SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
art
60,
subpart
VVV)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
the
regulations
at
40
CFR
part
60,
subpart
VVV
were
proposed
on
April
30,
1987
and
promulgated
on
September
11,
1989.
These
regulations
apply
to
each
coating
operation
and
any
on­
site
coating
mix
preparation
equipment
used
to
prepare
coatings
for
the
polymeric
coating
of
supporting
substrates
at
existing
facilities
and
new
facilities.
New
facilities
include
those
that
commenced
construction,
modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
60
subpart
VVV.

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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Approximately
53
respondents
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
one
additional
respondent
will
become
subject
to
the
regulation
in
each
of
the
next
three
years.

OMB
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."
2
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/
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
substrates
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
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
3
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
recordkeeping
and
reporting
requirements
in
the
standard(
s)
ensure
compliance
with
the
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standard(
s).
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standards
at
all
times.

The
notifications
required
in
the
standards
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
and
the
standards
are
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
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
performance
test
may
also
be
observed.

The
required
quarterly/
semiannual
reports
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation/
maintenance
procedures
and
for
compliance
determinations.

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
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
4
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
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
May
25,
2004,
(
69
FR
29718).
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
In
order
to
obtain
information
on
the
burden
for
this
ICR,
EPA
consulted
Jeff
Rose
of
Cytec
Engineered
Materials,
501
West
3rd
Street,
Winona,
Minnesota
55987
(
507­
312­
8824).
EPA
also
consulted
its
Air
Facility
System
(
AFS)
to
identify
sources
subject
to
the
standard.

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
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
5
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
40
CFR,
subpart
VVV
2241
313221
2295
31332
2296
314992
2394
314912
3052
32622
3053
339991
3069
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:

Notification
Reports
Requirement
Regulation
reference
Construction/
reconstruction.
60.7(
a)(
1)

Actual
startup.
60.7(
a)(
3)

Initial
performance
test
results.
60.8
(
a)
6
Notification
Reports
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
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
two
years.
The
first
two
years
of
records
must
be
kept
onsite.
60.747(
h)

Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data,
e.
g.,
temperature,
pressure
drop,
leaks
and
spills
of
mercury,
etc.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.
7
Also,
regulatory
agencies
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
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
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.

Monitor
projected
and
actual
VOC
use.

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
8
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,
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
noncompliance
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
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
and
annual
emission
inventory
data
for
more
than
125,000
industrial
and
government­
owned
facilities.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
and
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
There
is
a
distribution
of
business
sizes
affected
by
this
regulation.
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
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
40
CFR,
Sections
60.744(
b),
60.747(
b)
and
60.747(
c)
which
require
reports
and
records
of
VOC
use.
This
9
reduces
regulatory
requirements
for
smaller
facilities.
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
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV).

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
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
(
40
CFR
Part
60,
Section
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
to
be
12,553
(
Total
Labor
Hours
from
Table
1).
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
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
10
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standards
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.

(
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/
Startu
p
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)

VOC
monitor
40,000
1
40,000
8,500
53
450,500
Temperature
monitor
8,500
1
8,500
2,000
53
106,000
The
total
capital/
startup
costs
for
this
ICR
are
$
48,500.
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
operating
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
556,500.
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
are
estimated
to
be
$
605,000.
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.
The
continuous
monitoring
costs
that
are
included
in
this
section
consist
only
of
those
capital/
startup
and
O&
M
costs
that
a
source
incurs
as
a
result
of
the
standard.
Some
continuous
monitoring
costs
may
not
be
included
in
this
section.
For
instance,
if
a
particular
industry
typically
utilizes
a
control
device
that
must
have
a
continuous
monitor
(
e.
g.,
temperature,
pressure
drop,
etc.)
to
function
properly,
and
the
recordation
of
additional
11
measurements
beyond
the
minimum
are
required
by
the
standard,
then
there
is
no
capital/
startup
or
O
&
M
cost,
but
there
is
a
labor
cost
to
record
the
additional
readings.
Such
a
cost
would
not
appear
in
this
section,
but
in
the
industry
burden
Section
6(
d)
below.

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
$
30,478,
see
Table
2.
Annual
Agency
Burden
and
Cost,
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV).

