PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Large
Household
and
Commercial
Appliances
Surface
Coating
Operations."

This
is
a
new
information
collection
request
(
ICR),
and
the
U.
S.

Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
is
1954.02.

(
b)
Short
Characterization
This
ICR
is
prepared
for
an
EPA
final
rule
developed
under
authority
of
Section
112
of
the
Clean
Air
Act(
CAA).
This
final
rule
amends
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
a
new
subpart
NNNN­­
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Category:
Large
Household
and
Commercial
Appliances
Surface
Coating
Operations.

The
Large
Household
and
Commercial
Appliances
(
Large
Appliances)

Surface
Coating
Operations
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP).

(
i)
Applicability:
Respondents
are
owners
and
operators
of
new
and
existing
facilities
that
engage
in
the
surface
coating
of
large
appliances
and
related
parts
and
emit
hazardous
air
pollutants
(
HAP's).
Seventy­
four
existing
facilities
are
expected
to
meet
the
applicability
criteria
defined
in
the
rule.
2
Four
new
facilities
are
expected
to
be
constructed
in
each
of
the
next
5
years.

(
ii)
Large
Appliances
Surface
Coating
Operations:
Owners
or
operators
of
facilities
engaged
in
the
surface
coating
of
large
appliances
to
which
this
rule
is
applicable
must
choose
one
of
the
compliance
options
described
in
the
rule,
which
may
include
1)
using
compliant
materials,
2)
averaging
materials,
3)

installing
and
monitoring
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level,
or
4)
a
combination
of
these
options.
The
respondents
will
be
subject
to
those
sections
of
subpart
A
of
40
CFR
part
63
that
relate
to
NESHAP.
These
requirements
include
those
associated
with
the
notification
of
compliance
status
for
the
first
monthly
compliance
period,
and
semiannually
thereafter.

(
iii)
Record
Retention:
Owners
or
operators
of
facilities
that
are
engaged
in
the
surface
coating
of
large
appliances
must
maintain
a
copy
of
all
specified
records
for
a
minimum
of
5
years.
Each
record
must
be
kept
onsite
for
at
least
the
first
2
years
after
the
date
of
each
occurrence,
measurement,

maintenance,
corrective
action,
report,
or
record.
The
records
can
be
kept
offsite
for
the
remaining
three
years.
All
records
are
to
be
submitted
upon
request
to
EPA
or
the
respondent's
State
or
local
agency,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
3
or
not
facilities
subject
to
the
NESHAP
are
achieving
the
standards.

(
iv)
Reports:
The
final
rule
relies
in
part
on
the
provisions
of
subpart
A
of
40
CFR
part
63.
A
table
included
in
the
rule
designates
certain
sections
of
subpart
A
that
apply
to
the
final
rule.
Specific
recordkeeping
and
reporting
requirements
for
each
type
of
emission
compliance
option
are
also
included
in
the
rule.

The
following
reports
must
be
submitted
to
the
Administrator
as
appropriate:
(
1)
Initial
notification,
(
2)
Notification
of
Compliance
Status
Report,
(
3)
Semiannual
Compliance
Reports,
and
(
4)
Other
Reports
as
requested
by
the
Administrator.
The
requirements
for
each
of
the
four
reports
are
summarized
in
the
rule.

2.
Need
For
and
Use
of
the
Collection
The
EPA
is
required
under
section
112(
d)
of
the
CAA
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).
The
predominant
HAP's
emitted
from
large
appliance
surface
coating
operations
include
xylenes,
glycol
ethers,
toluene,
methylene
diphenyl
diisocyanate,
and
methyl
ethyl
ketone.

In
the
Administrator's
judgement,
the
pollutants
emitted
from
large
appliance
surface
coating
operations
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Therefore,
this
source
4
category
was
listed
for
regulation
under
section
112.

Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
facilities
subject
to
the
standard
and
to
ensure
that
the
standard,
which
is
based
on
maximum
achievable
control
technology
(
MACT)
specific
to
large
appliance
surface
coating
operations,
is
being
achieved.
These
records
and
reports
are
required
under
the
General
Provisions
of
40
CFR
part
63,

subpart
A
(
as
authorized
under
sections
101,
112,
114,
116,
and
301
of
the
Act
as
amended
by
Pub.
L
101­
549
[
42
U.
S.
C.
7401,

7412,
7414,
7416,
7601]).

(
a)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
Agency
enforcement
personnel
to
(
1)
identify
new,
modified,
reconstructed,
and
existing
facilities
subject
to
the
standards;
and
(
2)
ensure
that
MACT
is
being
properly
applied
and
that
compliance
is
being
maintained
and
documented.

In
addition,
records
and
reports
are
necessary
to
enable
the
Agency
to
identify
facilities
that
are
not
in
compliance
with
the
standards.
Based
on
reported
information,
the
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
operations
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
will
indicate
to
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
standards.

Much
of
the
information
the
EPA
will
need
to
determine
5
compliance
will
be
recorded
and
compiled
monthly.
Such
information
will
be
reviewed
by
enforcement
personnel
during
an
inspection.

3.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Code
Respondents
are
owners
or
operators
of
facilities
that
perform
surface
coating
of
large
appliances
and
that
are
classified
as
major
sources
under
section
112
of
the
CAA.
In
general,
facilities
that
coat
large
appliances
are
covered
under
the
Standard
Industrial
Classification
(
SIC)
and
North
American
Industrial
Classification
System
(
NAICS)
codes
listed
in
the
table
below.
However,
facilities
classified
under
other
SIC
or
NAICS
codes
may
be
subject
to
the
final
rule
if
they
meet
the
applicability
criteria.
Not
all
facilities
classified
under
the
SIC
and
NAICS
codes
in
the
table
will
be
subject
to
this
rule
because
some
of
the
classifications
cover
products
outside
the
scope
of
the
NESHAP
for
large
appliances.

