1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NESHAP
Subpart
EE,
Magnetic
Tape
Manufacturing
Operations
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
Subpart
EE,

Magnetic
Tape
Manufacturing
Operations
1(
b)
Short
Characterization/
Abstract
In
general
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
2
to
NESHAP.

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
5
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
EPA
Regional
Office.

The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
Magnetic
Tape
Manufacturing
Operations
were
proposed
on
March
11,
1994
and
promulgated
on
December
15,
1994
(
59
FR
64596).
These
standards
apply
to
the
following
magnetic
tape
manufacturing
operations
located
at
major
sources
of
hazardous
air
pollutants
(
HAP):
solvent
storage
tank,
mix
preparation
equipment,
coating
operation,
waste
handling
device,
and
condenser
vent
in
solvent
recovery
commencing
construction
or
reconstruction
after
March
11,
1994.

Exceptions
include
research
or
laboratory
facilities,
and
coating
operation
that
produce
a
quantity
of
magnetic
tape
that
is
one
percent
or
less
of
total
production.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63
Subpart
EE.

Approximately
thirteen
(
13)
sources
are
currently
subject
to
the
standard,
and
we
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.

We
assumed
that
three
coating
lines
are
expected
to
be
constructed
at
existing
sources
over
the
next
three
years.
This
information
was
developed
from
previous
estimates
and
checked
against
the
Agency's
IDEA
database.

2.
Need
for
and
Use
of
the
Collection
3
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction:

.
.
.
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
shall
require
the
maximum
degree
of
reduction
in
emissions
of
the
hazardous
air
pollutants
subject
to
this
section
(
Section
112(
d)(
2)).

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,
HAP
emissions
from
magnetic
tape
manufacturing
4
operations
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
63
Subpart
EE.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
HAP
from
magnetic
tape
manufacturing
operations
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
methyl
ethyl
ketone,
toluene,
methyl
isobutyl
ketone,
xylene
and
ethyl
benzene,
and
magnetic
particles
containing
chromium
dioxide
and
cobalt
compounds
from
magnetic
tape
manufacturing
operations
are
the
result
of
operation
of
the
facilities
that
are
specifically
associated
with
the
manufacture
of
magnetic
tape.
These
standards
rely
on
the
reduction
of
HAP
emissions
by
capturing
and
destroying
HAP
by
using
carbon
adsorbers,

incinerators
or
condensers,
or
using
reduced
HAP
coating
mix.
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
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.

Each
CEM
shall
record
the
inlet
and
outlet
concentrations
when
determining
percent
efficiency
if
this
is
applied
to
the
control
device.
Thermal
incinerators
and
catalytic
incinerators
require
thermocouples
to
measure
the
minimum
combustion
temperature
and
temperature
across
the
catalyst
bed
as
established
as
site­
specific
operating
parameters.
Each
thermocouple
calibration
5
shall
be
verified
or
replaced
every
three
months.

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
NESHAP
continue
to
operate
the
control
equipment
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
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
EE.

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
exists.
6
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
April
18,
2000.

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
1320.6.

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
7
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
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
magnetic
tape
manufacturing
operations.
The
primary
SIC
and
NAICS
Codes
for
the
respondents
affected
by
the
standards
are
SIC
Code
3695
and
NAICS
Code
334613
(
Magnetic
and
Optical
Recording
Media),
and
SIC
Code
2675
and
NAICS
Code
322226
(
Die­
cut
Paper
and
Paperboard
and
Cardboard).

4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
EE.

