1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
Subpart
VVV
Polymeric
Coating
of
Supporting
Substrates
Facilities
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Standards
of
Performance
for
New
Stationary
Sources;
Polymeric
Coating
of
Supporting
Substrates
Facilities,
Subpart
VVV.

1(
b)
Short
Characterization/
Abstract
In
general,
all
New
Source
Performance
Standards
(
NSPS)
require
initial
notifications,

performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,

maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.

In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
Environmental
Protection
Agency
(
EPA)
Regional
Office.
2
The
NSPS
for
Subpart
VVV,
Polymeric
Coating
of
Supporting
Substrates
Facilities,
were
proposed
on
April
30,
1987
and
promulgated
on
September
11,
1989.
These
standards
apply
to
each
coating
operation
and
any
on­
site
coating
mix
preparation
equipment
used
to
prepare
coatings
for
the
polymeric
coating
of
supporting
substrates
for
which
construction,
modification
or
reconstruction
after
the
date
of
proposal.
Any
affected
facility
for
which
the
amount
of
volatile
organic
compounds
(
VOC)
used
is
less
than
95
Mg
per
12­
month
period
is
subject
only
to
the
requirements
of
§
§
60.744(
b),
60.747(
b)
and
60.747(
c).
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
VVV.

Approximately
51
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
an
additional
one
plant
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
This
estimate
is
based
on
the
number
of
sources
("
coating
operations
and
any
onsite
mix
preparation
equipment")
subject
to
the
NSPS
listed
in
the
Air
Facility
System
(
AFS)
database.
The
list
of
sources
were
estimated
using
the
Standard
Industry
Classification
(
SIC)
codes
listed
under
Section
4(
a)
of
the
Proposed
Rule
Federal
Register
of
April
30,
1987.
We
have
also
assumed
that:
1)
each
existing
plant
has
one
solvent­
borne
coating
operation
subject
to
this
NSPS;
2)
a
total
of
5
new
coating
lines
per
year
will
be
installed
at
existing
plants,
of
which
4
are
solventborne
lines
and
one
is
a
water­
borne
line;
and
3)
the
new
plant
will
install
at
least
one
solventborne
coating
operation.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:
3
Application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
Section
111(
a)(
l).

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;

(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
VOC
emissions
from
polymeric
coating
of
supporting
4
substrates
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
an
NSPS
was
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
VVV.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
VOCs
from
polymeric
coating
of
supporting
substrates
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOCs
from
polymeric
coating
of
supporting
substrates
facilities
are
generated
by
each
coating
operation
and
the
associated
onsite
coating
mix
preparation
equipment
used
to
prepare
coatings
for
the
polymeric
coating
of
supporting
substrates.
These
standards
rely
on:
the
capture
of
VOC
emissions
by
a
partial
or
total
enclosure
around
the
coating
operation
("
alternative
standard"),
and/
or
by
covers
on
each
piece
of
affected
mix
preparation
equipment;
the
reduction
of
VOC
emissions
to
the
atmosphere
from
the
coating
operation
to
a
control
device
("
emission
reduction
standard"),
and/
or
from
the
affected
covered
equipment
to
a
control
device;
and
the
recovery
of
VOC
emissions
at
one
coating
operation
if
the
liquid
material
balance
is
used
to
demonstrate
compliance
.

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
determine
if
pollution
control
devices
are
properly
installed
and
operated,
or
the
emission
reduction
standard
is
being
met.
Operating
conditions
that
may
be
noted
include:
a
measure
of
the
gaseous
volumetric
flow
rates;
VOC
emissions
from
the
coating
operation;
capture
efficiency
of
the
control
device;
amount
of
coating
applied
at
the
coating
applicator
after
all
ingredients
have
been
added
to
the
coating;
VOC
content
of
all
coatings;
a
measure
of
the
cumulative
amount
of
5
VOC
recovered
by
the
control
device
over
a
nominal
1­
month
period;
the
average
inward
face
velocity
across
all
natural
draft
openings
of
a
total
enclosure;
and
other
parameters
that
demonstrate
a
total
enclosure
has
been
properly
installed.
The
initial
notifications
are
used
to
determine
the
compliance
provisions
that
would
apply
to
an
affected
facility.
Performance
test
reports
are
needed
to
document
for
the
Agency
that
a
source
is
capable
of
complying
with
the
emission
standard,
and
under
what
operating
conditions
compliance
was
achieved.
The
semiannual
reports
of
no
exceedances
or
of
compliance,
and
the
quarterly
reports
of
periods
of
noncompliance
are
used
for
problem
identification
and
for
compliance
determinations.

