 

                                                                        


 SF 83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles
(40 CFR part 63, subpart OOOO)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Printing, Coating and Dyeing of Fabrics and other Textiles
(40 CFR part 63, subpart OOOO) (Renewal)

1(b)  Short Characterization/Abstract

	

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for printing, coating and dyeing of fabrics and other textiles were
proposed on July 11, 2002 (67 FR 46028), promulgated on May 29, 2003 (68
FR 32172), and amended on August 4, 2004 (69 FR 47001).  These standards
apply to each existing, new or reconstructed printing, coating,
slashing, dyeing or finishing of fabric and other textiles.  This
information is being collected to assure compliance with 40 CFR part 63,
subpart OOOO.

	

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They 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
affected facilities subject to NESHAP.  A semiannual report of
compliance is also required.

Any owner/operator subject to the provisions of this part shall maintain
a file of these measurements, and retain the file for at least five
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.

Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

An average of 140 respondents will be subject to the regulation over the
period covered by this ICR.  It is estimated that one additional
respondent per year will become subject to the regulation in the next
three years.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

Need for and Use of the Collection

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. 
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, hazardous air pollutants (HAP)
emissions from printing, coating and dyeing of fabrics and other
textiles facilities cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP were promulgated for this source category at 40
CFR part 63, subpart OOOO.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where 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. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	

The notifications required in the standard 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, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

	The required 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 requested recordkeeping and reporting are required under 40 CFR
part 63, subpart OOOO.

	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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	For the information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR, and used other resources
to obtain the most recent data available.  We reviewed information
available from the United States Census Bureau, the AIRS Facility System
(AFS), and websites covering flexible polyurethane foam fabrication.  We
also consulted with the EPA Office of Air Quality Planning and
Standards, Information Transfer and Program Integration Division, and
the National Council of Textile Organizations (NCTO), Mr. Mike Hubbard
at (704) 824-3522.

	

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 that 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 part 1320, section 1320.5.

	These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the part 70 permit program and the five year statute of limitations
on which the permit program is based.  The retention of records for five
years would allow EPA to establish the compliance history of a source
and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

	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

The respondents to the recordkeeping and reporting requirements are
printing, coating and dyeing of fabrics and other textiles.  The United
States Standard Industrial Classification (SIC) codes for the
respondents affected by the standards, which corresponds to the North
American Industry Classification System (NAICS) codes, are listed below
for source category descriptions.

Standard (40 CFR Part 63, Subpart OOOO)	SIC Codes	NAICS Codes

Broadwoven Fabric Mills, Cotton	2211	313210

Broadwoven Fabric Mills, Manmade Fiber and Silk	2221	313210

Broadwoven Fabric Mills, Wool (including dyeing and finishing)	2231
313210

Textile Goods, NEC (broadwoven fabrics of jute, linen, hemp, and ramie
and hand woven fabrics)	2299	313210

Narrow Fabric and Other Smallware Mills; Cotton, Wool, silk and Manmade
Fiber	2241	313221

Textile Goods, NEC (narrow woven fabric of jute, linen, hemp, and ramie)
2299	313221

Knitting Mills, NEC (knitting weft fabric and fabricating textile
products, such as bedspreads, curtains, or towels	2259	313241

Broadwoven Fabric Mills, Wool (wool broadwoven fabric finishing without
weaving fabric)	2231	313311

Finishers of Broadwoven Fabrics of Cotton	2261	313311

Finishers of Broadwoven Fabrics of Manmade Fiber and Silk	2262	313311

Broadwoven Fabric Mills, Wool (wool fabric, except broadwoven, finishing
without weaving fabric)	2231	313312

Knit Outerwear Mills (dyeing and finishing knit outerwear without
knitting outerwear)	2253	313312

Knit Underwear and Nightwear Mills (dyeing and finishing underwear and
nightwear without knitting garments)	2254	313312

Weft Knit Fabric Mills (finishing weft fabric without knitting weft
fabric)	2257	313312

Lace and Warp Fabric Mills (Finishing lace or warp fabric without
knitting lace or warp fabric)	2258	313312