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)
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
Agency
Burden
and
Cost,
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
53
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
an
additional
one
source
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
12
Number
of
Respondents
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
5
51
0
4
52
2
5
52
0
4
53
3
5
53
0
4
54
Average
5
52
0
4
53
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

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
53.
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:

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
Notification
of
construction/
reconstruction
5
1
0
5
Notification
of
actual
startup
5
1
0
5
Notification
of
initial
performance
test
5
1
0
5
Notification
of
VOC
use
at
the
end
of
the
initial
year
1
1
0
1
Report
of
performance
test
5
1
0
5
Report
of
performance
retest
1
1
0
1
Report
of
monitoring
exceedances
and
periods
of
noncompliance
11
4
0
44
Report
of
no
excess
emissions
42
2
0
84
13
Total
Annual
Responses
Report
when
1st
projected
VOC
use
exceeds
the
applicable
cutoff
2
1
0
2
Notification
of
changes
1
1
0
1
Total
153
The
number
of
Total
Annual
Responses
is
153.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
Note
that
four
respondents
have
been
double
counted
in
the
above
table
because
they
have
both
existing
affected
facilities
and
new
affected
facilities.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
805,367.
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
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV),
attached.
The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
605,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
771
labor
hours
at
a
cost
of
$
30,478.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV),
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
805,367.
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
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV),
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
83
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
605,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
14
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
771
labor
hours
at
a
cost
of
$
30,478.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV),
attached.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
decrease
in
burden
is
due
to
a
reduction
in
the
estimate
of
shutdowns
and
malfunctions
occurring
annually,
a
correction
in
the
number
of
reported
respondents,
and
a
recalculation
of
burden
resulting
from
reporting
activities.
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
have
also
been
revised
to
reflect
the
increased
costs
of
equipment
and
maintenance
over
time.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
83
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
0018,
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
15
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
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
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Attention:
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Docket
ID
Number
OECA­
2004­
0018
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.
16
TABLE
1.
Annual
Respondent
Burden
and
Cost:
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,
Subpart
VVV)

Burden
item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
b
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,
$
a
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
5b+
c+
d
5
0.3
0.5
6
$
367
B.
Required
activities
°
Initial
performance
test
280
1
280
5
1,400
70
140
1,610
$
102,725
°
Repeat
of
performance
test
280
1
280
1e
280
14
28
322
$
20,545
°
Monthly
compliance
test
90
12
1080
1f
1,080
54
108
1,242
$
79,245
C.
Create
information
included
in
3B
D.
Gather
existing
information
included
in
3E
E.
Write
report
New
Affected
Facilities
°
Notification
of
construction/

reconstruction
2
1
2
5
10
0.5
1
12
$
734
°
Notification
of
actual
startup
2
1
2
5
10
0.5
1
12
$
734
°
Notification
of
initial
performance
test
2
1
2
5
10
0.5
1
12
$
734
°
Notification
of
VOC
use
at
the
end
of
the
initial
year
2
1
2
1
g
2
0.1
0.2
2
$
147
°
Report
of
performance
test
included
in
3B
New
and
Existing
Affected
Facilities
°
Report
of
monitoring
exceedances
and
periods
of
non­
compliance
16
4
64
11h
704
35
70
810
$
51,656
°
Report
of
no
excess
emissions
8
2
16
42i
672
34
67
773
$
49,308
°
Report
when
1st
projected
VOC
use
exceeds
the
applicable
cutoff
2
1
2
2
4
0.2
0.4
5
$
294
°
Report
when
1st
actual
12­
month
VOC
use
exceeds
the
applicable
cutoff
2
1
2
0
j
0
0
0
0
$
0
°
Notification
of
changes
4
1
4
5d
20
1
2
23
$
1,468
4.
Recordkeeping
Requirements
New
and
Existing
Affected
Facilities
17
Burden
item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Technical
person­
hours
per
respondent
per
year
(
C=
A*
B)
(
D)
b
Respondents
per
year
(
E)
Technical
person­
hours
per
year
(
E=
C*
D)
(
F)
Management
person­
hours
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hours
per
year
(
G=
E*
0.1)
(
H)
Respondent
person­
hours
per
year
(
H=
E+
F+
G)
(
I)
Cost,
$
a
A.
Read
instructions
included
in
3A
B.
Plan
activities
included
in
3B
C.
Implement
activities
included
in
3B
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
°
Records
of
startups,
shutdowns,
malfunctions,

etc.
1.5
25k
37.5
53
1,988
99
199
2,286
$
145,833
°
Records
of
operating
parameters
0.25
350l
87.5
53
4,638
232
464
5,333
$
340,277
°
Records
of
semiannual
estimate
of
projected
VOC
use
1
2m
2
11
22
1
2
25
$
1,614
°
Records
of
12
month
actual
VOC
use
1
12m
12
11
132
7
13
152
$
9,686
F.
Train
personnel
N/
A
G.
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)

NATIONWIDEa
10,976
549
1,098
12,623
$
805,367
Footnotes
a
Costs
assume
a
rate
of
$
64.60/
hour
for
technical
labor,
$
95.32/
hour
for
management
labor,
and
$
40.09/
hour
for
clerical
labor.