The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
achieve
compliance
with
the
NSPS.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
VVV.

3(
a)
Nonduplication
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
6
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
September
15,
2000,
(
65FR55955).
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

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
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.5.

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
7
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
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
polymeric
coating
of
supporting
substrates
facilities
including:

Regulation
SIC
Codes
NAICS
Codes
NSPS
Subpart
VVV
­
Polymeric
Coating
of
Supporting
Substrates
Facilities
2241
2295
2296
2394
3052
3053
3069
313221
31332
314992
314912
32622
339991
31332
315299
315999
339113
33992
339932
326192
326299
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
VVV.

A
source
must
make
the
following
reports:
8
Reports
for
NSPS
SUBPART
VVV
Construction/
reconstruction.
60.7(
a)(
1)

Actual
startup.
60.7(
a)(
3)

Initial
performance
test
results.
60.8
(
a)

Initial
performance
test.
60.8(
d)

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

Physical
or
operational
change.
60.7(
a)(
4)

Projected
and
actual
VOC
use,
if
VOC
use
is
less
than
95.0Mg/
yr
or
less
than
130
Mg/
yr.
60.747
Excess
emissions
or
periods
of
noncompliance
quarterly.
60.747(
d)(
1)­(
6)
and
60.747(
e)(
2)

No
excess
emissions/
no
deviations
from
operating
parameters
semiannually.
60.747(
d)(
7)
and
60.747(
e)(
1)

A
source
must
maintain
the
following
records:

Recordkeeping
for
NSPS
SUBPART
VVV
Record
startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)

Records
for
performance
test
measurements.
60.8(
a)

Record
projected
VOC
use
and
actual
12­
month
VOC
use,
operating
parameters
(
e.
g.,
concentration
level
of
organic
compounds,
periods
of
actual
coating
operations,
system
efficiency,
average
combustion
temperature,
gas
temperature
before
and
after
the
catalytic
bed)
of
the
control
device
(
e.
g.,
carbon
absorption
system,
thermal
incinerator,
and
catalytic
incinerator)
and
other
parameters
depending
on
the
compliance
method
being
used
60.747
Records
for
sources
with
continuous
monitoring
systems.
60.7(
f)

Records
are
required
to
be
retained
for
2
years.
The
first
2
years
of
records
must
be
kept
onsite.
60.747(
h)
9
ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
required
monitoring
devices
to
continuously
monitor
the
concentration
level
of
organic
compounds,
the
combustion
temperature,
gas
temperature
or
other
value
of
the
chosen
parameter,
depending
on
the
control
device
used.
60.744(
c­
g)

Monitor
projected
and
actual
VOC
use.
60.744(
b)

Perform
performance
tests
and
use
the
appropriate
reference
methods:
Reference
Method
24
test
to
determine
VOC
content
in
coating
or
formulation
data
(
if
approved
by
Administrator);
Reference
method
25
(
or
alternative
methods
18,
or
25A)
to
determine
incinerator
VOC
gas
streams
concentration,
the
efficiency
of
a
fixed­
bed
carbon
adsorption
system;
Method
1
or
1A
for
sample
and
velocity
traverses;
Method
2,
2A,
2C
or
2D
for
velocity
and
volumetric
rates;
Method
3
for
gas
analysis;
and
Method
4
for
stack
gas
moisture
measurements.

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
10
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,

and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
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
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
quarterly
reports
of
non­
compliance
and
semiannual
reports
of
compliance
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
11
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(
s).
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development
and
the
requirements
reflect
the
burden
on
small
businesses.
Even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
to
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
of
the
Subparts
included
in
this
ICR.

The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.
12
40
CFR
Part
60.747.