Finishers of Textiles, NEC (except linen fabric finishing)	2269	313312

Thread Mills (finishing thread without manufacturing thread)	2284	313312

Textile Goods, NEC (finishing hard fiber thread and yarn without
manufacturing thread or yarn)	2299	313312

Coated Fabrics, Not Rubberized	2295	313320

Fabricated Rubber Products, NEC (rubberizing fabric or purchased textile
products)	3069	313320

Carpets and Rugs	2273	314110

Rubber and Plastics Hose and Belting	3052	326220

Gaskets, Packing, and Sealing Devices	3053	339991

Fabricated Rubber Products, NEC (rubberizing fabric or purchased textile
products)	3069	313320



	4(b)  Information Requested

	These reporting or recordkeeping requirements do not violate any of the
regulations that OMB established under 5 CFR part 1320, section 1320.5.

		(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles
(40 CFR part 63, subpart OOOO).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Initial notification	63.9(b), 63.4310(b)

Notification of intent to construction/reconstruction	63.9(b)(4),
63.4310

Notification of anticipated startup	63.9(b)(4), 63.4310

Notification of actual startup	63.9(b)(4), 63.4310

Request for extension of compliance date	63.9(c), 63.4283

Notification of performance test	63.9(e), 63.6310

Notification of compliance status	63.9(h)(2), 63.4310

Continuous monitoring system 	63.9(h)

Performance test report	63.10(d)(2), 63.4311

Startup, shutdown, malfunction (SSM) report	63.6.(e)(3), 63.4311

Excess emissions or no excess emissions report	63.10(e)(3), 63.4311



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	63.6(e)(3), 63.4311

Records are required to be retained for five years	63.10(b)(2)



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  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.

	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 33 percent of
the respondents use electronic reporting.

		(ii)  Respondent Activities	

 Respondent Activities

Read instructions.

Perform initial performance test, 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.

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

Transmit, or otherwise disclose the information.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.

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.

	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/operator for five years.

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., 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 Industry Burden for NESHAP for
Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR part
63, subpart OOOO).

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 20,821
(Total Labor Hours from Table 1).  These 

hours are based on Agency studies and background documents from the
development of this regulation, 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 the following labor rates: 

		Managerial	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2. Civilian Workers, 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 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 and
other costs such as photocopying and postage.

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 Cost`s for One Respondent	

(F)

Number of Respondents with O&M	

(G)

Total O&M,

(E X F)



Parametric monitoring (contractor)	

$2,953	

1	

$2,953	

$26	

140	

$3,640



The total capital/startup costs for this ICR are $2,953.  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 $3,640.
 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 $7,000.  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
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $44,574.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General 

Schedule” which excludes locality rates of pay.  Details upon which
this estimate is based appear in Table 2: Average Annual EPA Burden,
NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles
(40 CFR part 63, subpart OOOO).

	6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Based on our research for this ICR, on average over the next three
years, approximately 140 existing respondents will be subject to the
standard.  It is estimated that one additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is 140 per year.

	The 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	

(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	1	138	0	0	139

2	1	139	0	0	140

3	1	140	0	0	141

Average	1	139	0	0	140



	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 140.  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

Initial notification	1	1	0	1

Application of construction/reconstruction	1	1	0	1

Notification of anticipated startup	1	1	0	1

Notification of actual startup	1	1	0	1

Notification of compliance status	1	1	0	1

Notification of performance test	1	1	0	1

Performance test report	1	1	0	1

Report of monitoring exceedances	6.6	2	0	13.2

Report of no excess emissions	59.4	2	0	118.8

Startup, shutdown, malfunction report	6.6	2	0	13.2

Report of compliance deviation	7.4	2	0	14.8

Report of no compliance deviations	66.6	2	0	133.2



	Total	300



	The number of Total Annual Responses is 300.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

	6(e)  Bottom Line Burden Hours Burden 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 $1,680,831.  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, NESHAP for
Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR part
63, subpart OOOO).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 69 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $7,000.  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.

		(ii) The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 1,099 labor hours at a cost of $44,574.  See Table 2.
Annual Agency Burden and Cost, NESHAP for Printing, Coating and Dyeing
of Fabrics and Other Textiles (40 CFR part 63, subpart OOOO).

