SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
rubber
tire
manufacturing
plants
were
proposed
on
January
20,
1983,
and
promulgated
on
September
15,
1987.
Minor
revisions
to
the
standards
of
performance
for
the
rubber
tire
manufacturing
industry
were
proposed
on
February
14,
1989
and
promulgated
on
September
19,
1989.
These
standards
apply
to
undertread
cementing
operations,
sidewall
cementing
operations,
tread
end
cementing
operations,
bead
cementing
operations,
green
tire
spraying
operations,
Michelin­
A
operations,
Michelin­
B
operations,
and
Michelin­
C
automatic
operations,
commencing
construction,
modification
or
reconstruction
after
January
20,
1993.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
60,
subpart
BBB.

In
general,
all
NSPS
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.
Monitoring
requirements
specific
to
rubber
tire
manufacturing
plants
provide
information
on
the
operation
of
the
emissions
control
device
and
compliance
with
the
VOCs
standards.
Semiannual
reports
of
excess
emissions
are
required.
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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

In
the
development
of
this
Information
Collection
Request
(
ICR),
we
reviewed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
(
TOC)
section
on
the
active
ICR.
There
were
no
comments
in
the
TOC
section.

Approximately
41
rubber
tire
manufacturing
plants
are
currently
subject
to
the
standard.
It
is
estimated
that
there
will
be
no
industry
growth
over
the
next
three
years.
Although
some
plants
may
conduct
operational
changes,
these
changes
will
not
trigger
applicability
of
this
rule.
2
We
are
also
assuming
that
all
plants
are
now
using
the
water­
based
sprays
that
meet
the
NSPS
green
tire
spray
limits
without
having
to
use
add­
on
control
equipment.
These
estimates
are
based
on
information
gathered
from
EPA's
Air
Facility
System
(
AFS)
database
through
the
Online
Tracking
Information
System
(
OTIS);
consultation
with
the
Agency's
contact
for
the
development
of
this
rule
at
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS);
and
the
review
of
information
available
on
the
active
ICR.

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
(
CAA),
as
amended,
to
establish
standards
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
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,
volatile
organic
compound
(
VOC)
emissions
from
rubber
tire
manufacturing
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
were
promulgated
for
this
source
3
category
at
40
CFR
part
60,
subpart
BBB.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
VOC
emissions
from
rubber
tire
manufacturing
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
VOC
emissions
from
rubber
tire
manufacturing
plants
are
the
result
of
operation
of
the
following
affected
facilities:
undertread
cementing
operations,
sidewall
cementing
operations,
tread
end
cementing
operations,
bead
cementing
operations,
green
tire
spraying
operations,
Michelin­
A
operations,
Michelin­
B
operations,
and
Michelin­
C­
automatic
operations
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
VOC
emissions
using
thermal
incinerators,
and
catalytic
incinerators,
carbon
absorbers
and/
or
other
recovery
devices.

The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
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
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
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
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subpart
BBB.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
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
its
own
similar
standards
to
implement
the
Federal
standards,
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
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
4
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
69
FR
29718)
on
May
25,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
No
comments
were
received
on
the
industry
burden
published
in
the
Federal
Register.
For
this
information
collection,
several
sources
were
used
to
obtain
updated
information
on
the
number
of
sources
and
on
the
assumptions
made
to
determine
the
industry
burden.
As
discussed
in
Section
1(
b),
the
number
of
sources
was
estimated
by
conducting
queries
on
the
EPA's
AFS
database
through
OTIS,
through
consultation
with
Keith
Barnet,
the
OAQPS
rule
lead,
and
Tracey
Norberg,
Environmental
Affairs
Manager
for
the
Rubber
Manufacturers
Association
in
Washington,
D.
C.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
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
at
5
CFR
1320.5.

3(
f)
Confidentiality
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
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
5
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
rubber
tire
manufacturing
plants
that
commenced
construction,
modification,
or
reconstruction
after
January
20,
1983.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
U.
S.
Standard
Industrial
Classification
(
SIC)
3011
which
corresponds
to
The
North
American
Industry
Classification
System
(
NAICS
)
326211
for
Tire
Manufacturing
(
except
Retreading).

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB).