A
source
must
make
the
following
reports
8
Requirement
Regulation
reference
General
Provision
reference
Reports
for
NESHAP
Subpart
EE
­
Notification
of
intent
to
construct
or
reconstruct
63.707(
a)
63.9(
b),
63.5(
b)

­
Notification
and
report
of
construction
date
63.707(
a)
63.9(
b)(
4)

­
Notification
of
anticipated
startup
63.7.7(
a)
63.9(
b)(
4)

­
Actual
startup
notification
63.707(
a)
63.9(
b)(
4)

­
Notification
of
applicability
of
the
standard
63.707(
a),
(
b),
and
(
c)
63.9(
b)(
2)­(
3)

­
Develop
startup,
shutdown,
malfunction
plan,
submit
reports
63.707(
a)
and
63.707(
i)
63.6(
e)(
3)
and
63.10(
d)(
5)

­
Develop
quality
control
plan
for
CMS
63.707(
a)
63.8(
d)

­
Notification
and
report
of
performance
tests
and
results
63.707(
a)
63.7(
b),
63.8(
e),
63.9(
e)
and
(
g),
63.10(
d)(
2)
and
(
e)(
2)

­
Report
of
when
exceed
HAP
usage
cutoff
or
when
area
source
becomes
major
63.707(
j)
63.9(
b),
63.9(
h)

­
Notification
and
report
of
compliance
status
63.707(
a)
63.9(
h)(
2)­(
3)

­
Notification
and
report
for
waiver
application
63.707(
a)
63.7(
h)

­
Semiannual
reports
of
no
excess
emissions
63.707(
a)
and
(
i)
63.10(
e)(
3)

­
Quarterly
reports
of
monitoring
exceedances
and
excess
emissions
63.707(
a)
and
(
i)
63.10(
e)(
3)

Recordkeeping
for
NESHAP
Subpart
EE
­
5
year
retention
of
records
63.706(
a)
and
(
h)
63.10(
b)(
1)

­
Records
of
monitored
values,
maintenance,
startup,
shutdown,
malfunction
63.706(
a)
63.10(
b)(
2),
63.10(
c),
and
63.6(
e)

­
Records
of
the
freeboard
ratio
63.706(
b)
63.10(
b)(
2)

­
Records
of
CMS
maintenance,
calibration
63.706(
a)
63.8(
c),
63.8(
d)(
3),
63.10(
b)(
2),
63.10(
c)

­
Records
of
performance
tests
63.705,
63.706(
a)
63.10(
b)(
2)
9
­
Records
of
material
balance
calculation
63.706(
a)
and
(
d)
63.10(
b)(
2)

­
Records
of
HAP
usage
63.706(
e)
63.10(
b)(
2)

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CEM
for
VOC
inlet/
outlet
concentration
to
measure
efficiency
of
control
device,
and
thermocouples
to
measure
minimum
combustion
temperature
and
temperature
across
catalyst
bed
for
site­
specific
operating
parameters.
Maintain
records
of
coating
mix
HAP
concentration
and
measure
freeboard
ratio.

Perform
initial
performance
test,
EPA
Method
24
for
VOC
content
in
coatings,
EPA
Method
18
or
EPA
Method
25A
to
determine
HAP
or
VOC
concentrations
of
air
exhaust
streams,
EPA
Method
22
to
determine
visible
emissions,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

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

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

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

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

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

Transmit,
or
otherwise
disclose
the
information.

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,
10
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,
excess
emissions
reports,
startup,
shutdown,
malfunction
plan,
and
quality
control
plan
for
CMS
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.
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
11
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
five
years.

5(
c)
Small
Entity
Flexibility
Three
of
the
13
facilities
in
this
source
category
that
meet
the
applicability
criteria
are
small
businesses.
The
rule
will
significantly
impact
one
small
business.
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutants.
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
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.
Small
facilities
can
minimize
their
recordkeeping
and
reporting
burden
by
continuing
to
stay
in
compliance
with
the
regulations.
More
detailed
reporting
is
necessary
for
deviations
from
compliance.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.
12
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.

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
7042
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
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
technical
labor
rates
of
$
54.94
per
hour.
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
13
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor,
continuous
emission
monitoring,
a
material
balance
of
solvent
in
the
coating
operation
(
available
to
solvent
recovery
devices
like
carbon
absorbers
and
condensers),
or
recordkeeping
of
coating
mix
HAP
concentration.
The
capital
start­
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor.

