1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
Subpart
FFF
Flexible
Vinyl
and
Urethane
Coating
and
Printing
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
FFF
­
Flexible
Vinyl
and
Urethane
Coating
and
Printing
Industry
Subject
to
New
Source
Performance
Standards
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
FFF
were
proposed
on
January
18,
1983,
and
promulgated
on
June
29,
1984.
These
standards
apply
to
the
following
facilities
in
Subpart
FFF:
each
rotogravure
printing
line
used
to
print
or
coat
flexible
vinyl
or
urethane
products,
and
for
which
construction,
modification
or
reconstruction
commenced
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
FFF.
Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Monitoring
requirements
specific
to
this
rule
provide
information
on
the
operation
of
emissions
control
devices.
Semiannual
reports
of
excess
emissions
or
exceedances
of
standards
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
NSPS.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
2
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
Approximately
10
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
one
additional
source
will
become
subject
to
the
standard
in
the
next
three
years.
The
cost
of
this
ICR
will
be
$
18,085.70
dollars.
The
numbers
of
sources
is
based
upon
an
AIRS
data
pull.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
2
of
performance
for
new
stationary
sources
that
reflect:
.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
nonair
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
111(
a)(
l)].
The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.
In
addition,
Section
114(
a)
States
that:
.
.
.
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to
(
A)
establish
and
maintain
such
records,
(
B)
make
such
reports,
(
C)
install,
use,
and
maintain
such
monitoring
equipment
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.
In
the
Administrator's
judgment,
volatile
organic
compound
emissions
from
printing
or
coating
on
flexible
vinyl
and
urethane
products
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
FFF.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
volatile
organic
compounds
from
printing
and
coating
flexible
vinyl
and
urethane
products
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
volatile
organic
compounds
are
the
result
of
operation
of
the
printing
on
flexible
vinyl
and
urethane
coating.
These
standards
rely
on
the
reduction
of
volatile
organic
compounds
emissions
by
using
inks
with
low
VOC
contents
or
on
the
capture
of
those
compounds
by
either
solvent
recovery
systems,
thermal
incinerators
or
catalytic
incinerators.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
(
if
this
method
is
chosen
to
comply
with
the
regulation)
are
properly
installed
and
operated
and
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
For
facilities
using
control
equipment
to
meet
this
standard,
the
operating
conditions
may
include
temperature
or
volatile
organic
compound
concentration.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
3
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
FFF.
If
the
standard
has
not
been
delegated
the
information
is
sent
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
a
copy
of
the
report
submitted
to
the
State
or
Local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
Standard.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
October
29,
1999.

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

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

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
Subpart
FFF
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.
4
3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
Subpart
FFF
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
Subpart
FFF
that
commenced
construction,
modification,
or
reconstruction
after
January
18,
1983.
They
are
listed
under
SIC
Codes
2295
and
2679.
Both
of
these
Codes
contain
firms
that
are
not
covered
by
this
rule.
This
rule
does
not
cover
resilient
floor
covers
or
flexible
packaging.
The
government
is
in
the
process
of
transitioning
to
the
new
North
American
Industrial
Classification
System
(
NAICS).
The
NAICS
codes
for
this
industry
are
31332,
322222,
and
322299.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60
Subpart
FFF.
A
source
must
make
the
following
reports
Notification
Reports
Initial
notification
of
Construction/
reconstruction
60.7(
a)(
1)

Physical
or
operational
change
60.7(
a)(
4)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
60.8(
d)
Notification
Reports
5
Delay
of
/
and
rescheduled
initial
performance
test
60.8(
d)

Demonstration
of
continuous
monitoring
system
60.7(
a)(
5)

Reports
Initial
performance
test
results
60.8
(
a),
60.585(
a)

Excess
emission
reports
­
semi
annual
reports
60.7(
c)
&(
d),
60.585(
b)

A
source
must
keep
the
following
records.

Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b),
60.584(
d)

Records
for
sources
with
continuous
monitoring
systems
60.7(
d)

Maintain
file
of
all
measurements
60.7(
e),
60.583(
b),

60.583(
c)

Records
of
performance
test
conditions
60.8(
c)

Records
of
operating
conditions
for
control
equipment
(
i.
e.
Temp
or
VOC
concentration
60.584(
a)(
2),

60.584(
b)(
2),

60.584(
c)(
2)

Records
are
required
to
be
retained
for
2
Years.
The
first
2
years
of
records
must
be
kept
onsite.

ii.
Respondent
Activities
6
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
VOC
concentration
or
temperature..

Perform
initial
performance
test,
see
60.583
,
60.584,
and
60.580
(
c)
for
test
methods.
Repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
information
required
under
40
CFR
Subpart
FFF:

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.
Agency
Activities
7
Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

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

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
{
VOC
concentration
or
temperature}
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant.
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
smaller
businesses
may
have
smaller
production
capabilities
and
may
have
less
data
to
record.
Even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
8
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Since
this
rule
has
been
in
effect
since
1984,
the
respondents
have
had
years
of
experience
with
the
existing
recordkeeping
and
reporting
requirements.
There
has
been
no
change
to
those
requirements,
therefore
no
additional
costs
are
involved
in
adjusting
their
system.
Occurences
of
CMS
upkeep
however
was
adjusted
in
the
table.
The
regulation
required
annual
calibration
and
proper
maintenance
of
the
equipment.
The
previous
ICR
had
250
occurances
per
year.
This
ICR
adjusts
that
to
weekly
(
52
times
per
year)
minor
adjustment.
This
should
more
realistically
reflect
the
annual
calibration
and
minor
adjustments
needed
through
the
year.
Responses
to
this
information
collection
are
mandatory.
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
329.19
(
total
from
industry
table)
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
I)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
54.94
.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead
As
with
most
older
NSPS
or
NESHAP
standards,
one
labor
class
is
used
­
the
technical
labor
rate.
These
standards
only
use
technical
labor
because
they
are
not
as
sophisticated
as
MACT
standards.
These
standards
are
over
17
years
old
and
for
all
the
existing
facilities
are
standard
procedures
which
involve
mantaining
records
of
materials
usage
or
reading
results
from
CMS.
There
is
no
need
for
management
or
clerical
involvement.
Reports
can
be
generated
using
the
technical
staff
person's
computer.
9
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
CEMs,
for
solvent
recovery
or
incineration
(
if
used).
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
capital
start
up
costs
for
this
regulation
are
$
6,600
dollars.
This
is
based
on
1
new
source
per
3
year
ICR
period
or
.3
sources
per
year
multiplied
by
$
20,000
per
CMS.
The
annual
operations
and
maintenance
costs
are
$
45,000
dollars.
This
is
based
on
5
of
the
10
existing
sources
using
control
devices
(
and
therefore
CMS)
multiplied
by
$
9,000
for
upkeep
of
the
monitoring
device.
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
51,600.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Monitoring
device
start
up
cost
($)
annual
O&
M
costs
($)
For
1
unit
For
1
unit
Continuous
monitor
$
20,000
$
9,000
for
control
device
or
temperature
or
feed
rate
monitor
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
1,950.90
(
from
table
1).
This
cost
is
based
on
an
average
wage
of
a
(
GS
10
step
1
employee
rate,
($
16.52
hr
+
110%
overhead
=
$
34.69
)
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
NSPS
Subpart
FFF
is
10.
The
number
of
new
sources
subject
to
NSPS
Subpart
FFF
is
1.
The
number
of
total
respondents
is
10.33.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.
The
total
annual
responses
is
21,
this
number
is
calculated
from
the
number
of
new
sources
multiplied
by
the
number
of
initial
reports,
plus
the
number
of
existing
sources
multiplied
by
the
(
semiannual
or
whatever
the
requirements
are)
reports.
The
total
annual
labor
costs
are
329.19
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
51,600
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
10
Please
see
Tables
1
and
2.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment
in
the
hours
needed
for
calibration
of
the
CMS.
This
was
explained
in
section
6.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1157.06
and
OMB
control
number
2060­
0073
in
any
correspondence.

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