LARGE
APPLIANCES
PRODUCT
DESCRIPTIONS
AND
CORRESPONDING
SIC
AND
NAICS
CODES
Product
Description
1987
SIC
Code
Equivalent
1997
NAICS
Code(
s)
Equivalent
1997
NAICS
Product
Description
6
Household
Cooking
Equipment
3631
335221
Household
Cooking
Appliance
Manufacturing
Household
Refrigerators
and
Home
and
Farm
Freezers
3632
335222
Household
Refrigerator
and
Home
Freezer
Manufacturing
Household
Laundry
Equipment
3633
335224
Household
Laundry
Equipment
Manufacturing
Household
Appliances;
not
elsewhere
classified
3639
335228
Other
Major
Household
Appliance
Manufacturing
Commercial
Laundry
Equipment
3582
333312
Commercial
Laundry,

Drycleaning,
and
Pressing
Machine
Manufacturing
Air
Conditioning
and
Warm
Air
Heating
Equipment
and
Commercial/

Industrial
Refrigeration
Equipment
3585
333415
Air
Conditioning
and
Warm
Air
Heating
Equipment
and
Commercial/

Industrial
Refrigeration
Equipment
Manufacturing
7
Service
Industry
Machinery;
not
elsewhere
classified
3589
333319
Other
Commercial
and
Service
Industry
Machinery
Manufacturing
(
b)
Information
Requested
(
i)
Data
items:
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
activities:
The
respondent
activities
required
by
the
standards
in
the
first
3
years
following
the
effective
date
are
described
in
Attachment
2.
The
assumptions
used
to
develop
the
estimated
burden
on
affected
facilities
are
presented
in
Attachment
3.
The
respondent
activities
and
corresponding
burden
estimates
are
listed
in
the
first
two
columns
of
Tables
1
through
11,
which
are
presented
in
Attachment
4.
Tables
12
through
14
also
show
the
calculated
burden
for
the
entire
industry
for
each
year
after
the
effective
date
of
the
rule.
Individual
tables
for
existing
and
for
new
facilities
for
each
of
the
first
3
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
during
each
of
the
first
3
years.
Tables
were
also
developed
for
the
second
3­
year
period
after
the
effective
date
of
the
rule
because
existing
facilities
will
not
be
required
to
comply
with
the
rule
until
three
years
after
the
rule
is
final.
Therefore,
on
an
industrywide
basis,
8
most
of
the
recordkeeping
and
reporting
burden
is
not
required
until
the
fourth
year
after
the
effective
date
of
the
rule.

4.
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
Agency
activities
for
the
first
3
years
following
the
effective
date
of
the
standards
are
provided
in
Tables
15
through
17
in
Attachment
4,
and
are
discussed
in
section
6c.
Individual
tables
for
each
of
the
first
3
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
each
year.
Tables
18
through
20
show
the
Agency
burden
for
the
second
three
year
period
after
the
rule
is
in
effect,
and
Table
21
shows
a
summary
of
the
burden
by
year.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
reports
will
be
entered
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
operated
and
maintained
by
the
Agency's
Office
of
Air
Quality
Planning
and
Standards.
Data
obtained
during
periodic
visits
by
Agency
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
semiannual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.
The
rule
does
not
require
the
use
of
automated,
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
9
information
technology.
Although
many
of
the
large
companies
have
elaborate
collection
methods,
automated
systems
are
not
expected
to
reduce
the
burden.

(
c)
Small
Entity
Flexibility
Seven
of
the
74
affected
facilities
in
this
source
category
are
owned
by
small
businesses
as
defined
by
the
Small
Business
Administration
(
SBA).
The
Agency
does
not
expect
any
large
appliance
surface
coating
operation,
including
the
small
businesses,
to
experience
more
than
minimal
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

(
d)
Collection
Schedule
For
all
existing
facilities,
the
Initial
Notification
must
be
submitted
within
12
months
after
the
effective
of
the
standard
and
the
initial
Notification
of
Compliance
Status
must
be
submitted
within
30
days
after
the
end
of
the
initial
compliance
period.
Records
necessary
to
determine
compliance
will
be
compiled
on
a
monthly
basis
and
notifications
of
compliance
status
will
be
submitted
to
the
Administrator
on
a
semiannual
basis.

5.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
10
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule.

(
b)
Consultations
The
EPA
advised
interested
parties
on
July
16,
1992
(
57
FR
31576)
of
the
categories
considered
as
sources
of
HAP's,
and
"
Large
Appliance
Surface
Coating
Operations"
was
listed
as
a
category
of
major
sources.
No
specific
information
was
provided
with
respect
to
burden
estimates
at
that
time.

Representatives
from
other
interested
EPA
offices
and
programs,
including
State
and
Regional
environmental
agency
personnel,
participated
in
the
regulatory
development
and
were
given
opportunities
to
review
and
comment
on
the
rule
before
proposal.
Therefore,
the
EPA
believes
that
the
implication
to
other
EPA
offices
and
programs
was
adequately
considered
during
the
development
of
the
rule.
In
addition,
the
EPA
met
with
some
members
of
industry
concerning
the
rule
prior
to
the
proposal
of
the
rule.
Attachment
5
presents
a
list
of
project
stakeholders.

Finally,
industry,
regulatory
authorities,
and
environmental
groups
were
given
an
opportunity
to
comment
on
the
rule
and
provide
additional
information
during
the
public
comment
period
following
proposal.

(
c)
Effects
of
Less
Frequent
Collection
If
the
relevant
information
were
collected
less
frequently
by
the
owner
or
operator,
the
EPA
would
not
be
reasonably
assured
11
that
a
facility
is
in
compliance
with
the
standards.
Less
frequent
collection
could
result
in
long­
term
exceedances
of
the
applicable
emission
limits.
This
reporting
frequency
is
consistent
with
the
requirements
of
title
V
permit
programs.

