TABLE
2.
ANNUAL
INDUSTRY
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
NSPS
SUBPART
VVV:
POLYMERIC
COATING
OF
SUPPORTING
SUBSTRATES
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
(
F)

Occurrence/
Hours/

Hours/
respondent/
respondent/
Respondents/
Hours/
Cost/

occurrence
year
year
year
year
year
a
1.
APPLICATIONS
............................
not
applicable.........................

2.
SURVEYS
AND
STUDIES
............................
not
applicable.........................

3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
1
1
1
7.5
(
b+
c+
d)
7.5
428.4
B.
Required
Activities
Initial
performance
test
280
1
280
7.5
(
b+
c+
d)
2100
119,952.0
Repeat
of
performance
test
280
1
280
1.6e
448
25,589.8
Monthly
Compliance
Test
90
12
1,080
1
f
1080
61,689.6
C.
Create
Information
See
3B.

D.
Gather
Existing
Information
See
3E.

E.
Write
Report
New
Affected
Facilities
Notification
of
construction/

reconstruction
2
1
2
5
10
571.2
Notification
of
actual
startup
1
1
2
5
10
571.2
Notification
of
initial
performance
test
2
1
2
5
10
571.2
Notification
of
VOC
use
at
the
end
of
the
initial
year
2
1
2
1
g
2
114.2
Report
of
performance
test
See
3B.

New
and
Existing
Affected
Facilities
Report
of
monitoring
16
4
64
11.2h
717
40,955.0
exceedances
and
periods
of
non­
compliance
Report
of
no
excess
emissions
8
2
16
44.8
i
717
40,955.0
Report
when
1st
projected
VOC
use
exceeds
the
applicable
cutoff
2
1
2
0
j
0
0
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
(
F)

Occurrence/
Hours/

Hours/
respondent/
respondent/
Respondents/
Hours/
Cost/

occurrence
year
year
year
year
year
a
Report
when
1st
actual
12­
month
VOC
use
exceeds
the
applicable
cutoff
2
1
2
0
0
0
Notification
of
changes
4
1
4
2.5d
10
571.2
F.
Subtotal
5,111.5
291,968.9
4.
RECORDKEEPING
REQUIREMENTS
New
and
Existing
Affected
Facilities
A.
Read
Instructions
Included
in
3A.

B.
Plan
Activities
Included
in
4C.

C.
Implement
Activities
Included
in
3B.

D.
Develop
Record
System
............................
not
applicable.........................

E.
Time
to
Enter
Information
Records
of
startups,

shutdown,
malfunction,
etc.
1.5
50
k
75
56
4,200
239,904
Records
of
operating
parameters
0.25
350
l
87.5
56
4,900
279,888
Records
of
semiannual
estimate
of
projected
VOC
use
1
2
m
2
11
22
1,256.6
Records
of
12­
month
actual
VOC
use
1
12
m
12
11
132
7,539.8
F.
Train
Personnel
............................
not
applicable.........................

G.
Audits
............................
not
applicable........................

H.
Subtotal
9,254
528,588.5
TOTAL
ANNUAL
BURDEN
14,365.5
820,557.4
a
Assume
an
hourly
wage
of
$
27.20
plus
110%
overhead
costs
which
equals
$
57.12.
This
labor
rate
is
based
on
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group
for
technical
personnel,
Table
10,
March
2001.

b
There
are
a
total
of
51
existing
plants
subject
to
this
NSPS,
according
to
AIRS.
Assume
that
each
existing
plant
has
one
solvent­
borne
coating
operation
subject
to
this
NSPS.
Assume
that
a
total
of
5
new
coating
lines
per
year
will
be
installed
at
existing
plants.
Of
these
5
lines
per
year,
4
are
expected
to
be
solvent­
borne
lines
with
annual
VOC
usage
greater
than
95
Mg/
yr
and
1
a
water­
borne
line.
This
assumption
is
based
on
the
fact
that
the
growth
in
this
industry
is
expected
in
lines
with
annual
VOC
usage
greater
that
95
Mg
per
year,
according
to
the
economic
impact
analysis
done
for
the
development
of
this
rule.
Water­
borne
lines
will
not
have
to
be
tested.