(
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)

Total
enclosure
$
10,000
1
$
10,000
0
0
0
VOC
CEM
0
0
0
$
7,000
8
$
56,000
Thermocouples
0
0
0
$
1,800
13
$
23,400
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
10,000.
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
14
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
79,400.
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
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
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
89,400.
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
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
$
3626.00.
This
cost
is
based
on
an
average
wage
of
a
GS
10
step
1
employee
rate,
$
17.09
hr
+
110%
overhead
=
$
35.89.
This
rate
is
from
OPM's
2000
General
Schedule,
excluding
locality
pay,
basic
rates
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
15
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
total
respondents
is
13.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a..

This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.
The
total
annual
responses
is
26.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
386,889.
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
entities
are
$
89,400.
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
Tables
1
and
2
6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
solely
due
to
an
increase
in
the
labor
rate
estimates.
The
burden
hours
have
not
changed.

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
16
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,

Mail
code
2822,
1200
Pennsylvania
Avenue,
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
and
OMB
control
number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
TABLE
1:
AGENCY
BURDEN
(
A)

EPA
Hours
Per
Occurrence
(
B)

Occurrences
Per
Year
(
C)
EPA
Person­
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)

EPA
Person­
Hours
Per
Year
(
E=
CxD)
(
F)

Cost
a
($)

Initial
performance
test
b
60
0
0
0
0
0
Repeat
initial
performance
test
c
1.
Retesting
preparation
16
0
0
0
0
0
2.
Retesting
60
0
0
0
0
0
Report
review
Notification
of
intent
to
constr./
reconstr.
d
2
1
2
1
2
72
Notification
of
construction
date
d
2
1
2
1
2
72
Notification
of
anticipated
startup
d
2
1
2
1
2
72
Notification
of
actual
startup
d
2
1
2
1
2
72
Notification
of
applicability­­
existing
sources
e
2
0
0
0
0
0
Notification
of
applicability­­
new/
reconstr.
Sources
d
2
1
2
1
2
72
Notification
of
initial
performance
test
f
2
1
2
1
2
72
Report
of
initial
test
f
8
1
8
1
8
287
Notification
of
compliance
status
g
4
0
0
0
0
0
Startup,
shutdown,
malfunction
plan
h
4
0
0
0
0
0
Quality
control
plan
for
CMS
h
4
0
0
0
0
0
Report
of
monitoring
exceedances
and
i
periods
of
noncompliance
8
1
8
4
32
1148
Report
of
no
excess
emissions
i
2
2
4
12
48
1723
Report
for
facilities
below
cutoff
j
1
1
1
1
1
36
Report
of
area
source
becoming
a
major
k
source
or
exceeding
HAP
usage
cutoff
8
0
0
0
0
0
Waiver
application
l
8
0
0
0
0
0
TOTAL
BURDEN
AND
COST
(
SALARY)
101
3626
a
Costs
are
based
on
an
hourly
rate
of
$
17.09
plus
110
percent
of
overhead
which
equals
$
35.89.
b
Assumes
10
percent
of
the
number
of
tests
conducted
are
attended
by
EPA.
c
Assumes
that
20
percent
fail
the
initial
performance
tests
and
retest.
d
Assumes
that
one
new
coating
line
will
be
added
per
year.
This
line
will
be
at
an
existing
facility.
e
The
notification
of
the
applicability
of
the
standard
for
existing
sources
has
already
occurred.
f
Based
on
one
facility
conducting
test,
including
retest.
g
Assumes
no
facilities
require
notification.
h
Assumes
that
EPA
will
review
no
startup,
shutdown,
malfunction
plans
and
CMS
quality
control
plans.
i
The
number
of
noncompliance
reports
and
reports
of
no
excess
emissions
correspond
to
the
respondents
per
year
reported
in
Table
1
(
column
D)
multiplied
by
the
number
of
occurrences
per
year
reported
in
Table
1
(
column
B).
j
One
existing
facility
is
expected
to
be
below
the
solvent
usage
cutoff.
k
No
existing
area
sources
are
expected
to
exceed
the
HAP
usage
cutoff
or
become
area
sources.
l
Assumes
all
waiver
applications
have
been
submitted.
TABLE
2:
INDUSTRY
BURDEN
Burden
Item
a
(
A)