Consequently,
less
frequent
reports
would
not
result
in
a
lower
burden.

(
d)
General
Guidelines
This
ICR
requires
that
large
appliance
surface
coating
operations
retain
records
of
control
device
monitoring
or
HAP
emissions
calculation
records
at
facilities
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.5;
however,
the
5­
year
period
is
consistent
with
the
General
Provisions
to
40
CFR
part
63
and
the
permit
requirements
under
40
CFR
part
70.
All
facilities
subject
to
this
rule
will
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,
in
accordance
with
the
provisions
of
40
CFR
part
71,
when
promulgated.
None
of
the
other
guidelines
in
4
CFR
1320.6
are
being
exceeded.

(
e)
Confidentiality
All
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
part
2;
41
12
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,

1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,

1979).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
are
presented
in
Tables
1
through
14
in
Attachment
4.

Individual
tables
for
the
first
3
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
each
of
the
first
3
years.
The
74
major
source
facilities
that
exist
as
of
the
effective
date
of
the
rule
are
not
required
to
come
into
compliance
with
the
rule
until
3
years
after
the
effective
date.

Four
new
facilities
are
projected
to
be
constructed
each
year
after
the
effective
date
of
the
rule,
and
must
comply
when
they
begin
operating.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
the
Agency's
experience
with
other
standards.
These
costs
represent
the
average
burden
that
will
be
incurred
by
facilities
and
the
entire
industry
in
the
first
3
years
after
the
standards
go
into
effect.
Tables
are
also
presented
in
Attachment
4
showing
the
burden
for
the
second
3­

year
period
because
the
burden
is
significantly
higher
then.

(
b)
Estimating
Respondent
Costs
Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
of
technical
at
$
47.04,
management
at
$
70.34,
and
13
clerical
at
$
28.67.

No
capital/
startup
costs
have
been
assigned
because
the
recordkeeping
and
reporting
requirements
of
the
standards
are
not
expected
to
result
in
the
need
for
purchasing
any
additional
equipment,
or
the
expenditure
of
any
startup
costs.
Facilities
are
expected
to
comply
with
the
standards
by
reformulating
their
coating
materials
rather
than
purchasing
add­
on
control
devices.

Thus,
the
purchase
of
monitoring
or
recording
devices
is
not
anticipated.

The
annual
operating
and
maintenance
costs
included
the
costs
to
copy
and
mail
each
response,
and
was
estimated
to
be
$
20
per
response.
Over
the
first
3
years
after
the
effective
date
of
the
standards,
four
new
facilities
are
projected
each
year.

During
this
period,
the
12
affected
facilities
will
submit
a
total
of
48
reports
(
8
in
year
1;
16
in
year
2;
24
in
year
3)
at
a
cost
of
$
960
(
48
*
$
20
=
$
960).
The
annualized
operating
and
maintenance
cost
over
the
3
years
is,
therefore,
$
320
per
year.

(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
were
estimated
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
14
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
AIRS,
with
the
result
that
no
Federal
costs
can
be
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
Agency's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
Government
will
incur
are
user
costs
associated
with
the
analysis
of
the
information
reported
semiannually
by
the
sources,
(
unless
the
semiannual
reports
indicate
a
violation,
thereby
triggering
an
enforcement
action)
as
presented
in
Tables
15
through
21
in
Attachment
4.

Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
of
technical
at
$
47.04,
management
at
$
70.34,
and
clerical
at
$
28.67.

(
d)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables
(
i)
Respondent
Tally:
The
annual
bottom
line
respondent
burden
hours
and
costs
are
calculated
by
adding
the
total
personhours
and
labor
costs
for
74
existing
facilities
during
the
first
3
years
to
the
total
person­
hours
and
labor
costs
for
the
four
new
facilities
in
each
of
the
first
3
years,
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
burden
hours
and
labor
costs
are
shown
on
the
following
table.
15
Year
Total
burden,
hours
Total
costs,
$

1
5,373
249,597
2
3,312
153,861
3
14,527
674,852
Total
23,212
1,078,310
Bottom
line
annual
burden
7,737
359,437
(
ii)
The
Agency
Tally:
The
annual
bottom
line
Agency
burden
hours
and
costs
are
calculated
by
adding
the
total
personhours
and
labor
costs
from
each
of
the
first
3
years,
and
then
dividing
by
the
3­
year
review
period.
The
annual
number
of
hours
averaged
over
the
first
3
years
is
521
at
a
cost
of
$
24,219
per
year.
The
Agency
burden
is
shown
on
the
following
table.

Year
Total
burden,
hours
Total
costs,
$

1
865
40,175
2
294
13,677
3
405
18,805
Total
1,564
72,657
Bottom
line
annual
burden
521
24,219
(
iii)
Variations
in
the
annual
bottom
line:
The
annual
burden
hours
and
costs
vary
over
the
course
of
the
3­
year
review
period
because
of
the
burden
associated
with
initial
reports
and
other
one­
time
activities
(
e.
g.,
developing
the
recordkeeping
system).
Also,
because
existing
sources
are
not
required
to
16
comply
for
3
years,
there
is
only
a
relatively
low
level
of
burden
during
this
period.
Hours
for
reading
and
understanding
the
rule
and
preparing
the
Initial
Notification
are
assigned
to
the
first
year
and
hours
for
planning
activities
and
training
personnel
are
allotted
for
the
third
year.
For
existing
sources,

the
actual
recordkeeping
and
reporting
activities
begin
in
the
fourth
year,
and
will
be
ongoing
each
year
thereafter.

The
Agency
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
the
number
of
respondents
increases
by
four
new
facilities
each
year.
Tables
15
through
17
present
the
Agency
burden
hours
and
costs
of
each
of
the
3
years
following
the
effective
date
of
the
rule.
The
overall
Agency
burden
after
the
first
3­
year
period
will
increase
significantly
as
existing
facilities
begin
semi­
annual
reporting
during
the
fourth
year.