	

	6(f)  Reasons for Change in Burden

	The decrease in burden from the most recently approved ICR is due to
the requirements of the standard, which requires all existing sources to
be in compliance within three years.  All existing sources are
therefore, assumed to be incompliance and the burden associated with the
initial compliance efforts no longer exists.

	There was a decrease in the capital/startup and operations and
maintenance (O&M) costs from the previous ICR.  The reason for this
decrease is we are only accounting for the number of respondents
associated with the O&M costs, not the number of reports filed annually
that was used in the previous ICR.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 69 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
EPA-HQ-OECA-2005-0023, which is available for online viewing at 
www.regulations.gov, or in person 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, DC  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 www.regulations.gov.  This site can be used 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.  You
can also send comments 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.  Please include
the EPA Docket Number:  EPA-HQ OECA-2005-0023, and OMB Control Number
2060-0522 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:  Annual Respondent Burden and Cost – NESHAP for Printing,
Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63,
Subpart OOOO) 

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $  b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting Requirements









   A.  Read instructions 	4	1	4	1	4	0.2	0.4	$371.35

   B.  Required activities









       Initial oxidizer performance test c, e	280	1	280	1	280	14	28
$25,994.64

       Repeat oxidizer performance 

       test c, e, f 	280	1	280	0.2	56	2.8	5.6	$5,179.44

       Initial capture performance test c, e	215	1	215	1	215	10.75	21.5
$19,960.16

       Repeat capture performance test c, e, f	215	1	215	0.2	43	2.15	4.3
$3,992.03

       Startup, shutdown, malfunction

       plan c	40	1	40	1	40	2	4	$3,713.52

       Solvent recovery system compliance

       determination c, p	4	12	48	13.2	633.6	31.68	63.36	$58,822.16

       Emission rate limit compliance                 determination  	4
12	48	140	6,720	336	672	$623,871.36

       Coordination with suppliers g	40	1	40	140	5,600	280	560
$519,892.80

    C.  Create information	See 4B







	    D.  Gather existing information	See 4B







	    E.  Write report









        Initial notification c	2	1	2	1	2	0.1	0.2	$185.68

        Notification of construction/                     reconstruction
c	2	1	2	1	2	0.1	0.2	$185.68

        Notification of anticipated startup c	2	1	2	1	2	0.1	0.2	$185.68

        Notification of actual startup c	2	1	2	1	2	0.1	0.2	$185.68

        Notification of compliance status c	4	1	4	1	4	0.2	0.4	$371.35

        Notification of performance test c, e	2	1	2	1	2	0.1	0.2	$185.68

        Performance test report c, e	40	1	40	1	40	2	4	$3,713.52

        Report of monitoring

        exceedances  c, h, k	16	2	32	6.6	211.2	10.56	21.12	$19,607.39

        Report of no excess emissions c, i,  k	8	2	16	59.4	950.4	47.52
95.04	$88,233.23

        Startup, shutdown, malfunction                 report c, j, k	8
2	16	6.6	105.6	5.28	10.56	$9,803.70

        Report of compliance

        deviation d, k, l	16	2	32	7.4 	236.8	11.84	23.68	$21,984.04

        Report of no compliance

        deviations d, k, m	8	2	16	66.6 	1,065.6	53.28	106.56	$98,928.18

4.  Recordkeeping Requirements









    A.  Read instructions	See 4B







	    B.  Plan activities	N/A







	    C.  Implement activities 	N/A







	    D.  Develop record system	N/A





	 

    E.  Time to enter information









        Records of all information required          by standards n	0.25
52	13	140	1,820	91	182	$168,965.52

    F.  Time to train personnel	N/A







	    G. Time to adjust existing ways to                 comply with
previously applicable            requirements	N/A







	    H. Time to transmit or disclose                      information o
0.25	2	0.5	140	70	3.5	7	$6,498.66

     I. Time for audits 	N/A







	Subtotals Labor Burden and cost  



	18,105.2	905.26	1,810.52	$1,680,831.02

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	20,821	$1,680,831



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 140, which equates to 66 coating and
printing sources, and 74 slashing, dyeing, and finishing sources. There
will be one additional new source per year that will become subject to
the rule over the three-year period of this ICR. 