b
There
are
a
total
of
53
existing
plants
subject
to
this
NSPS.
Assume
that
each
existing
plant
has
one
solvent­
borne
coating
operation
subject
to
this
NSPS.
Assume
that
a
total
of
4
new
coating
lines
per
year
will
be
installed
at
existing
plants.

c
Assume
one
additional
solvent­
borne
coating
operation
with
VOC
usage
greater
than
95Mg/
yr
per
year
will
be
installed
at
a
new
plant
each
year
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)
will
not
occur
frequently.
Therefore,
we
assume
that
each
year
4
existing
plus
1
new
polymeric
coating
plants
will
undertake
a
change
that
constitutes
modification
or
reconstruction.

e
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure
(
5
x
20%
=
1).

fIf
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.
Assume
there
is
one
new
waterborne
line
per
year
(
which
uses
less
than
95
Mg
of
VOC
per
year)
being
installed
at
existing
plants
over
the
3
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
the
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.
[
53
x
20%
=
11
(
rounded)].

iAssumes
80
percent
of
solvent­
borne
lines
report
no
excess
emissions
semiannually.
[
53
x
80%
=
42
(
rounded)].

jNo
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
2
weeks
(
50
weeks
per
year).

lAssume
operating
parameters
recorded
350
days
per
year.

m
Assume
that
20
percent
of
the
existing
coating
lines
or
"
affected
facilities"
[
53
x
20%
=
11
(
rounded)]
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.
18
TABLE
2.
Annual
Agency
Burden
and
Cost:
NSPS
for
Polymeric
Coating
of
Supporting
Substrates
Facilities
(
40
CFR
Part
60,

Subpart
VVV).
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
line
per
year
(
C)
Respondents
per
year
(
D)
Technical
personhours
per
year
(
D=
B*
C)
(
E)
Management
person­
hours
per
year
(
E=
D*
0.05)
(
F)
Clerical
personhours
per
year
(
F=
D*
0.1)
(
G)
Total
personhours
per
year
(
G=
D+
E+
F)
(
H)
Cost,

$
a
New
Affected
Facilities
°
Attend
initial
performance
testb+
c
12
12
5d
60
3
6
69
$
2,729
°
Attend
repeat
performance
teste
12
12
1f
12
0.6
1
14
$
546
°
Review
of
notification
of
construction/
reconstruction
2
2
5
10
0.5
1
12
$
455
°
Review
of
notification
of
actual
startup
2
2
5
10
0.5
1
12
$
455
°
Review
of
notification
of
initial
performance
testb+
c+
g
2
2
5
10
0.5
1
12
$
455
°
Review
of
notification
of
VOC
use
at
the
end
of
the
initial
yearg
2
2
1
2
0.1
0.2
2
$
91
°
Review
of
performance
test
resultsb+
c
8
8
5
40
2
4
46
$
1,820
New
and
Existing
Affected
Facilities
°
Quarterly
reports
of
monitoring
exceedances
and
periods
of
noncompliance
8
32
11
h
352
18
35
405
$
16,012
°
Semiannual
reports
of
no
excess
emissions
2
4
42j
168
8
17
193
$
7,642
°
Report
when
1st
projected
VOC
use
exceeds
the
applicable
cutoff
2
2
2
4
0.2
0.4
5
$
182
°
Report
when
1st
actual
12­
month
VOC
use
exceeds
the
applicable
cutoff
2
2
0
j
0
0
0
0
$
0
°
Notification
of
changes
2
2
1
2
0.1
0.2
2
$
91
TOTAL
BURDEN
AND
COSTg
670
34
67
771
$
30,478
19
Footnotes
a
Costs
assume
a
rate
of
$
40.56/
hour
for
technical
labor,
$
54.66/
hour
for
management
labor,
and
$
21.95/
hour
for
clerical
labor.

b
There
are
a
total
of
53
existing
plants
subject
to
this
NSPS.
Assume
that
each
existing
plant
has
one
solvent­
borne
coating
operation
subject
to
this
NSPS.
Assume
that
a
total
of
4
new
coating
lines
per
year
will
be
installed
at
existing
plants.

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

d
A
total
of
5
new
solvent­
borne
lines
per
year
perform
initial
performance
test.

e
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure
(
5
x
20%
=
1).

f
Assume
retests
are
attended
by
EPA
personnel.

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.

Assume
there
is
one
new
water­
borne
line
per
year
(
which
uses
less
than
95
Mg
of
VOC
per
year)
being
installed
at
existing
plants
over
the
3
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
the
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.
[
53
x
20%
=
11
(
rounded)].

jAssumes
80
percent
of
solvent­
borne
lines
report
no
excess
emissions
semiannually.
[
53
x
80%
=
42
(
rounded)].

k
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.