(
e)
Reasons
for
Change
in
Burden
This
section
does
not
apply
because
this
is
a
new
collection.

(
f)
Burden
Statement
(
i)
The
EPA
is
required
under
section
112(
d)
of
the
CAA
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).

(
ii)
The
information
is
needed
as
part
of
the
overall
compliance
and
enforcement
program.

(
iii)
The
total
annual
reporting
and
recordkeeping
burden
17
for
this
collection
averaged
over
the
first
3
years
is
estimated
to
be
7,737
hours
per
year
for
the
entire
source
category.
The
average
burden
for
the
facilities
that
exist
as
of
the
effective
date
of
the
rule
is
about
60
hours
per
year
for
reading
the
rule
and
preparing
to
comply
with
the
rule.
For
each
of
the
four
new
sources
that
are
projected
each
year,
the
burden
is
about
492
hours
in
the
first
year
(
Table
6)
and
about
336
hours
in
subsequent
years
(
Table
7).
The
rule
requires
a
one­
time
initial
notification
and
a
notification
of
compliance
status
from
each
respondent
and
subsequent
notification
every
6
months
to
indicate
their
compliance
status.
A
respondent
will
also
be
required
to
keep
necessary
records
of
data
to
determine
compliance
with
the
standards
in
the
rule.
The
data
will
be
recorded
monthly.
There
are
an
estimated
74
respondents
initially
subject
to
the
collection
requirements,
and
four
additional
respondents
each
year
thereafter.
This
burden
estimate
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
18
or
otherwise
disclose
the
information.

(
iv)
The
respondents
will
be
subject
to
applicable
recordkeeping,
reporting,
and
other
requirements
in
40
CFR
63.9
and
63.10,
as
specified
in
the
final
rule.

(
v)
All
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
Information
(
see
40
CFR
part
2;

41
FR
36902,
September
1,
1076;
amended
by
43
FR
39999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979).

(
vi)
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
rules
are
listed
in
a
table
in
40
CFR
part
9.

The
EPA
will
amend
part
9
when
the
ICR
is
approved.

Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
484
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
19
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.

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
No.
OAR­
2003­
0016,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,

Room
B102,
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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
20
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­

2003­
0016).
21
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
rule.
22
ATTACHMENT
1
Source
Data
and
Information
Requirements
23
REQUIREMENT
CITATION
NOTIFICATIONS
Initial
Notification
63.4110
Notification
of
Compliance
Status
63.4110
Notification
of
construction
or
reconstruction
63.9
Notification
of
anticipated
date
of
initial
startup
63.9
Notification
of
actual
date
of
initial
startup
63.9
Notification
of
modification
63.9
Notification
of
intent
to
conduct
a
performance
test
63.7;
63.8;
63.9;
63.4110
RECORDKEEPING
Material
formulation
data
63.4131
Records
of
HAP
content
calculations
63.4131
Copies
of
Notifications
and
Reports
63.4131
Records
of
names
of
materials
used
63.4131
HAP
fractions
in
each
material
used
63.4131
Coating
solids
fraction
in
each
material
used
63.4131
Density
of
materials
used
63.4131
Documentation
of
waste
material
shipped
offsite
63.4131
Start­
up,
shutdown,
and
malfunction
plan/
records
63.6;
63.4131
Documentation
of
control
device
performance
tests
63.10;
63.4131
Values
measured
by
continuous
monitoring
systems
63.4131
Monitoring
system
calibrations,
maintenance
63.4131
Periods
of
monitoring
system
failure/
shutdown
63.4131
24
REPORTING
Periodic
reports(
semiannual)
63.4120
statement
of
compliance(
if
no
exceedances
occurred)
63.4120
average
monitoring
data
for
any
periods
where
exceedances
or
excursions
occur
63.4120
periods
of
monitoring
system
downtime
63.4120
results
of
any
performance
tests
63.4120
start­
up,
shutdown,
malfunction
reports
63.4120
25
ATTACHMENT
2
Description
of
Respondent
Activities
26
Description
of
Respondent
Activities
(
1)
Read
Rule
and
Instructions
are
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
points
at
a
facility.

(
2)
Plan
Activities
represents
such
burdens
as
design,

redesign,
scheduling,
and
selecting
methods
of
compliance.

(
3)
Training
represents
the
portion
of
activities
from
(
1)

Read
Rule
and
Instruction
for
which
an
average
facility
would
elect
to
provide
classroom
instruction.
The
standard
does
not
require
specific
training
itself.

(
4)
Create,
Test,
and
Research
and
Development
are
the
activities
involving
testing,
retesting,
establishing
parameter
monitoring
levels
and
determining
emission
point
applicability.

(
5)
Gather
Information,
Monitor,
and
Inspect
are
the
activities
involving
collection
of
monitored
data
and
other
related
activities.

(
6)
Process/
Compile
and
Review
are
the
activities
that
involve
analysis
of
the
information
collected
during
the
compliance
period
for
accuracy
and
completeness,
and
include
generation
of
appropriate
internal
reports
and
records
required
as
a
result.

(
7)
Complete
Reports
represents
the
activities
normally
27
associated
with
filling
out
required
forms.
Because
the
rule
requires
no
standardized
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters
as
appropriate.

(
8)
Record/
Disclose
are
activities
that
are
solely
recordkeeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
These
activities
involve
software
translation,
duplication,
or
archival
processes
normally
associated
with
data
management
and
storage
common
to
this
industry.

(
9)
Store/
File
are
again
activities
that
are
solely
recordkeeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
The
activities
involve
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
stored,
to
the
time
they
are
disposed.

(
10)
LDAR
Reporting
and
Recordkeeping
is
the
burden
that
is
associated
with
requirements
to
develop
and
implement
a
leak
detection
and
repair
plan.

