our
activities
is
provided
in
Tables
5a
through
5f.
Table
6
summarizes
our
estimated
labor
hours
and
costs.
These
tables
are
introduced
in
Section
6(
c)
of
this
Supporting
Statement.

5(
b)
Collection
Methodology
and
Information
Management.

Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
our
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Information
contained
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
obtained
during
periodic
visits
by
our
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.
13
5(
c)
Small
Entity
Flexibility.

Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
our
part.
We
have
reduced
the
recordkeeping
and
reporting
requirement
respondent
burden
to
include
only
the
information
needed
by
us
to
determine
compliance
with
the
POWC
NESHAP.
The
POWC
NESHAP
is
applicable
to
only
major
sources.

By
definition,
a
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.
For
the
POWC
source
category,
a
small
business
is
defined
by
the
number
of
employees.
For
our
source
category,
the
small
business
threshold
ranges
from
500
to
750
or
fewer
employees,
depending
on
SIC
category.
Based
on
available
information,
51
facilities
are
anticipated
to
meet
the
applicable
definition
of
a
small
business
for
the
POWC
source
category.
In
addition,
based
on
the
available
information
on
(
1)
processes
and
operations
at
these
facilities
and
(
2)
estimated
HAP
emissions
from
HAP
emission
points
in
the
POWC
source
category,
we
anticipate
that
these
51
facilities
are
likely
to
be
major
sources
with
respect
to
total
facility
HAP
emissions.

5(
d)
Collection
Schedule.

The
initial
notification
is
due
not
later
than
one
year
before
the
compliance
date
for
existing
affected
sources.
For
new
affected
sources,
it
is
due
no
later
than
one
year
after
initial
startup
of
the
source.
The
notification
of
compliance
status
must
be
submitted
within
60
days
following
completion
by
the
affected
source
of
the
performance
test
specified
in
the
rule.

Affected
sources
must
submit
periodic
excess
emissions
summary
reports
with
their
semiannual
compliance
report.
In
addition,
affected
sources
must
submit
SSM
reports
semiannually
when
actions
taken
in
the
event
of
a
SSM
are
consistent
with
the
source's
SSM
plan.

If
actions
taken
are
not
consistent
with
the
source's
plan,
an
immediate
report
must
be
submitted.

6.
ESTIMATING
BURDEN
AND
COST
OF
THE
COLLECTION
14
6(
a)
Estimating
Respondent
Burden.

The
existing
affected
source
annual
burden
estimates
for
recordkeeping
and
reporting
are
presented
in
Tables
3a
through
3c
for
the
POWC
source
category.
The
new
affected
source
annual
burden
estimates
for
recordkeeping
and
reporting
are
presented
in
Tables
3d
through
3f.

The
estimates
of
annual
total
technical
labor
hours
per
source
and
the
annual
number
of
activities
per
respondent
listed
in
each
table
are
based
upon
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts
and
the
number
of
emission
points
in
each
source.
Activities
that
are
one­
time
only
activities
are
noted
in
the
tables.

6(
b)
Estimating
Respondent
Costs.

6(
b)(
i)
Estimating
Labor
Costs
The
information
collection
activities
for
the
first
three
years
for
existing
and
new
affected
sources
subject
to
the
POWC
NESHAP
are
presented
in
Tables
3a
through
3f.
The
costs
of
these
activities
were
based
on
data
from
U.
S.
Bureau
of
Labor
Statistics
(
BLS)
Internet
web
site
(
http://
www.
bls.
gov/
news.
release/
ecec.
toc.
htm
Table
10)
accessed
March
18,
2002.
BLS
labor
rates
were
increased
by
110%
to
more
accurately
reflect
the
actual
labor
rates
of
the
industry.

Labor
costs
were
divided
into
the
following
three
categories
(
1)
technical,
(
2)
managerial,
and
(
3)
clerical.
Managerial
and
clerical
labor
hours
were
calculated
as
5
and
10
percent,
respectively,

of
each
technical
labor
hour
requirement.
We
estimated
the
cost
of
technical
labor
in
the
POWC
source
category
to
be
$
79
per
hour,
the
cost
of
managerial
labor
to
be
$
86/
hr,
and
the
cost
of
clerical
labor
to
be
$
36/
hr.
These
estimates
included
fringe
benefits.
All
costs
are
in
First
Quarter
2001
dollars.

