SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Paper and Other Web Coating (40 CFR part 63, subpart JJJJ)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NESHAP for Paper and Other Web Coating (40 CFR part 63, subpart JJJJ)

	1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for Paper and Other Web Coating were proposed on September 13, 2000, (65
FR 55331), and promulgated on December 4, 2002, (67 FR 72341).  These
regulations apply to each existing, new, or reconstructed affected
source at facilities engaged in paper and other web coating that
includes web coating lines engaged in the coating of metal webs used in
flexible packaging, and web coating lines engaged in the coating of
fabric substrates for use in pressure sensitive tape and abrasive
materials.  This Information Collection Request (ICR) is for Hazardous
Air Pollutant (HAP) emission sources in the Paper and Other Web Coating
(POWC) operations source category.  This information is being collected
to assure compliance with 40 CFR part 63, subpart JJJJ.

	In general, all NESHAP standards require initial notifications,
compliance status reports, and performance tests by the owners/operators
of the affected facilities.  They also are required to maintain records
of the occurrence and duration of any startup, shutdown, or malfunction
(SSM) 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.  Semiannual
summary reports also are 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 215 respondents will be subject to the regulation over
the period covered by this ICR, and it is estimated that six (6)
additional respondent per year will become subject to the regulation in
the next three years.

	There is a reduction of 226 respondents compared to the previous ICR
due to the completion of a one-time-only activity.

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

2.  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, particulate matter emissions from
facilities conducting paper and other web coating may cause or
contribute to air pollution that might reasonably be anticipated to
endanger public health or welfare.  Therefore, the NESHAP were
promulgated for the source category at 40 CFR part 63, subpart JJJJ.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information also is
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
also may 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 JJJJ.

	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 Air Facility System
(AFS), and websites covering paper and other web coating.  We also
consulted with the EPA’s Office of Air Quality Planning and Standards,
Information Transfer and Program Integration Division; the Graphic Arts
Technical Foundations Industry, Mr. Gary Jones at (412) 741-6860; and
the American Forest and Paper Association (AF&PA), Mr. Glynn Roundtree
at (202) 463-2762.

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 violates 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.  Also, 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 contains sensitive
questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
paper and other web coated product producers.  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 JJJJ)	

SIC Codes	

NAICS Codes



Corrugated and Solid Fiber Box Manufacturing	

2653	

322211



Folding Paperboard Box Manufacturing	

2657	

322212



Coated and Laminated Packaging Paper and Plastics Film Manufacturing	

2671	

322221



Coated and Laminated Paper Manufacturing  [dupe ?]	

2672 and 2679	

322222



Plastics, Foil, and Coated Paper Bag Manufacturing	

2673	

322223



Uncoated Paper and Multiwall Bag Manufacturing	

2674	

322224



Surface-Coated Paperboard Manufacturing	

2675	

322226



All Other Converted Paper Product Manufacturing	

2675 and

2679	

322299



Commercial Gravure Printing	

2754	

323111



Manifold Business Forms Printing	

2761	

323116



Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing	

3081	

326113



Laminated plastics Plate, Sheet (except Packaging), and Shape
Manufacturing	

3083	

326130



Abrasive Product Manufacturing	

3291	

327910



Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses	

3497	

322225



	4(b)  Information Requested

	None of these reporting or recordkeeping requirements violates any of
the regulations established by OMB at 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 Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Initial notification	63.9(b), 63.3400(b)

Notification of performance test	63.7, 63.9(e), 63.3400(d)

Notification of compliance status	63.9(h), 63.3400(e)

Performance test report	63.3400(e)

SSM report	63.10(d)(5), 63.3400(g)

Semiannual compliance report	63.3400(c)(3)



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	63.10(b)(2), 63.3410(a)

Records are required to be retained for five years	63.10(b)(1)



Electronic Reporting

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

	Also, regulatory agencies, in cooperation with the respondents,
continue to create reporting systems to transmit data electronically. 
However, electronic reporting systems still are 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.

Perform initial performance test, Reference Method 24, 25, 25A, 1, 1A,
2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4,  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.



	

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 and
monitoring 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 Air Facility
System (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,
operation, 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
Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ).

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 11,312
(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.

		(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 1	

(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)



Parametric monitoring (contractor)	

$10,000	

5	

$50,000	

$25	

192	

$4,800



Continuous emission monitoring system (CEMS)	

$183,500	

1	

$183,500	

$26,700	

23	

$614,100

 1  There will be six new sources per year over the next three years of
this ICR, out of the six sources, one source will be using              
                                                                        
                                                                   
solvent recovery devices and will engage the CEMS to monitor their
emissions.

The total capital/startup costs for this ICR are $233,500.  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 operation and maintenance (O&M) costs for this ICR are
$618,900.  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 $852,400.  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 $326,875.  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 Paper and Other Web Coating (40 CFR Part 63, Subpart
JJJJ).

	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 215 existing respondents will be subject to the
standard.  It is estimated that six additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is 215 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	6	203	0	0	209

2	6	209	0	0	215

3	6	215	0	0	221

Average	6	209	0	0	215



	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 215.  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	6	1	0	6

Notification of performance test	6	1	0	6

Notification of compliance status	6	1	0	6

Performance test reports	6	1	0	6

SSM reports	192	0.2	0	38.4

Semiannual summary report	215	2	0	430



	Total	492



	The number of Total Annual Responses is 492.  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 are 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 $ 913,229.  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 Paper
and Other Web Coating (40 CFR Part 63, Subpart JJJJ).  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 23 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $ 852,400.  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 the next three years is
estimated to be 8,066 labor hours at a cost of $ 327,000.  See Table 2.
Annual Agency Burden and Cost, NESHAP for Paper and Other Web Coating
(40 CFR Part 63, Subpart JJJJ).

	6(f)  Reasons for Change in Burden

	The decrease in burden from the most recently approved ICR is due to
the requirements of the rule.  All existing sources must be in
compliance within three years of promulgation date, thus, less burden is
imposed on existing sources.

Also, in the previous ICR, 226 respondents read the rule and determined
that they were not subject, since this is a one-time only activity, the
number of respondents is 226 fewer than in the previous ICR.

	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.  Also, there are only six new sources
per year versus 18 in the previous ICR.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 23 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-2005-0032, 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, N.W.,
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 the Federal Docket Management System
(FDMS) at http://www.regulations.gov.  Use FDMS 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, N.W., Washington, D.C. 20503, Attention:
Desk Officer for EPA.  Please include the EPA Docket ID Number
OECA-2005-0032 and OMB Control Number 2060-0511 in any correspondence.

Part B of the Supporting Statement

	This part is not applicable because no statistical methods were used in
collecting this information.

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