A
source
must
make
the
following
reports:

Reports
Notification
of
construction/
reconstruction.
60.7(
a)(
1)

Notification
of
anticipated
startup.
60.7(
a)(
2)

Notification
of
actual
startup.
60.7(
a)(
3)

Initial
performance
test
results.
60.8(
a)

Initial
compliance
report
that
includes
initial
performance
test,
monthly
schedule
to
be
used
in
making
compliance
determinations,
design
and
equipment
specifications
and
compliance
method.
60.8(
d),
60.8(
a),
60.546(
a)
through
(
e)

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

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

Periodic
startup,
shutdown,
malfunction
reports,
and
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)

Seeking
to
comply
with
an
alternative
method,
from
use
of
applicable
percent
emission
reduction
requirement
to
applicable
total
(
uncontrolled)
monthly
VOC
use
limit.
60.546(
h)

Initial
and
annual
formulation
data
or
Method
24
results
to
verify
VOC
content
of
water­
based
sprays.
60.546(
j)

Excess
emissions
report.
60.546(
f)
and
(
g)

A
source
must
keep
the
following
records:
6
Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)

Maintain
a
file
of
all
measurements
including,
performance
test
measurements,
and
all
other
information
required
by
this
part
recorded
in
a
permanent
file
suitable
for
inspection.
The
file
shall
be
retained
for
at
least
two
years.
60.7(
f)

Maintain
records
of
operating
parameters
of
monitoring
device
results
for
catalytic
or
thermal
incinerator,
or
carbon
absorber.
60.545(
a),
(
b)
and
(
c)

Maintain
records
of
monthly
VOCs
use,
number
of
days
in
compliance
period,
and
other
information
needed
to
verify
results
of
all
monthly
tests.
60.545(
d)
and
(
e)

Maintain
records
of
formulation
data
or
results
of
Method
24
analysis
of
water­
based
sprays
containing
less
than
1.0
percent
of
VOC.
60.545(
f)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
a
temperature
monitoring
device
with
a
continuous
recorder,
an
organics
monitoring
device
with
a
continuous
recorder
to
detect
the
concentration
level
of
organic
compounds,
or
a
recovery
device,
as
applicable.

Perform
initial
performance
test,
Reference
Method
24
test
or
formulation
data
analysis
for
the
determination
of
the
VOC
content
of
cements
or
green
tire
spray
materials,
Method
25A
for
the
determination
of
the
VOC
concentration
if
using
a
control
device,
Method
2
for
the
determination
of
the
flow
rate
at
the
stack
gas,
monthly
performance
test
or
formulation
data
analysis
of
the
spray
material,
and
repeat
performance
test
if
necessary.

Write
the
notifications
and
reports
listed
above.
7
Respondent
Activities
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
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
Air
Facility
System
(
AFS).

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
8
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
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
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost:
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
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
to
be
13,323
(
Total
Labor
Hours
from
Table
1).
These
9
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
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
rates:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standard
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor(
s)
and
other
costs
such
as
photocopying
and
postage.

Two
types
of
monitoring
devices
are
used
to
collection
information:
the
gas
stream
monitoring
device
and
the
VOC
monitoring
device.
The
gas
stream
temperature
monitoring
device
has
a
continuous
recorder
to
measure
the
temperature
before
and
after
the
emission
reduction
at
the
control
device.
The
VOC
monitoring
device
has
a
continuous
analyzer
to
measure
the
outlet
gas
concentration
when
a
VOC
recovery
device
is
used.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)
10
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
VOC
(
organics)
monitor
$
35,000
0
$
0
$
7,500
0
$
0
Temperature
monitors
at
thermal
and
catalytic
incinerators
$
7,500
0
$
0
$
4,000
4.1l
$
16,400
Total
Cost
$
16,400
1
An
estimated
10
percent
of
the
respondents
use
a
temperature
monitor.

There
are
no
total
capital/
startup
costs
for
this
ICR
because
we
have
assumed
that
none
of
the
existing
tire
manufacturing
plants
that
are
not
currently
subject
to
the
rule
or
any
new
plants
built
will
conduct
an
operational
change
that
triggers
rule
applicability.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
16,000
(
rounded).
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
16,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
12,520.