6(
b)(
ii)
Estimating
Capital/
Startup
and
O&
M
Costs
The
total
annual
estimated
operating
and
maintenance
costs
(
O&
M)
were
calculated
based
on
(
1)
the
estimated
storage,
filing,
photocopying,
and
postage
costs
for
the
1,477
estimated
total
annual
responses
associated
with
the
provisions
of
the
POWC
NESHAP
and
(
2)
the
O&
M
costs
for
the
equipment
required
for
compliance
with
this
standard.

Storage,
filing,
and
photocopying
costs
per
response
were
estimated
as
0.5
hour
of
administrative
labor
at
a
rate
of
$
36/
hr,
or
$
18
per
response
for
multiple
copies.
First
class
postage
was
estimated
as
$
7.40
per
response
for
mailing
of
a
one­
pound
package
and
two
half­
15
pound
packages
to
regulatory
agencies.
The
postage
rates
were
based
on
data
from
U.
S.
Postal
Services
Internet
web
site
(
http://
www.
usps.
com/),
accessed
March
18,
2002.
Thus,
the
total
storage,
filing,
photocopying,
and
postage
cost
per
response
was
$
25.40,
for
an
annual
estimated
total
of
$
37,516.

For
the
majority
of
facilities
subject
to
the
POWC
NESHAP,
the
only
capital
costs
associated
with
MRR
activities
are
expected
to
be
associated
with
performance
testing
by
outside
parties.
It
is
assumed
that
all
POWC
facilities
using
add­
on
control
devices
will
contract
a
testing
company
to
provide
sampling
and
analytical
services
required
to
demonstrate
that
control
devices
achieve
the
required
emission
reductions.
Estimates
were
requested
from
testing
firms
for
performance
testing
using
EPA
Method
25,
including
planning,
setup,
testing,
and
reporting.

Consideration
of
the
estimates
resulted
in
an
estimated
cost
of
$
10,000
per
performance
test
(
Source:
Price
quotation
for
EPA
Method
25
stack
test,
April
17,
2000).
These
costs
are
detailed
in
Table
7.

For
these
facilities,
the
only
continuous
monitoring
requirements
are
for
parametric
monitoring
at
facilities
achieving
compliance
through
the
use
of
control
devices
and
these
systems
are
already
in
place,
therefore
no
new
equipment
will
be
required
by
the
recordkeeping
and
reporting
requirements.

It
is
assumed
that
POWC
facilities
using
solvent
recovery
devices
will
employ
CEMS
to
monitor
their
emissions.
Capital/
Startup
and
O&
M
costs
associated
with
these
CEMS
were
estimated
using
EPA's
CEMS
Cost
model,
Ver.
3.0,
obtained
from
EPA's
Emission
Measurement
Center
WWW
site
(
http://
www.
epa.
gov/
ttn/
emc/
cem.
html).
These
costs
are
detailed
in
Table
7.

6(
b)(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Table
7
details
the
Capital/
Start­
up
and
O&
M
costs
during
the
implementation
period.

Capital/
Startup
cost
items
include
performance
testing
and
CEMS,
while
O&
M
costs
include
ongoing
CEMS
costs,
and
storage,
filing,
photocopying
and
postage
costs.
These
costs
are
reflected
in
Box
14
of
OMB
Form
83­
I.

6(
c)
Estimating
the
EPA's
Burden
and
Cost.
16
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
POWC
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.

Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
AFS
operated
and
maintained
by
our
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
affected
sources.
Periodic
inspections
are
part
of
our
overall
compliance
and
enforcement
program.
Therefore,
these
examinations
are
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information.
Labor
rates
and
associated
costs
are
based
on
the
2001
General
Schedule
(
GS)
base
annual
salary
data
from
Federal
Personnel
Guide
Internet
web
site
(
http://
www.
opm.
gov/
oca/
payrates/),
accessed
March
19,
2002.
We
estimated
an
average
hourly
labor
cost
of
$
65
for
managerial
staff
(
GS
­
15/
3),
$
40
for
technical
staff
(
GS
­
12/
3),
and
$
20
for
administrative/
clerical
staff
(
GS
­
6/
3).
To
derive
hourly
estimates,
we
divided
annual
compensation
estimates
by
2,080
which
is
the
number
of
hours
in
the
Federal
work
year.
We
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6
for
60
percent
overhead
expenses.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Cost.