c
Assume
one
additional
solvent­
borne
coating
operation
with
VOC
usage
greater
than
95Mg/
yr
per
year
will
be
installed
at
a
new
plant
and
will
become
subject
to
the
standard
in
the
next
three
years.

d
Assume
that
changes
constituting
modification
or
reconstruction
making
an
existing
coating
operation
and/
or
a
coating
mix
preparation
equipment
(
e.
g.,
changes
to
an
existing
coating
mix
preparation
equipment
such
as
the
replacement
of
a
coating
applicator
or
the
oven
and
installing
a
new
part),
subject
to
this
NSPS
will
not
occur
frequently.

Therefore,
we
assume
that
only
5
percent
of
the
existing
polymeric
coating
plants
will
undertake
a
change
that
constitute
modification
over
the
next
three
years
(
0.5
X
51=
2.5
per
year)
and
will
have
to
conduct
performance
test.

e
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure
(
8
solvent­
borne
coating
lines
x
0.20
=
1.6).

f
If
an
affected
facility
is
complying
with
the
liquid­
liquid
material
balance
compliance
method,
monthly
compliance
determination
are
required
to
determine
VOC
used
and
recovered
(
by
Method
24),
and
percent
emission
reduction.
Assume
that
3
lines
over
the
three
year
period
(
one
line
per
year)
will
demonstrate
compliance
with
a
liquid
material
balance
method.
Therefore,
will
be
required
to
conduct
monthly
compliance
tests.
This
method
can
only
be
used
when
a
VOC
recovery
device
controls
only
those
emissions
from
one
affected
coated
operation.

g
An
affected
facility
claiming
to
use
less
than
95Mg
per
year
or
less
than
130
Mg
per
year
of
VOC
in
the
first
year
of
operation
shall
submit
actual
VOC
records
at
the
end
of
the
initial
year.
As
stated
in
(
b)
and
(
c)
above,
there
is
one
new
water­
borne
line(
which
uses
less
than
95
Mg
of
VOC
per
year)
being
installed
at
existing
plants
over
the
year
period.
This
existing
plant
would
be
required
to
submit
a
notification
of
VOC
use
at
the
end
of
the
intial
year
of
operation
of
its
new
coating
line.
Also
we
assume
that
all
of
the
5
new
solvent­
borne
lines
being
installed
use
at
least
130
Mg
of
VOC
per
year
and
are
not
required
to
notified
actual
VOC
use
at
the
end
of
the
initial
year.

h
Assume
that
20
percent
of
the
affected
facilities
(
either
complying
with
the
emission
reduction
standard,
the
alternative
standard
and/
or
coating
mix
preparation
equipment
standard)
report
monitoring
exceedances
or
periods
of
noncompliance
quarterly.
Since
the
average
number
of
solvent­
borne
lines
with
recurrent
annual
burden
is
56
(
51
existing
lines
+
5
additional
new
lines
per
year
over
the
three
year
period=
56
lines),
then
20
percent
of
that
number
equals
11.2
(
0.2
x
56=
11.2).

i
Assumes
80
percent
of
solvent­
borne
lines
report
no
excess
emissions
semiannually
(
0.8
x
56=
44.8).

j
No
lines
with
projected
VOC
consumption
of
less
than
95
Mg/
yr
or
less
than
130
Mg
of
VOC
are
expected
to
exceed
the
cutoff
value
in
the
future.

k
Assume
one
occurrence
of
malfunction/
shutdown
per
week
(
50
weeks
per
year).

l
Assume
operating
parameters
recorded
350
days
per
year.

m
Assume
that
20
percent
of
the
existing
coating
lines
or
"
affected
facilities"
(
0.2
x
51=
10.2)
claiming
use
of
less
than
95
Mg
of
VOC
per
year
or
less
than
130
Mg
of
VOC
per
year,
as
well
as
the
new
water­
borne
line
being
installed
per
year
are
required
to
record
semiannual
estimates
of
the
projected
amount
of
VOC
to
be
use
for
the
manufacture
of
polymeric
coated
substrates
at
the
affected
coating
operation
that
year
and
of
actual
12­
month
VOC
use.