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
11
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
and
Cost
for
the
Federal
Government:
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
41
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
new
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
4.1
4.1
36.9
4.1
41
2
4.1
4.1
36.9
4.1
41
3
4.1
4.1
36.9
4.1
41
Average
4.1
4.1
36.9
4.1
41
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities
(
10%
x
41
=
4.1).
The
remainder
must
keep
records
(
90%
x
41
=
36.9).

To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
41.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:
12
Total
Annual
Responses
(
A)
Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Method
25A
3
1
0
3
Annual
Report
of
Formulation
Data/
Method
24
41
1
0
41
Semiannual
Report
of
Excess
Emissions
13.7
2
0
27.4
Report
of
Operational
Change
4.1
1
0
4.1
Notification
of
Change
in
Spray
Materials
Formulation
4.1
1
0
4.1
TOTAL
0
79.6
The
number
of
Total
Annual
Responses
is
80
(
rounded).
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
850,093.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost:
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
16,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
appear
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
167
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
Although
the
number
of
respondents
has
slightly
reduced
from
43
to
41,
there
is
a
net
increase
in
burden
hours.
The
increase
in
the
burden
from
the
most
recently
approved
ICR
is
due
13
to
an
adjustment.
The
reason
for
this
change
in
the
burden
from
the
most
recently
approved
ICR
is
that
we
took
into
consideration
not
only
technical
hours,
but
also
the
managerial
and
clerical
hours.
The
previous
ICR
only
covered
the
technical
burden
hours.
The
increase
in
labor
cost
from
the
most
recently
approved
ICR
is
due
to
a
revised
hourly
labor
rate
from
the
United
States
Department
of
Labor.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
167
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
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
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
Number
OECA­
2004­
0014,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
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.
When
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,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0014
and
OMB
Control
Number
2060­
0156
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable,
as
no
statistical
methods
were
used
in
collecting
this
information.
14
Table
1:
Annual
Respondent
Burden
and
Cost:
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB)

Burden
Item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,

and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
A.
Read
Instructions
1
1
1
0
0
0
0
$
0.00
B.
Required
Activities
a
+
c
Initial
Performance
Test
d
240
5
1,200
0
0
0
0
$
0.00
Repeat
of
Initial
Performance
Test
d
240
1
240
0
0
0
0
$
0.00
Monitoring
of
VOC
Emissions
and
Operations
e
1
252
252
41
10,332
516.6
1,033.2
$
758,110.50
Monthly
performance
tests
e
+
j
2
12
24
0
0
0
0
$
0.00
C.
Create
Information
Included
in
4B
and
5E
D.
Gather
Existing
Information
Included
in
4B
and
5E
E.
Write
report
15
Burden
Item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
Notification
of
Actual
Startupc
2
1
2
0
0
0
0
$
0.00
Notification
of
Initial
Performance
Test
a
+
b
2
1
2
0
0
0
0
$
0.00
Initial
Performance
Test
Results
a
+
b
2
1
2
0
0
0
0
$
0.00
Notification
of
Method
25A
Test
f
4
1
4
3
12
0.6
1.2
$
880.50
Notification
of
construction
or
reconstruction
a
+
b
2
1
2
0
0
0
0
$
0.00
Report
of
Physical
Operational
Change
g
4
2
8
4.1
32.8
1.64
3.28
$
2,406.70
Report
of
Spray
Materials
Formulation
Change
h
Formulation
4
2
8
4.1
32.8
1.64
3.28
$
2,406.70
Semiannual
Reports
of
Excess
Emissions
and
Monitoring
Systems
Performance
i
10
2
20
13.7
274
13.7
27.4
$
20,104.75
Annual
Report
of
Formulation
Data/
Method
24
Results
j
4
1
4
41
164
8.2
16.4
$
12,033.50
5.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
4A
16
Burden
Item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
B.
Plan
Activities
Included
in
4B
C.
Implement
Activities
Included
in
4B
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
and
Transmit
Information:
k
Records
of
Startup,