Person­
Hours
Per
Occurrence
(
B)

Number
of
Occurrences
Per
Year
(
C)

Person­
Hours
Per
Respondent
Per
Year
(
C=
AxB)
(
D)

Respondents
Per
Year
(
E)

Person­
Hours
Per
Year
(
E=
CxD)
(
F)

Cost
b
($)

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
c
1
1
1
0
0
0
B.
Required
activities
Tests
Initial
performance
test­­
APCD
d
445
1
445
0
0
0
Conduct
performance
test
method
audits
d
27
1
27
0
0
0
Repeat
initial
performance
test­­
APCD
e
445
1
445
0
0
0
Repeat
performance
test
method
audits
e
27
1
27
0
0
0
Initial
performance
test­­
total
enclosure
f
215
1
215
1
215
11812
Repeat
initial
performance
test­­
total
enclosure
e
215
1
215
0
0
0
Performance
test
for
VOC
CEM's
g
175
1
175
0
0
0
Quarterly
VOC
CEM
audits
g
10
4
40
8
320
17581
C.
Create
information
Included
in
3B
and
4E
D.
Gather
existing
information
Included
in
3B
and
4E
E.
Write
report
Notification
of
intent
to
constr./
reconstr.
f
6
1
6
1
6
330
Notification
of
construction
date
f
2
1
2
1
2
110
Notification
of
anticipated
start­
up
f
2
1
2
1
2
110
Actual
start­
up
notification
f
2
1
2
1
2
110
Notification
of
applicability
of
the
standard­­
existing
sources
c
2
1
2
0
0
0
Notification
of
applicability
of
the
standard­­
new/
reconstructed
sources
f
2
1
2
1
2
110
Notification
of
initial
performance
test
h
2
1
2
0
0
0
Report
of
initial
test
Included
in
3B
Notification
of
compliance
status
i
4
1
4
0
0
0
Submit
startup,
shutdown,
malfunction
plan
i
20
1
20
0
0
0
Develop
and
implement
quality
control
plan
for
continuous
monitoring
systems
(
CMS)
i
50
1
50
0
0
0
Burden
Item
a
(
A)

Person­
Hours
Per
Occurrence
(
B)

Number
of
Occurrences
Per
Year
(
C)

Person­
Hours
Per
Respondent
Per
Year
(
C=
AxB)
(
D)

Respondents
Per
Year
(
E)

Person­
Hours
Per
Year
(
E=
CxD)
(
F)

Cost
b
($)