(
11)
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
is
the
cost
for
purchasing
automated
monitoring
and
recording
devices
that
are
required
by
the
standards.
28
ATTACHMENT
3
Assumptions
Used
in
Cost
Estimates
29
Assumptions
Used
in
Burden
Estimates
(
a)
There
are
74
major
(
or
"
affected")
sources
and
all
are
assumed
to
come
into
compliance
3
years
after
the
effective
date
of
the
rule,
as
required
by
the
rule.

(
b)
There
are
expected
to
be
12
new,
modified,
or
reconstructed
sources
during
the
first
three
years
(
4
each
year).

(
c)
A
total
of
40
hours
were
estimated
for
obtaining,

reading,
and
understanding
the
requirements
of
the
standard.

(
Burden
Item
1)

(
d)
An
estimated
40
hours
will
be
required
for
communication
and
coordination
with
materials
suppliers
to
ensure
that
all
needed
information
relative
to
HAP
and
solids
content
of
materials
is
provided
with
each
purchase
or
shipment.
(
Burden
Item
2)

(
e)
A
total
of
76
hours
were
estimated
for
training
an
additional
employee
in
the
preparation
of
records
and
reports,
as
well
as
creating
a
"
template"
for
the
reports.
(
Burden
Items
3
&
4)

(
f)
A
total
of
20
hours
per
month
were
assumed
for
gathering
or
retrieving
the
inventory
data
from
which
the
monthly
compliance
determination
will
be
made
and
for
the
analysis
of
the
data.
(
Burden
Items
5&
6)

(
g)
An
estimated
8
hours
will
be
required
for
each
of
the
30
semi­
annual
compliance
reports
submitted
to
EPA.
(
Burden
Item
7)

(
h)
A
total
of
8
hours
were
estimated
for
managing
(
copying,
distributing,
storing,
etc)
each
of
the
semi­
annual
reports.
(
Burden
Items
8&
9)

(
i)
Average
labor
costs
per
hour
are:
technical
­
$
47.04,

management
­
$
70.34,
clerical
­
$
28.67.

(
j)
Management
hours
are
assumed
to
equal
5
percent
of
the
total
technical
hours
required
and
clerical
hours
are
10
percent
of
the
technical
hours.

For
the
second
year
(
and
subsequent
years)
after
facilities
begin
complying
with
the
rule,
the
following
estimates
were
included:

(
a)
A
total
of
20
hours
were
assumed
annually
for
rereading
portions
of
the
standards,
coordination
with
suppliers,
and
training
additional
employees.

(
b)
A
total
of
20
hours
per
month
were
assumed
for
completing
the
compliance
determination.

(
c)
An
estimated
8
hours
were
assumed
for
preparing
each
semi­
annual
compliance
report.

(
d)
An
estimated
8
hours
were
assumed
for
"
managing"
each
semi­
annual
report.

(
e)
Average
labor
costs
per
hour
are:
technical
­
$
47.04,

management
­
$
70.34,
clerical
­
$
28.67.
31
(
f)
Management
hours
are
assumed
to
equal
5
percent
of
the
total
technical
hours
required
and
clerical
hours
are
10
percent
of
the
technical
hours.
32
ATTACHMENT
4
TABLES
PRESENTING
DETAILED
BURDEN
ESTIMATES
33
TABLE
1.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
1
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
74
2,960
148
296
158.1
2.0
Plan
Activities
40
1
40
0
0
0
0
0.0
3.0
Training
16
1
16
0
0
0
0
0.0
4.0
Create,
Test,
and
Research
and
Development
60
1
60
0
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
0
0
0
0
0.0
6.0
Process/
Compile
and
Review
8
12
96
0
0
0
0
0.0
7.0
Complete
Reports
8
2
16
0
0
0
0
0.0
8.0
Record/
Disclose
4
2
8
0
0
0
0
0.0
9.0
Store/
File
4
2
8
0
0
0
0
0.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
192
­­
428
74
2,960
148
296
158.1
34
TABLE
2.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
2
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
0
0
0
0
0.0
2.0
Plan
Activities
40
1
40
0
0
0
0
0.0
3.0
Training
16
1
16
0
0
0
0
0.0
4.0
Create,
Test,
and
Research
and
Development
60
1
60
0
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
0
0
0
0
0.0
6.0
Process/
Compile
and
Review
8
12
96
0
0
0
0
0.0
7.0
Complete
Reports
8
2
16
0
0
0
0
0.0
8.0
Record/
Disclose
4
2
8
0
0
0
0
0.0
9.0
Store/
File
4
2
8
0
0
0
0
0.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
192
­­
428
74
0
0
0
0.0
35
TABLE
3.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
3
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
0
0
0
0
0.0
2.0
Plan
Activities
40
1
40
74
2,960
148
296
158.1
3.0
Training
16
1
16
74
1,184
59
118
63.3
4.0
Create,
Test,
and
Research
and
Development
60
1
60
74
4,440
222
444
237.2
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
0
0
0
0
0.0
6.0
Process/
Compile
and
Review
8
12
96
0
0
0
0
0.0
7.0
Complete
Reports
8
2
16
0
0
0
0
0.0
8.0
Record/
Disclose
4
2
8
0
0
0
0
0.0
9.0
Store/
File
4
2
8
0
0
0
0
0.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
192
­­
428
74
8,584
429
858
458.6
36
TABLE
4.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
4
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
74
296
15
30
15.8
2.0
Plan
Activities
8
1
8
74
592
30
59
31.6
3.0
Training
8
1
8
74
592
30
59
31.6
4.0
Create,
Test,
and
Research
and
Development
0
1
0
74
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
74
10,656
533
1,066
569.3
6.0
Process/
Compile
and
Review
8
12
96
74
7,104
355
710
379.5
7.0
Complete
Reports
8
2
16
74
1,184
59
118
63.3
8.0
Record/
Disclose
4
2
8
74
592
30
59
31.6
9.0
Store/
File
4
2
8
74
592
30
59
31.6
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
74
21,608
1,080
2,161
1,154.4
37
TABLE
5.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
5
AND
YEAR
6
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
74
296
15
30
15.8
2.0
Plan
Activities
8
1
8
74
592
30
59
31.6
3.0
Training
8
1
8
74
592
30
59
31.6
4.0
Create,
Test,
and
Research
and
Development
0
1
0
74
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
74
10,656
533
1,066
569.3
6.0
Process/
Compile
and
Review
8
12
96
74
7,104
355
710
379.5
7.0
Complete
Reports
8
2
16
74
1,184
59
118
63.3
8.0
Record/
Disclose
4
2
8
74
592
30
59
31.6
9.0
Store/
File
4
2
8
74
592
30
59
31.6
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
74
21,608
1,080
2,161
1,154.4
38
TABLE
6.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
1
­
NEW
FACILITIES
(
YEARS
2,
3,
4,
5,
AND
6
WILL
BE
IDENTICAL,
AS
4
NEW
FACILITIES
ARE
CONSTRUCTED
EACH
YEAR)

Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
4
160
8
16
8.5
2.0
Plan
Activities
40
1
40
4
160
8
16
8.5
3.0
Training
16
1
16
4
64
3
6
3.4
4.0
Create,
Test,
and
Research
and
Development
60
1
60
4
240
12
24
12.8
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
4
576
29
58
30.8
6.0
Process/
Compile
and
Review
8
12
96
4
384
19
38
20.5
7.0
Complete
Reports
8
2
16
4
64
3
6
3.4
8.0
Record/
Disclose
4
2
8
4
32
2
3
1.7
9.0
Store/
File
4
2
8
4
32
2
3
1.7
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
192
­­
428
4
1,712
86
171
91.5
39
TABLE
7.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
2
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
4
16
1
2
0.9
2.0
Plan
Activities
8
1
8
4
32
2
3
1.7
3.0
Training
8
1
8
4
32
2
3
1.7
4.0
Create,
Test,
and
Research
and
Development
0
1
0
0
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
4
576
29
58
30.8
6.0
Process/
Compile
and
Review
8
12
96
4
384
19
38
20.5
7.0
Complete
Reports
8
2
16
4
64
3
6
3.4
8.0
Record/
Disclose
4
2
8
4
32
2
3
1.7
9.0
Store/
File
4
2
8
4
32
2
3
1.7
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
4
1,168
58
117
62.4
40
TABLE
8.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
3
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
8
32
2
3
1.7
2.0
Plan
Activities
8
1
8
8
64
3
6
3.4
3.0
Training
8
1
8
8
64
3
6
3.4
4.0
Create,
Test,
and
Research
and
Development
0
1
0
8
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
8
1,152
58
115
61.5
6.0
Process/
Compile
and
Review
8
12
96
8
768
38
77
41.0
7.0
Complete
Reports
8
2
16
8
128
6
13
6.8
8.0
Record/
Disclose
4
2
8
8
64
3
6
3.4
9.0
Store/
File
4
2
8
8
64
3
6
3.4
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
8
2,336
117
234
124.8
41
TABLE
9.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
4
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
12
48
2
5
2.6
2.0
Plan
Activities
8
1
8
12
96
5
10
5.1
3.0
Training
8
1
8
12
96
5
10
5.1
4.0
Create,
Test,
and
Research
and
Development
0
1
0
12
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
12
1,728
86
173
92.3
6.0
Process/
Compile
and
Review
8
12
96
12
1,152
58
115
61.5
7.0
Complete
Reports
8
2
16
12
192
10
19
10.3
8.0
Record/
Disclose
4
2
8
12
96
5
10
5.1
9.0
Store/
File
4
2
8
12
96
5
10
5.1
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
12
3,504
175
350
187.2
42
TABLE
10.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
5
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
16
64
3
6
3.4
2.0
Plan
Activities
8
1
8
16
128
6
13
6.8
3.0
Training
8
1
8
16
128
6
13
6.8
4.0
Create,
Test,
and
Research
and
Development
0
1
0
16
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
16
2,304
115
230
123.1
6.0
Process/
Compile
and
Review
8
12
96
16
1,536
77
154
82.1
7.0
Complete
Reports
8
2
16
16
256
13
26
13.7
8.0
Record/
Disclose
4
2
8
16
128
6
13
6.8
9.0
Store/
File
4
2
8
16
128
6
13
6.8
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
16
4,672
234
467
249.6
43
TABLE
11.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
6
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
20
80
4
8
4.3
2.0
Plan
Activities
8
1
8
20
160
8
16
8.5
3.0
Training
8
1
8
20
160
8
16
8.5
4.0
Create,
Test,
and
Research
and
Development
0
1
0
20
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
12
12
144
20
2,880
144
288
153.9
6.0
Process/
Compile
and
Review
8
12
96
20
1,920
96
192
102.6
7.0
Complete
Reports
8
2
16
20
320
16
32
17.1
8.0
Record/
Disclose
4
2
8
20
160
8
16
8.5
9.0
Store/
File
4
2
8
20
160
8
16
8.5
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
56
­­
292
20
5,840
292
584
312.0
44
TABLE
12.
SUMMARY
OF
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEARS
1,
2,
AND
3
YEAR
EXISTING
SOURCE
COSTS
($
1,000)
EXISTING
SOURCE
BURDEN
(
HOURS)
NEW
SOURCE
COSTS
($
1,000)
NEW
SOURCE
BURDEN
(
HOURS)
TOTAL
NATIONWIDE
ANNUAL
COSTS
($
1,000)
TOTAL
NATIONWIDE
BURDEN
(
HOURS)