Shutdowns
and
Malfunction
l
0.5
36
18
41
738
36.9
73.8
$
54,150.75
Records
of
Monthly
Performance
Test
Included
in
4B
Records
of
Emissions
and
Operations
Included
in
4B
F.
Time
to
Train
Personnel
N/
A
G.
Time
for
Audits
N/
A
Subtotal
Labor
Burden
11,585.6
579.28
1,158.56
$
850,093.40
TOTAL
LABOR
BURDEN
AND
COST
(
Rounded)
13,323
$
850,093
Assumptions:

a
We
have
assumed
that
there
are
41
existing
rubber
tire
manufacturing
plants
subject
to
this
standard,
one
of
which
mixes
only
rubber
compound.
Also,
we
have
assumed
that
no
new
tire
manufacturing
plants
will
become
subject
to
the
standard
in
the
next
three
years.
In
addition,
we
have
not
included
the
reporting
requirements
burden
for
affected
facilities
exemptions
under
40
CFR
§
60.676(
d)
in
the
table
because
their
occurrence
is
very
rare
in
practice.

b
This
ICR
uses
the
following
labor
rates:
$
95.32
for
Managerial
labor,
$
64.60
for
Technical
labor,
and
$
40.09
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
17
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c
We
have
assumed
that
the
rubber
tire
manufacturing
plants
will
not
construct
or
reconstruct
an
affected
facility,
however,
they
will
conduct
operational
changes
on
10
percent
of
the
affected
operations.

d
A
new
plant
typically
would
have
about
five
new
affected
facilities.
However,
we
are
assuming
that
no
new
plants
will
become
subject
to
this
rule.

e
Sources
are
required
to
monitor
and
record
monthly
performance
tests,
VOC
use,
the
number
of
days
in
each
compliance
period,
control
device
efficiency,

formulation
data
or
the
results
of
Method
24
analysis
conducted
to
verify
the
VOC
content
of
the
spray,
monitoring
device
data
and
other
operational
data
such
as
the
number
of
tires
processed.
We
have
assumed
sources
will
operate
approximately
252
days
per
year
or
36
weeks.
We
have
further
assumed
that
the
burden
incurred
to
record
these
items
is
one
hour
per
occurrence
since
much
of
the
required
information
would
be
currently
recorded
by
the
industry
with
or
without
regulation.

f
We
have
assumed
that
three
existing
sources
using
control
devices
will
conduct
a
Method
25
test
once
a
year
to
determine
the
VOC
concentration
in
each
stack
(
source
using
a
capture
system)
both
entering
and
leaving
the
control
device.

g
We
have
assumed
that
ten
percent
of
the
existing
rubber
tire
manufacturing
plants
subject
to
this
rule
will
make
a
physical/
operational
change
due
adding
a
green
tire
spray
booth
or
a
new
line.

h
A
source
is
required
to
do
Method
24
or
formulation
data
analysis
if
the
operational
change
involves
spray
materials
formulation
changes
and
results
should
be
reported
within
30
days.

i
Exceedance
reports
submitted
as
applicable.
Assume
one­
third
of
the
sources
report
exceedance
reports
for
each
six
month
period.

j
We
have
assumed
that
all
existing
sources,
will
submit
an
annual
Method
24
report
or
an
annual
formulation
data
report
to
verify
the
VOC
content
of
each
tread
end
cement
and
green
tire
spray
material
in
lieu
of
conducting
a
monthly
performance
test.
We
have
further
assumed
that
50
percent
of
the
existing
sources
will
continue
to
use
HAP
materials
(
VOC)
in
the
spray
at
levels
that
meet
the
green
tire
VOC
limitations
in
NSPS
not
needing
add
on
control
devices.
The
remaining
plants
use
only
water­
based
sprays
and
are
not
required
to
do
monthly
performance
tests.

We
have
assumed
that
the
burden
incurred
to
record
these
items
is
one
hour
per
occurrence
per
source
due
to
the
nature
of
the
control
equipment
used
and
its
intermittent
use.

k
We
have
assumed
two
occurrences
of
startup,
shutdown
and/
or
malfunction
per
source
per
month
which
yields
an
average
of
18
occurrences
per
source
per
respondent(
36
weeks).
18
Table
2.
Annual
Burden
and
Cost
for
The
Federal
Government:
NSPS
for
Rubber
Tire
Manufacturing
(
40
CFR
part
60,
subpart
BBB)

Burden
Item
(
A)
Technical
Person
hours
per
occurrence
(
B)
Number
of
occurrences
per
plant
per
year
(
C)