There
are
a
total
of
429
existing
sources
that
will
respond
to
the
rule,
and
an
estimated
6
new
sources
per
year
that
will
respond
to
the
rule,
for
an
annual
average
of
441
respondents
(
429
+
12,
the
number
of
new
sources
in
year
2).
As
described
in
Section
1b
of
this
Supporting
Statement,
226
of
the
429
existing
facilities
are
non­
major
and
will
only
read
the
rule.
Tables
3a­
f
detail
the
annual
responses
and
the
number
of
respondents
performing
them,
with
totals
listed
in
Table
7
(
under
"
Storage,
filing,
photocopying,
&
postage").
The
annual
average
number
of
responses
is
1,405
for
existing
affected
sources
and
72
for
new
affected
sources,
giving
a
total
annual
average
number
of
responses
of
1,477.
17
The
total
annual
labor
hours
are
41,462.
Details
upon
which
this
estimate
is
based
appear
in
Tables
3a­
f:
Industry
Burden,
and
Table
4:
Summary
of
Source
Category
Burden.

6(
e)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables.

6(
e)(
i)
Respondent
Tally.

The
bottom
line
respondent
burden
hours
and
costs
were
calculated
by
adding
total
labor
hours
and
costs
as
detailed
in
Tables
3a­
f
and
summarized
in
Table
4.

The
estimated
total
nationwide
burden
for
affected
sources
in
the
first
three
years
of
the
POWC
NESHAP
will
be
an
estimated
38,708
total
labor
hours
per
year
at
a
cost
of
$
2,914,796
per
year
for
existing
affected
sources
and
2,754
total
labor
hours
per
year
at
a
cost
of
$
206,283
per
year
for
new
affected
sources.
The
total
estimated
annual
labor
hour
reporting
and
recordkeeping
burden
is
41,462
labor
hours
per
year
at
a
cost
of
$
3,121,078
per
year,
presented
in
Box
13
of
OMB
Form
83­
I.

6(
e)(
ii)
The
EPA
Tally.

The
bottom
line
Federal
government
burden
hours
and
costs
that
will
result
from
this
ICR
are
presented
in
Tables
5a
through
5c
for
existing
affected
sources
and
Tables
5d
through
5f
for
new
affected
sources.
Table
6
summarizes
the
Federal
government
burden
labor
hours
and
costs
for
the
POWC
NESHAP.

The
estimated
total
annual
EPA
labor
hours
and
costs
of
the
POWC
NESHAP
for
existing
affected
sources
in
the
POWC
source
category
for
the
first
three
years
of
compliance
activities
are
11,538
total
labor
hours
at
a
cost
of
$
953,354.
The
estimated
total
annual
EPA
labor
hours
and
costs
of
the
POWC
NESHAP
for
new
affected
sources
in
the
POWC
source
category
for
the
first
three
years
of
compliance
activities
are
787
total
labor
hours
at
a
cost
of
$
62,926.
The
total
estimated
Federal
government
burden
is
12,325
labor
hours
per
year
at
a
cost
of
$
1,016,280
per
year.

6(
e)(
iii)
Variations
in
the
Annual
Bottom
Line.

Variation
in
the
annual
bottom
line
for
this
regulation
may
occur
(
1)
due
to
the
fact
that
certain
one­
time
activities
will
typically
occur
in
the
first
year
following
promulgation
of
the
rule
18
and
(
2)
by
the
third
year
following
promulgation
of
the
rule,
when
all
affected
sources
must
be
in
compliance,
and
will
therefore
be
subject
to
recurring
recordkeeping
and
reporting
requirements.

6(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
collection.

6(
g)
Burden
Statement.

The
respondent
universe
consists
of
429
existing
paper
and
other
web
coating
facilities
and
18
new
facilities
(
6
per
year
during
the
three­
year
period
covered
by
this
analysis),
for
an
annual
average
of
441
affected
facilities.
The
total
burden
hours
and
costs
for
these
facilities
are
presented
in
Tables
3a­
f.
Capital/
startup
and
O&
M
costs
are
detailed
in
Table
7.

The
total
three­
year
monitoring,
recordkeeping,
and
reporting
burden
for
this
collection
is
estimated
at
124,385
labor
hours,
and
the
annual
average
burden
is
41,462
labor
hours.
Based
on
the
annual
average
of
441
respondents,
the
average
burden
per
respondent
is
94
hours
per
year.

The
total
capital/
startup
and
O&
M
cost
is
estimated
to
be
$
8,782,797
over
three
years,
averaging
$
2,927,599
per
year
or
$
6,639
per
respondent
(
based
on
an
annual
average
of
441
respondents).

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,
19
Mail
Code
2822,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­
0001;
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
and
OMB
Control
Number
in
any
correspondence.
20
PART
B
OF
THE
SUPPORTING
STATEMENT
Not
applicable.
No
sampling
or
other
methods
are
used
to
select
respondents
because
all
owners
and
operators
of
facilities
subject
to
the
POWC
NESHAP
are
required
to
collect
information.
