SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
part
60,
subpart
FFF)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
part
60,
subpart
FFF)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
subpart
FFF
were
proposed
on
January
18,
1983,
and
promulgated
on
June
29,
1984.
These
standards
apply
to
the
following
facilities
in
subpart
FFF:
each
rotogravure
printing
line
used
to
print
or
coat
flexible
vinyl
or
urethane
products,
and
for
which
construction,
modification
or
reconstruction
commenced
after
January
18,
1983.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
60,
subpart
FFF.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
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.
Monitoring
requirements
specific
to
this
rule
provide
information
on
the
operation
of
emissions
control
devices.
Semiannual
reports
of
excess
emissions
or
exceedances
of
standards
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required,
in
general,
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
20
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
one
additional
source
will
become
subject
to
the
standard
in
the
next
three
years,
for
an
average
of
0.33
new
sources
per
year.
These
figures
are
based
on
queries
conducted
in
the
EPA's
Air
Facility
System
(
AFS)
through
the
Online
Tracking
Information
System
(
OTIS).
The
cost
of
this
Information
Collection
Request
(
ICR)
will
be
$
36,535.

In
the
development
of
this
ICR,
we
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
(
TOC)
on
the
active
ICR.
The
TOC
is
as
follows:

The
request
to
extend
this
collection
of
information
is
approved
for
three
years
pursuant
to
the
Paperwork
Reduction
Act
as
codified
at
5
CFR
1320.
Before
resubmission
of
this
ICR,
the
Agency
should
provide
in
the
Supporting
Statement
a
discussion
of
the
estimates
of
burden
per
respondent
and
the
methodology
by
which
the
Agency
generated
those
estimates.
Furthermore,
the
Agency
should
revisit
the
estimates
of
the
number
of
sources
to
confirm
that
burden
estimates
are
reasonable.
2
For
this
information
collection,
we
used
several
different
resources
to
obtain
the
most
recent
data
available
for
the
flexible
vinyl
and
urethane
coating
and
printing
sources.
We
first
referenced
the
most
recent
ICR,
and
accessed
the
data
(
April
14,
2003)
available
on
the
Air
Facility
System
(
AFS)
database
maintained
by
the
Office
of
Compliance.
We
also
retrieved
data
from
the
Toxic
Release
Inventory
System
(
TRIS)
maintained
by
the
Office
of
Environmental
Information
(
OEI).
In
addition,
we
contacted
all
the
facilities
listed
in
our
queries
for
confirmation.
Based
on
this
information,
there
will
be
an
estimated
20
respondents
with
one
source
of
industry
growth
(
an
average
of
0.33
sources)
expected
over
the
next
three
years.

The
burden
per
respondent
and
the
methodology
employed
is
discussed
in
section
6
of
this
ICR.

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)(
1).

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
required
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
volatile
organic
compounds
(
VOC)
from
printing
and
coating
flexible
vinyl
and
urethane
products
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
volatile
organic
compounds
are
the
result
of
operation
of
the
printing
on
flexible
vinyl
and
urethane
coating.
These
standards
rely
on
the
reduction
of
volatile
organic
compounds
emissions
by
using
inks
with
low
VOC
content
or
on
the
capture
of
those
compounds
by
either
solvent
recovery
systems,
thermal
incinerators
or
catalytic
incinerators.

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
(
if
this
method
is
chosen
to
comply
with
the
regulation)
are
properly
installed
and
operated
and
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
For
facilities
using
control
equipment
to
meet
this
standard,
the
operating
conditions
may
include
temperature
or
volatile
organic
compound
concentration.

The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
3
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subpart
FFF.

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
on
September
26,
2002.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
used
several
different
resources
to
obtain
the
most
recent
data
available
for
the
flexible
vinyl
and
urethane
coating
and
printing
sources.
We
referenced
the
most
recent
ICR,
and
accessed
the
data
(
April
14,
2003)
available
on
the
Air
Facility
System
(
AFS)
database
maintained
by
the
Office
of
Compliance.
We
also
retrieved
data
from
the
Toxic
Release
Inventory
System
(
TRIS)
maintained
by
the
Office
of
Environmental
Information.
In
addition,
we
contacted
all
the
facilities
listed
in
our
queries
for
confirmation.

Based
on
this
information
there
will
be
an
estimated
20
respondents
with
one
industry
growth
expected
over
the
next
three
years.

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
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
1320.5.
4
3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
However,
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,
c
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
of
the
recordkeeping
and
reporting
requirements
are
subpart
FFF
that
commenced
construction,
modification,
or
reconstruction
after
January
18,
1983.
They
are
listed
under
SIC
Codes
2295
and
2679.
Both
of
these
Codes
contain
firms
that
are
not
covered
by
this
rule.
This
rule
does
not
cover
resilient
floor
covers
or
flexible
packaging.
The
government
is
in
the
process
of
transitioning
to
the
new
North
American
Industrial
Classification
System
(
NAICS).
The
NAICS
codes
for
this
industry
are
31332,
322222,
and
322299
for
source
category
description.