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
14,366
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
the
following
labor
rate:
$
57.12
per
hour
for
Technical.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2001,
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:

Technical
$
57.12
($
27.20
+
110%)

We
assume
a
technical
labor
rate
for
all
respondents'
activities
since
most
activities
will
be
of
this
nature,
and,
therefore,
is
our
best
estimate
for
calculating
respondent
burden.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor,
capital
expenditures
for
monitoring
devices,
and
operation
and
maintenance
of
those
devices.
The
capital
start­
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
13
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor.
Total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
(
A)

Continuous
Monitoring
device
(
B)

Start
up
cost
($)
for
1
affected
facility
(
C)

#
of
new
affected
facilities
to
start
up
(
D)

Total
start
up
(
B
X
C)
(
E)

Annual
O&
M
costs
($)
for
1
affected
facility
(
F)

#
of
affected
facilities
with
O&
M
(
G)

Total
O&
M
(
E
X
F)

VOC
monitor
35,000
1
35,000
7,500
56
420,000
Temperature
monitor
7,500
1
7,500
1,800
56
100,800
The
total
capital/
start­
up
costs
for
this
ICR
are
$
42,500.
This
is
the
total
of
column
D.

This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
the
nearest
thousand
and
are
truncated
to
show
the
cost
in
thousands
of
dollars.

The
total
operating
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
520,800.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
the
nearest
thousand
and
are
truncated
to
show
the
cost
in
thousands
of
dollars.

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
cost
for
capital
and
14
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
564,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
the
nearest
thousand
and
are
truncated
to
show
the
cost
in
thousands
of
dollars.

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
$
27,947
(
from
Table
1).
This
cost
is
based
on
an
average
labor
rate
of
a
GS
12
step
1
employee
rate.
This
rate
is
from
OPM's
2001
General
Schedule
(
GS)
base
annual
salary
data,

excluding
locality
pay,
basic
rates,
and
travel
associated
with
compliance
activities.
To
derive
the
hourly
estimates,
we
divided
annual
compensation
estimates
by
2,080
which
is
the
average
number
of
hours
worked
during
the
Federal
calendar
year.
We
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6
to
account
for
overhead
expenses.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
15
Respondent
Universe
Regulation
Title
(
A)

#
new
sources
per
year
(
B)

#
of
initial
reports
for
new
sources
(
C)

#
existing
sources
(
D)

#
of
reports
for
existing
sources
(
E)

total
annual
responses
(
A.
xB.)+(
CxD)

NSPS
Subpart
VVV
­
Polymeric
Coating
of
Supporting
Substrates
Facilities
5
4
51
3
173
The
number
of
total
respondents
is
56.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
anticipated
in
one
year.

The
total
annual
responses
is
173.
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
820,557.

The
total
annual
hours
requested
are
14,366.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
c.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
564,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.
These
costs
are
detailed
in
section
6
b
(
iii)

Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
the
attached
Tables
for
both
Government
and
Industry
burden
estimates.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
cost
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment
16
in
the
number
of
facilities
for
monitor
operation
and
maintenance
(
O&
M)
costs,
and
the
use
of
updated
labor
rates.
In
the
previous
ICR,
the
number
of
facilities
used
to
calculate
the
O&
M
costs
was
only
for
the
new
sources.
This
ICR
has
included
the
O&
M
costs
for
the
existing
sources
which
increased
the
total
O&
M
costs.
The
labor
rate
for
industry
is
based
on
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Groups
for
technical
personnel,
Table
10,
March
2001.
The
labor
rate
for
federal
employees
is
based
on
the
annual
wage
of
a
government
employee
at
a
grade
GS
12,

step
1.

The
decrease
in
hour
burden
from
the
most
recently
approved
ICR
is
due
to
a
change
in
the
rule
which
deleted
the
"
anticipated
startup
date"
as
a
reporting
requirement.
This
change
is
reflected
in
the
deletion
of
this
reporting
requirement
and
its
associated
burden
in
Table
2.

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
17
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
Ms.
Susan
Auby,
Collection
Strategies
Division,

(
Mail
Code
2822),
Office
of
Environmental
Information
(
OEI),
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
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
1284.06
and
OMB
Control
Number
2060­
0181
in
any
correspondence.

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