1
158.1
3,404
91.5
1,969
249.6
5,373
2
0.0
0
153.9
3,312
153.9
3,312
3
458.6
9,872
216.3
4,655
674.9
14,527
AVERAGE
COST
205.6
4,425
153.9
3,312
359.4
7,737
45
TABLE
13.
SUMMARY
OF
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEARS
4,
5,
AND
6
YEAR
EXISTING
SOURCE
COSTS
($
1,000)
EXISTING
SOURCE
BURDEN
(
HOURS)
NEW
SOURCE
COSTS
($
1,000)
NEW
SOURCE
BURDEN
(
HOURS)
TOTAL
NATIONWIDE
ANNUAL
COSTS
($
1,000)
TOTAL
NATIONWIDE
BURDEN
(
HOURS)

4
1,154.4
24,849
278.7
5,998
1,433.0
30,848
5
1,154.4
24,849
341.1
7,342
1,495.4
32,191
6
1,154.4
24,849
403.5
8,685
1,557.8
33,534
AVERAGE
COST
1,154.4
24,849
341.1
7,342
1,495.4
32,191
46
TABLE
14.
SUMMARY
OF
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
1
THROUGH
YEAR
6
YEAR
EXISTING
SOURCE
COSTS
($
1,000)
EXISTING
SOURCE
BURDEN
(
HOURS)
NEW
SOURCE
COSTS
($
1,000)
NEW
SOURCE
BURDEN
(
HOURS)
TOTAL
NATIONWIDE
ANNUAL
COST
($
1,000)
TOTAL
NATIONWIDE
BURDEN
(
HOURS)

1
158.1
3,404
91.5
1,969
249.6
5,373
2
0.0
0
153.9
3,312
153.9
3,312
3
458.6
9,872
216.3
4,655
674.9
14,527
4
1,154.4
24,849
278.7
5,998
1,433.0
30,848
5
1,154.4
24,849
341.1
7,342
1,495.4
32,191
6
1,154.4
24,849
403.5
8,685
1,557.8
33,534
AVERAGE
680.0
14,637
247.5
5,327
927.4
19,964
47
TABLE
15.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
1
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
4
32
2
3
1.7
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
i)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
initial
notification
8
78
624
31
62
33.3
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
48
l)
periodic
reports
of
compliance
status
12
8
96
5
10
5.1
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
752
38
75
40.2
TABLE
16.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
2
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
4
32
2
3
1.7
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
49
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
4
32
2
3
1.7
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
16
192
10
19
10.3
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
256
13
26
13.7
TABLE
17.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
3
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
50
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
4
32
2
3
1.7
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
4
32
2
3
1.7
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
24
288
14
29
15.4
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
352
18
35
18.8
51
TABLE
18.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
4
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
78
624
31
62
33.3
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
78
624
31
62
33.3
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
52
l)
periodic
reports
of
compliance
status
12
180
2,160
108
216
115.4
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
3,408
170
341
182.1
TABLE
19.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
5
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
4
32
2
3
1.7
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
53
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
4
32
2
3
1.7
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
188
2,256
113
226
120.5
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
2,320
116
232
123.9
TABLE
20.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
6
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
54
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
4
32
2
3
1.7
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
4
32
2
3
1.7
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
196
2,352
118
235
125.7
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
2,416
121
242
129.1
55
TABLE
21.
SUMMARY
OF
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
1
THROUGH
YEAR
6
YEAR
BURDEN
(
HOURS)
COST
($
1,000)

1
865
40.2
2
294
13.7
3
405
18.8
ANNUAL
AVERAGE
(
1ST
3
YRS)
521
24.2
4
3,919
182.1
5
2,668
123.9
6
2,778
129.1
ANNUAL
AVERAGE
(
2ND
3
YRS)
3,122
145.0
56
ATTACHMENT
5
LIST
OF
PARTICIPATING
STAKEHOLDERS
57
LARGE
APPLIANCES
SURFACE
COATING
NESHAP
STAKEHOLDER
LIST
STAKEHOLDER
AFFILIATION
TELEPHONE
FACSIMILE
Steven
Bachellor
Lennox
Industries,
Inc.
(
515)
754­
4361
(
515)
754­
4040
Onsoon
Berglund
Minnesota
Pollution
Control/
Agency,
AQD
(
612)
296­
7595
(
612)
297­
7709
Jim
Berry
Berry
Environmental
(
919)
785­
9631
(
919)
785­
9631
Cheryl
Bradley
Oklahoma
DEQ,
Air
Quality
Division
(
405)
290­
8247
(
405)
962­
2200
Robert
Buchanan
Texas
Natural
Resource
Conservation
Commission
(
512)
239­
5818
(
512)
239­
4808
John
Burchard
Arizona
DEQ,
Air
Quality
Division
(
602)
207­
2308
(
602)
207­
2366
Steve
Byrne
Cytec
(
973)
425­
0185
(
973)
425­
8406
Barbara
Ann
Cook
Rheem
Manufacturing
Company
(
212)
916­
8100
(
212)
916­
8109
John
Craichy
SBTDC
(
919)
715­
2650
(
919)
715­
0518
Rick
Crume
Resource
Consultants
Consulting
and
Engineering
(
615)
370­
6260
Kathy
Davey
US
Environmental
Protection
Agency
(
OPPTS)
(
202)
260­
2290
(
202)
260­
0178
Kirk
Drucker
Georgia
Department
of
Natural
Resources
(
404)
363­
7127
(
404)
363­
7100
Dennis
Dubitsky
Hussmann
Corporation
(
314)
298­
6541
(
314)
298­
6484
Robert
Eckdale
Wisconsin
Department
of
Natural
Resources
Bureau
of
Air
Management
(
AM/
7)
(
608)
266­
2856
(
732)
980­
6304
Dan
Elliott
The
Trane
Company
(
American
Standard)
(
908)
980­
3256
(
732)
980­
6304
Jeff
Estep
W.
C.
Wood
Company,
Inc.
(
419)
523­
9663
(
419)
523­
6168
Andrew
Fischer
Rheem
Manufacturing
Company
(
334)
279­
8930
(
334)
260­
1323
Ann
Foss
Minnesota
Pollution
Control
Agency,
AQD
(
612)
296­
7512
(
612)
297­
7709
Kenneth
Gabele
The
Sherwin­
Williams
Company
(
216)
566­
3316
(
216)
566­
2920
Michael
Garrison
State
Industries,
Inc.
(
615)
792­
6291
(
615)
792­
2124
Patrick
Guin
Resource
Consultants,