4(
b)
Information
Requested,
including
record
keeping
requirements
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
New
Source
Performance
Standards
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
part
60,
subpart
FFF).

A
source
must
make
the
following
reports:

Reports
for
40
CFR
part
60,
subpart
FFF
Construction/
reconstruction
60.7(
a)(
1)

Physical
or
operational
change
60.7(
a)(
4)

Initial
performance
test
60.8(
d)

Delay
of/
and
rescheduled
initial
performance
test(
s)
60.8(
d)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
results
60.8(
a),
60.585(
a)

Demonstration
of
continuous
monitoring
system
60.7(
a)(
5)

Semiannual
reports
60.7(
c)
and
60.7(
d)
60.585(
b)
5
A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
part
60,
subpart
FFF
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)
60.584(
d)

Records
for
sources
with
continuous
monitoring
systems
60.7(
d)

Maintain
file
of
all
measurements
60.7(
e)
60.583(
b)
and
60.583(
c)

Records
of
performance
test
conditions
60.8(
c)

Records
of
operating
conditions
for
control
equipment
(
i.
e.,
temperature
or
VOC
concentration)
60.584(
a)(
2)
60.584(
b)(
2)
60.584(
c)(
2)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
VOC
concentration
or
temperature.

Perform
initial
performance
test,
Reference
Methods
24,
25,
1,
2,
3,
and
4
tests,
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.

Adjust
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

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

Transmit,
or
otherwise
disclose
the
information.

Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
volatile
organic
compounds.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
Regulatory
Agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically,
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
Agencies.
6
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)
database.

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
(
VOC
concentration
or
temperature)
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
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
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
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
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
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
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
7
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
part
60,
subpart
FFF).

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
593
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
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
a
technical
labor
rate
of
$
61.66
per
hour.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rate
has
been
increased
by
110%
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
activity
in
the
regulations
are
for
labor
and
continuous
emission
monitoring
(
CEM).
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
The
type
of
industry
costs
associated
with
the
information
collected
activity
in
the
regulations
are
for
labor
and
continuous
emission
monitoring
(
CEM).
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.
8
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
for
One
Affected
Facility
(
C)
Number
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Affected
Facility
(
F)
Number
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Temperature
or
feed
rate
monitor
$
20,000
0.33
$
6,600
$
9,000
6
$
54,000
The
total
capital/
startup
cost
for
this
ICR
is
$
6,600.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
54,000.
This
is
the
total
of
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
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
of
the
next
three
years
of
the
ICR
are
estimated
to
be
$
60,600.
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.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
3,896,000.
[
see
Table
2
in
Section
6(
e)].
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
39.49.
This
rate
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2,
Annual
Agency
Burden
for
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
part
60,
subpart
FFF)
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
40
CFR
part
60
subpart
FFF
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Source
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD
)+
F
9
Respondent
Universe
and
Number
of
Responses
Per
Year
40
CFR
part
60,
subpart
FFF
0.33
2
20
2
0
40.66
The
number
of
total
respondents
is
20.33,
rounded
to
20.
This
number
is
the
sum
of
column
A
and
column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period
(
i.
e.,
the
total
of
the
number
of
new
respondents
over
the
three­
year
period
divided
by
three
years).
It
is
shown
in
block
13(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
41.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
It
is
shown
in
block
13(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.

The
total
annual
labor
costs
are
$
36,535,000.
This
number
is
not
shown
on
the
OMB
83­
I
form.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Annual
Respondent
Burden
and
Cost
­
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
part
60,
subpart
FFF).

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
61,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
14
(
rounded)
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
increase
in
the
number
of
sources,
due
to
more
accurate
estimates
of
existing
and
anticipated
new
sources.
We
first
determined,
based
on
queries
conducted
on
the
Air
Facility
System
through
the
Online
Tracking
Information
System,
that
there
were
22
respondents
potentially
subject
to
this
NSPS
rule.
Since
the
active
ICR
indicated
that
there
were
10
existing
respondents
subject
to
the
rule
and
one
new
source
was
estimated
for
the
three­
year
period,
we
conducted
additional
research
and
contacted
each
facility,
and
subsequently
determined
that
the
number
of
respondents
subject
to
the
rules
addressed
by
this
ICR
is
20.
The
change
in
respondent
cost
is
also
due
to
a
labor
rate
change
where
the
rate
has
increased
over
the
three­
year
period
of
this
ICR.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
14
(
rounded)
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.
10
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
2003­
0040,
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
Docket
is
(
202)
566­
1514.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
Once
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0040
and
OMB
Control
Number
2060­
0073
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
the
information.
11
TABLE
1:
Annual
Industry
Burden
­
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
Part
60,
Subpart
FFF)