Person
hours
per
plant
per
year
(
C=
AxB)
(
D)

Plants
per
year
a
(
E)
Technica
l
hours
per
year
(
E=
CxD)
(
F)
Management
hours
per
year
(
F=
0.05xE)
(
G)
Clericalperson
hours
per
year
(
G=
0.1xE)
(
H)

Cost,
$
b
Notification
of
actual
startup
c
2
1
2
0
0
0
0
$
0.00
Notification
of
initial
performance
test
c
2
1
2
0
0
0
0
$
0.00
Report
of
performance
test
results
c
2
1
2
0
0
0
0
$
0.00
Notification
of
construction
or
reconstruction
c
2
1
2
0
0
0
0
$
0.00
Notification
of
Method
25A
Test
d
8
1
8
3
24
1.2
2.4
$
1,091.71
Notification
of
Change
in
Spray
Materials
Formulation
e
2
1
2
4.1
8.2
0.41
0.82
$
373.00
Semiannual
reports
of
excess
emissions
and
monitoring
systems
performance
f
4
2
8
13.7
109.6
5.48
10.96
$
984.65
Annual
Report
of
Formulation
Data/
Method
24
Results
g
5
1
5
41
205
10.25
20.50
$
9,325.05
Report
of
Operational
Change
h
4
1
4
4.1
16.4
0.82
1.64
746.00
Subtotal
363.2
18.16
36.32
$
12,520.4
1
19
Burden
Item
(
A)
Technical
Person
hours
per
occurrence
(
B)
Number
of
occurrences
per
plant
per
year
(
C)

Person
hours
per
plant
per
year
(
C=
AxB)
(
D)

Plants
per
year
a
(
E)
Technica
l
hours
per
year
(
E=
CxD)
(
F)
Management
hours
per
year
(
F=
0.05xE)
(
G)
Clericalperson
hours
per
year
(
G=
0.1xE)
(
H)

Cost,
$
b
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
418
$
12,520
Assumptions:

a
We
have
assumed
that
there
are
41
existing
rubber
tire
manufacturing
plants
subject
to
this
standard,
one
of
which
mixes
only
rubber
compound.
Also,
we
have
assumed
that
no
new
tire
manufacturing
plants
will
become
subject
to
the
standard
in
the
next
three
years.

b
We
have
assumed
the
following
labor
rates
of
$
55.66
for
Managerial
labor,
$
40.56
for
Technical
labor,
and
$
21.95
for
Clerical
labor.
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

c
The
regulatory
agency
will
have
no
burden
associated
with
initial
requirements
since
there
will
be
no
new
sources.

d
We
have
assumed
that
three
existing
sources
using
control
devices
will
conduct
a
Method
25
test
once
a
year
to
determine
the
VOC
concentration
in
each
stack
(
source
using
a
capture
system)
both
entering
and
leaving
the
control
device.

e
A
source
is
required
to
do
Method
24
or
formulation
data
analysis
if
the
operational
change
involves
spray
materials
formulation
changes
and
results
should
be
reported
within
30
days.

f
Exceedance
reports
submitted
as
applicable.
Assume
one­
third
of
sources
report
exceedance
reports
for
each
six
month
period.

g
We
have
assumed
that
all
existing
sources,
will
submit
an
annual
Method
24
report
or
an
annual
formulation
data
report
to
verify
the
VOC
content
of
each
tread
end
cement
and
green
tire
spray
material
in
lieu
of
conducting
a
monthly
performance
test.
We
have
further
assumed
that
50
percent
of
the
existing
sources
will
continue
to
use
HAP
materials
(
VOC)
in
the
spray
at
levels
that
meet
the
green
tire
VOC
limitations
in
NSPS
not
needing
add
on
control
devices.
The
remaining
plants
use
only
water­
based
sprays
and
are
not
required
to
do
monthly
performance
tests.
We
have
assumed
that
the
burden
incurred
to
record
these
items
is
one
hour
per
occurrence
per
source
due
to
the
nature
of
the
control
equipment
used
and
its
intermittent
use.

h
We
have
assumed
that
ten
percent
of
the
existing
rubber
tire
manufacturing
plants
subject
to
this
rule
will
make
a
physical/
operational
change
due
adding
a
green
tire
spray
booth
or
a
new
line.