b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, (Table 2. Civilian Workers, by occupational
and industry group.(  The rates are 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.

c  This applies only to coating and printing facilities.

d  This applies only to slashing, dyeing and finishing facilities.

e  Occurs one time for new sources and involves one-time startup costs
associated with initial compliance determination and acquisition,
installation, and utilization of technology and systems needed to
support recordkeeping and reporting.

f  It is assumed that 20 percent of respondents will have to repeat
performance tests. 

g  We have assumed that it will take 40 hours for each respondent to
coordinate with suppliers.

h  We have assumed that 10 percent of respondents will report monitoring
exceedances.

i  We have assumed that 90 percent of respondents will report no excess
emissions.

j  We have assumed that 10 percent of respondents will file a startup,
shutdown, malfunction reports.

k  Semiannual reports are required.

l  It is assumed that 10 percent of respondents will report compliance
deviations.

m  It is assumed that 90 percent of respondents will report no
compliance deviations.

n  It is assumed that all of the respondents will be required to record
information on a weekly basis.

o  It is assumed that respondents will be required to transmit/disclose
information on a semiannual basis. 

p  It is assumed that 20 percent of the coating and printing facilities
will use solvent recovery equipment (20x66=13.2)

Table 2:  Average Annual EPA Burden - NESHAP for Printing, Coating and
Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) 

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants per year  a	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Cost, $ b

1.   Initial performance test c	495	1	495	1	495	24.75	49.5	  $23,077.39

2.   Repeat performance test                 preparations c, e	4

	0.1

	0.4

	1

	0.4

	0.02

	0.04

	$18.65



3.   Repeat performance test c, e	495	0.1	49.5	1	49.5	2.47	4.95
$2,307.45

4.   Report Review









        Notification of applicability	2	1	2	1	2	0.1	0.2	$93.24

        Notification of construction/

        reconstruction	2	1	2	1	2	0.1	0.2	$93.24

        Notification of anticipated              startup	2	1	2	1	2	0.1
0.2	$93.24

        Notification of actual startup	2	1	2	1	2	0.1	0.2	$93.24

        Notification of initial                      performance test c
2	1	2	1	2	0.1	0.2	$93.24

        Notification of compliance             status c	2	1	2	1	2	0.1
0.2	$93.24

        Review of initial performance         test report c	8	1	8	1	8
0.4	0.8	$372.97

        Review of repeat                            performance test
report c, f	8	0.1	0.8	1	0.8	0.04	0.08	$37.30

        Review of excess emissions           report c, g	8	1	8	6.6	52.8
2.64	5.28	$2,461.59

        Review of no excess                       emissions report c, h
2	1	2	59.4	118.8	5.94	11.88	$5,538.58

        Review of startup, shutdown,          malfunction reports c, i	2
1	2	13.2	26.4	1.32	2.64	$1,230.80

        Review of compliance                    deviations report d, j	8
1	8	7.4	59.2	2.96	5.92	$2,759.96

        Review of no compliance               deviations reports d, k	2
1	2	66.6	133.2	6.66	13.32	$6,209.91

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	1,099	

$44,574



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 140, which equates to 66 coating and
printing sources, and 74 slashing, dyeing, and finishing sources.  There
will be one additional new source per year that will become subject to
the rule over the three-year period of this ICR.

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) (2005 General Schedule( which
excludes locality rates of pay.

c  This applies only to coating and printing facilities.    

d  This applies only to slashing, dyeing and finishing facilities.    

e  We have assumed that 10 percent of new sources will have to repeat
performance test preparations and testing.

f  Assume that 10 percent of new sources will review the repeat
performance test report.

g  We have assumed that 10 percent of respondents will be engaged in the
reviewing of excess emissions reports.

h  We have assumed that 90 percent of respondents will be engaged in the
reviewing of no excess emissions reports.

i  We have assumed that 20 percent of respondents will have to review
the startup, shutdown, malfunction reports.

j  We have assumed that 10 percent of respondents will review the
compliance deviations report.

k  We have assumed that 90 percent of respondents will review the no
compliance deviations report.

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