Occurrences/
Hours/

Hours
per
Respondent/
Respondent/
Respondents
Hours
Cost/

Occurrence
Year
Year
per
Year
per
Year
Year
a
Reporting/
Recordkeeping
(
A)
(
B)
(
C=
A
x
B)
(
D)
(
E
=
C
x
D)
(
F=
E
x
$
61.66)
___________________________________________________________________________________________________________________________

1.
APPLICATIONS
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
REPORTING
REQUIREMENTS
New
Sources
b
A.
Read
Instructions
c
1
1
1
0.33
0.33
$
20.35
B.
Required
Activities
New
Sources
Initial
performance
test
d
280
1
280
0.33
92.4
$
5,697.38
Repeat
performance
test
e
280
0.2
56
0.33
18.48
$
1,139.48
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3B
E.
Write
Report
New
Sources
Notification
of
construction/
f
2
1
2
0.33
0.66
$
40.70
reconstruction
Notification
of
initial
performance
g
2
1
2
0.33
0.66
$
40.70
test
Report
of
initial
performance
test
Included
in
3B
Existing
Plants
Submit
semi­
annual
report
h
4
2
8
20
160
$
9,865.60
SUBTOTAL
272.53
$
16,804.21
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
E.
Time
to
Enter
Information
Records
of
startup,
shutdown
and
i
1.5
2
3
20
60
$
3,699.60
malfunctions
Records
of
VOC,
temperature
and
j
0.25
52
13
20
260
$
16,031.60
CMS
maintenance
F.
Audits
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
SUBTOTAL
320
$
19,731.20
TOTAL
ANNUAL
INDUSTRY
COST
BURDEN
(
rounded)
593
$
36,535
__________________________________________________________________________________________________________

Assumptions:

a.
Technical
labor
rate
(
Bureau
of
Labor
Statistics)
is
$
29.36
+
110%
=
$
61.66
b.
Number
of
new
facilities
(
per
year):
0.33
c.
Time
required
to
read
instructions
(
hours):
1
d.
Time
required
to
compete
performance
test
(
hours):
280
e.
Rate
of
failed
performance
tests:
20%

f.
Time
required
for
notification
preparation
(
hours):
2
g.
Time
required
for
notification
of
initial
performance
test
(
hours):
2
h.
Time
required
to
compile
data
for
semiannual
report
(
hours):
4
i.
Time
required
to
record
startup,
shutdown,
and
malfunction
(
hours):
1.5
j.
Time
required
to
record
VOC,
temperature
and
CMS
maintenance
(
hours):
0.25
12
TABLE
2:
AVERAGE
Annual
EPA
Burden
­
NSPS
for
Flexible
Vinyl
and
Urethane
Coating
and
Printing
(
40
CFR
Part
60,
Subpart
FFF)

EPA
hrs/
Occurrences
EPA
hrs/
Plants/
EPA
Occurrence
Plant/
Year
Plant/
Year
Year
Hrs/
Year
Burden
Items
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
____________________________________________________________________________________________________________________________

Required
Activities
New
Plant
Initial
performance
tests
24
1
24
0.33
7.92
Repeat
performance
tests
b
24
0.2
4.8
0.33
1.584
Report
Review
New
Plant
Notification
of
construction
c
2
1
2
0.33
0.66
Notification
of
initial
startup
d
0.5
1
0.5
0.33
0.165
Notification
of
actual
startup
e
0.5
1
0.5
0.33
0.165
Notification
of
initial
test
0.5
1.2
0.6
0.33
0.198
Review
test
results
g
0.5
1.2
9.6
0.33
3.168
Existing
Plants
Semiannual
reports
of
emission
h
2
2
4
20
80
exceedances
TOTAL
ANNUAL
HOURS
93.86
Travel
expenses
i
(
1
person
x
.33
plant/
year
x
3
days/
plant
x
$
75
per
diem)
+
($
350
round
trip/
plant
x
.33
plant/
year)
=
$
189.75
Salary
j
(
1
person
x
93.86
hr/
year
x
$
39.49/
hrs
)
=
$
3,706.53
TOTAL
ANNUAL
EPA
COST
BURDEN
=
$
3,896
(
rounded)
_______________________________________________________________________________________________________________________________

Assumptions:

a.
Time
required
to
participate
with
performance
test
(
hours
per
plant):
24
b.
Rate
of
failed
performance
tests:
20%

c.
Time
required
to
review
construction
notification
(
hours):
2
d.
Time
required
to
review
startup
and
initial
test
notifications
(
hours):
0.5
e.
Notification
of
actual
startup
(
hours):
0.5
f.
Time
required
to
review
initial
test
notification
(
hours):
0.5
g.
Time
required
to
review
test
results
(
hours):
8
h.
Time
required
to
review
semi­
annual
reports
(
hours):
2
i.
Round
trip
airfare
to
visit
plant:
$
350
j.
EPA's
labor
rate
at
a
GS­
12,
Step
1,
times
1.6
government
overhead
expenses:
$
39.49