Report
when
exceed
HAP
usage
cutoff
(
or
report
area
source
becoming
major
source)
j
2
1
2
0
0
0
Waiver
application
c
6
1
6
0
0
0
Report
of
monitoring
exceedances
and
periods
of
noncompliance,
including
inconsistencies
with
startup,
shutdown,
malfunction
plan
k
16
4
64
1
64
3516
Report
of
no
excess
emissions,
including
startup,
shutdown,
malfunction
reports
k
4
2
8
12
96
5274
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
Included
in
4D
D.
Develop
record
system
i,
l
40
1
40
0
0
0
E.
Time
to
enter
information
Facilities
above
cutoff
m
­
including
records
associated
with
startup,
shutdown,
malfunction,
maintenance
of
APCD,
and
measurement
of
freeboard
ratio
­
maintain,
adjust,
and
calibrate
CMS
n
and
maintain
records
of
this
and
any
CMS
malfunction
that
occurs
0.5
6
350
52
175
312
13
13
2275
4056
124989
222837
Facilities
below
cutoff
o
2
1
2
1
2
110
F.
Time
to
train
personnel
N/
A
G.
Time
for
audits
N/
A
TOTAL
BURDEN
AND
COST
NATIONWIDE:
7042
386889
Average
cost
per
facility
p
29761
a
Numbers
are
rounded
to
avoid
fractions.
b
Person­
hours
are
charged
at
$
26.16/
hr
plus
110
percent
overhead
costs
which
equals
$
54.94/
hr.
c
This
cost
will
only
be
incurred
during
the
first
year.
d
Hours
associated
with
the
initial
performance
test
include
preparation
of
a
site­
specific
test
plan.
Hours
for
performance
test
method
audits
are
estimated
as
6
percent
of
the
performance
test
hours.
No
facility
is
expected
to
conduct
testing
for
the
APCD
and
CEM's.
e
Assumes
20
percent
of
sources
will
have
to
be
retested.
f
It
is
projected
that,
on
the
average,
new
coating
lines
will
be
added
at
the
rate
of
one
per
year.
These
coating
lines
will
be
located
at
existing
facilities
which
will
already
be
meeting
the
reporting
and
recordkeeping
requirements
of
the
standard.
Also,
additional
emission
points
will
likely
be
tied
into
the
existing
APCD.
Therefore,
new
compliance
tests
for
the
APCD
and
continuous
monitors
will
not
be
necessary.
However,
a
new
total
enclosure
would
be
built
and
must
be
tested.
g
All
facilities
using
VOC
continuous
emission
monitors
(
CEM's)
will
have
to
perform
quarterly
audits
of
monitors,
estimated
at
8
facilities.
h
No
facilities
are
expected
to
conduct
an
initial
performance
test.
i
No
facilities
are
expected
to
be
required
to
report
on
status,
or
develop
a
startup,
shutdown,
malfunction
plan,
quality
control
plan
for
CMS,
or
record
system.
j
No
existing
area
sources
are
expected
to
exceed
the
HAP
usage
cutoff
or
become
a
major
source.
k
These
reports
will
include
data
based
on
CMS
performance
and/
or
material
balance
results.
It
is
assumed
that
90
percent
of
the
facilities
in
this
source
category
will
have
no
excess
emission:
reporting
will
therefore
be
semiannual.
Ten
percent
of
the
facilities
in
this
source
category
will
have
excess
emissions;
these
facilities
will
need
to
report
quarterly
each
year.
All
13
facilities
subject
to
the
control
requirements
will
be
submitting
reports.
l
Activities
that
must
be
implemented
at
all
facilities
include
maintaining
a
75
percent
freeboard
ration
in
wash
sinks,
the
use
of
a
closed
system
for
flushing
fixed
lines,
and
the
use
of
a
closed
system
for
particulate
transfer.
A
record
system
will
need
to
be
developed
to
maintain
records
associated
with
the
freeboard
ratio,
performance
tests,
notifications,
and
CMS
QA/
QC
program.
m
All
facilities
subject
to
the
control
requirements
of
the
standard
will
be
keeping
records.
n
All
but
one
of
the
13
facilities
subject
to
the
rule
will
operate
a
continuous
monitoring
system
(
CMS),
as
defined
in
section
63.2
of
the
proposed
General
Provisions.
The
one
facility
that
will
not
operate
a
CMS
has
only
one
control
device
and
will
perform
a
materials
balance
to
show
compliance.
o
Facilities
that
fall
below
the
HAP
usage
cutoff
will
have
to
submit
an
annual
report
certifying
this
usage.
One
facility
is
expected
to
be
subject
to
this
requirement.
p
The
average
facility
burden
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
13)
subject
to
the
control
provisions
of
the
standard