Consulting
&
Engineering
Services
(
615)
370­
6260
(
615)
370­
9198
(
615)
373­
3645
Madelyn
Harding
The
Sherwin­
Williams
Company
(
216)
566­
2630
(
216)
566­
2730
Bill
Haynes
Marathon
Equipment
Company
(
205)
695­
9105
(
205)
695­
7250
Dan
Herlihy
South
Carolina
Dept.
of
Health
&
Envir.
Control
(
DHEC)
803)
661­
4825
Linda
Herring
US
Environmental
Protection
Agency,
OAQPS/
ESD
(
919)
541­
5358
(
919)
541­
5689
Tim
Hooker
General
Electric
Appliances
(
502)
452­
4797
(
502)
452­
0441
Julie
Ingoli
Raytheon
Appliances
(
319)
622­
2785
(
319)
622­
2180
Joe
Junker
ARCO
Chemical
(
610)
359­
6846
(
610)
359­
2778
Robert
Karwowski
Whirlpool
Corporation
(
616)
923­
3614
(
616)
923­
5486
Glen
Kedzie
National
Paint
and
Coatings
Association
(
202)
462­
6272
Mike
Kendall
Campbell,
Dames,
and
Moore
(
301)
652­
2215
Christopher
Kent
U.
S.
Environmental
Protection
Agency
(
OPPTS)
(
202)
260­
3480
(
202)
260­
0178
Alan
Kessler
Raytheon
Appliances
(
319)
622­
2785
(
319)
622­
8428
Randy
Koppenhaven
Pennsylvania
Department
of
Environmental
Resources,

Bureau
of
Air
Quality
(
717)
787­
1663
(
717)
772­
2303
58
Frank
Losey
Brown
&
Company
(
205)
544­
9614
(
202)
544­
9618
Joe
Mattingly
Gas
Appliance
Manufacturers
Association
(
GAMA)
(
703)
525­
9565
(
703)
525­
0718
David
Mazzocco
PPG
Industries,
Inc.
(
412)
492­
5476
(
412)
492­
5377
Robert
McCrillis
US
Environmental
Protection
Agency
(
919)
541­
2733
(
919)
541­
0359
Jack
McGrogan
Pennsylvania
Dept.
of
Env.
Resources,
Bureau
of
AQ
(
717)
787­
1663
(
717)
772­
2303
Wayne
Morris
Association
of
Home
Appliance
Manufacturers
(
AHAM)
(
202)
434­
7478
Robert
(
Bob)
Mulliner
The
Trane
Company
(
608)
787­
2000
(
608)
787­
4261
Hank
Naour
Illinois
Environmental
Protection
Agency
(
217)
785­
4140
(
217)
525­
5023
Robert
J.
(
Bob)
Nelson
National
Paint
&
Coatings
Association
(
202)
462­
6272
(
202)
462­
8549
Carol
Niemi
Coating
Manufacturers
Association
Solvents
Council
(
517)
631­
4923
Khanh
Nguyen
Missouri
DNR
DEQ
Air
Pollution
Control
Program.
(
573)
751­
4817
(
573)
751­
2706
Jim
Orlemann
Ohio
EPA
Division
of
Air
Pollution
Controls
(
614)
644­
2270
(
614)
644­
3681
Venkata
Panchakarla
Florida
Dept.
of
Env..
Protection
(
FDEP)
(
904)
488­
0114
(
904)
922­
6979
John
Patton
Tennessee
DEC
Division
of
Air
Pollution
Control
(
615)
532­
0554
(
615)
532­
0614
Oscar
Robertson
White
Consolidated
Industries,
Inc.
(
216)
252­
8778
(
216)
252­
8160
Bob
Rose
U.
S.
Environmental
Protection
Agency
(
OSDBU)
(
703)
305­
5511
(
703)
305­
6462
Ray
Rusek
Maytag
Appliances
(
515)
791­
5749
(
515)
791­
5898
Charles
Samuels
Association
of
Home
Appliance
Manufactures
(
AHAM)
(
202)
434­
7311
(
202)
434­
7400
Tom
Sanford
Porcelain
Enamel
Institute
(
615)
387­
5357
(
615)
385­
5463
Jim
Sell
National
Paint
&
Coatings
Association
(
202)
462­
6272
(
202)
462­
8549
Mohinder
Sharma
Lilly
Industries,
Inc.
(
309)
762­
7546
(
309)
762­
9604
Don
Smith
South
Carolina
Dept.
of
Health
&
Envir.
Control
(
DHEC)
(
803)
661­
4825
(
803)
661­
4858
Michael
Sproule
PPG
Industries
(
614)
362­
6700
(
614)
362­
6802
Dale
Sweet
Carrier
Corporation
(
315)
432­
7875
(
315)
432­
3344
Scott
Throwe
U.
S.
Environmental
Protection
Agency
(
202)
564­
7013
(
202)
564­
0050
Jason
Trussell
Missouri
DNR
DEQ,
Air
Pollution
Control
Program
(
573)
751­
4817
(
573)
751­
2706
Larry
Wethje
Air
Conditioning
and
Refrigeration
Institute
(
703)
524­
8800
(
703)
528­
3816
Mark
Yohman
Lennox
International
(
972)
497­
5069
(
972)
497­
5268
Bernie
Zysman
Occidental
Chemical
Corporation
(
716)
278­
7894
(
716)
278­
7297
