TABLE
1.
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
FACILITIES
SUBJECT
TO
THE
NSPS
SUBPART
VVV:
POLYMERIC
COATING
OF
SUPPORTING
SUBSTRATES
(
A)
(
B)
(
C)
(
D=
BXC)
(
E)
b
EPA
hrs/
EPA
hrs/
lines/
EPA
hrs/
Cost/

Occurrence
line/
yr
year
year
year
a
ACTIVITY
New
Affected
Facilities
Initial
Performance
Tests
(
b+
c)
12
12
6.4
d
76.8
2,840.1
Repeat
Performance
e
Tests
12
12
0.2
f
2.4
88.8
Notification
of
construction
2
2
6
12
443.8
Notification
of
actual
startup
2
2
6
12
443.8
Notification
of
initial
test
(
b+
c+
g)
2
2
7.5
15
554.7
Notification
of
VOC
use
at
the
end
of
the
initial
year
g
2
2
1
h
2
f
74.0
Review
test
results
(
b+
c)
8
8
5
40
1,479.2
New
and
Existing
Affected
Facilities
Quarterly
reports
of
8
32
i
11.2
j
358.4
13,253.6
monitoring
exceedances
and
i
periods
of
non­
compliance
Semiannual
reports
of
2
4
i
44.8k
179.2
6,626.8
no
excess
emissions
d
Report
when
1st
projected
VOC
use
exceeds
the
applicable
cutoff
2
2
0l
0
0
Report
when
1st
actual
12­
month
VOC
use
exceeds
the
applicable
cutoff
2
2
0l
0
0
Notification
of
changes
2
2
2.5g
5
184.9
TOTAL
ANNUAL
HOURS
702.8
25,989.5
Travel
Expenses
m
(
1
person
x
4.1
lines/
yr
x
1.5
day/
plant
x
$
85
per
diem/
day/
person)
+
($
350
round
trip/
plant
x
4.1
plants/
yr)
=
$
1,957.8
TOTAL
ANNUAL
COST=
$
27,947.3
a
This
cost
is
based
on
the
annual
wage
of
a
government
employee
at
a
grade
of
GS12,
step
1
($
23.11)
plus
60
percent
overhead
for
a
total
of
$
36.98.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
D.

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
A
total
of
5
new
solvent­
borne
lines
per
year
and
3
modified
solvent­
borne
lines
perform
initial
performance
test.
EPA
personnel
attend
80
percent
of
these
tests,
or
6.4
tests
per
year.

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
Ten
percent
of
the
initial
performance
retests
are
attended
by
EPA
personnel
(
0.1
x
1.6=
0.16,
rounded
to
0.2)

g
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
(
0.05
X
51=
2.5
per
year).

h
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
initial
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.

i
(
A)
x
number
of
reports
required
annually.

j
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).
Rounded
to
11.

k
Assume
80
percent
of
the
solvent­
borne
lines
report
no
excess
emissions
semiannually.

(
0.8
x
56
=
44.8).
Rounded
to
45.

l
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.

m
Tests
attended
=
4
(
initial
tests)
+
0.1
(
repeat
tests)=
4.1
tests.
