SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

 NSPS for Pressure Sensitive Tape and Label Surface Coating Operations

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

New Source Performance Standards (NSPS) for Pressure Sensitive Tape and
Label Surface Coating Operations (40 CFR part 60, subpart RR) (Renewal)

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR Part 60, Subpart RR were proposed on December 30,
1980, and promulgated on October18,1983.  These regulations apply to
each coating line used in the manufacture of pressure sensitive tape and
label materials, and on which construction or reconstruction commenced
after December 30, 1980. Facilities that input 45 megagrams of volatile
organic compounds (VOC) or less per 12 month period are not subject to
the emission limit established by the subpart.  This information is
being collected to assure compliance with 40 CFR part 60, subpart RR.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports.  Owners or operators are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  These notifications, reports, and records are essential in
determining compliance, and are required of all sources subject to NSPS.
 

Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records.   All reports are sent to the delegated State or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) Regional Office.

Approximately 36 sources are currently subject to the regulation, and it
is estimated that an additional one source per year will become subject
to the regulation in the next three years.  It is further assumed that
there is an average of one affected facility per plant (respondent). 
These numbers are based on previous experience with the industry and a
recent search of the Agency’s AFS data base.  The increase in burden
from the most recently approved ICR is due to an adjustment.  The
adjustment increase is due to a correction made to the frequency of
temperature reports on sources that use incinerators to control
emissions. 

OMB approved the currently active 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 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

... application of the best technological system of continuous emissions
reduction which (taking into consideration the cost of achieving such
emissions reduction, or any non-air quality health and environmental
impact and energy requirements) the Administrator determines has been
adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.  In
addition, Section 114(a) states that the Administrator may require any
owner or 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, volatile organic compound (VOC)
emissions from coating lines used in the manufacture of pressure
sensitive tape and label materials cause or contribute to air pollution
that may reasonably be anticipated to endanger public health or welfare.
 Therefore, NSPS were promulgated for this source category at 40 CFR
Part 60, Subpart RR.

2(b)  Practical Utility/Users of the Data

The control of emissions of VOCs from coating lines used in the
manufacture of pressure sensitive tape and label materials requires not
only the installation of properly designed equipment, but also the
operation and maintenance of that equipment.  Emissions of VOCs from
coating lines used in the manufacture of pressure sensitive tape and
label materials are the result of operation of the affected facilities. 
The subject standards are achieved by the use of reduced (low solvent)
VOC coatings; VOC solvent capture and reuse; or capture and destruction
of VOC emissions by incineration.  The notifications required in the
applicable regulations 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 or that low solvent coatings are being used and the regulations
are 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 standards, and serve as a record of the operating conditions
under which compliance was achieved.  

Facilities that are subject to the emission limit need to ensure that
the solvent recovery system or thermal incinerator is functioning
correctly.  Thermal incinerators must be operated at a high enough
temperature to ensure 90 percent control of VOC.  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 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 the
applicable regulations, 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 recordkeeping and reporting requested is required under 40 CFR part
60, subpart RR.

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 their 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 June 21, 2006 (71 FR 35652). 
No Comments were received on the burden published in the Federal
Register.

3(c) Consultations

	The primary source of information as reported by industry, in
compliance with the record keeping and reporting provisions in the
stand, is the ARS (Air Facility Subsystem) which is operated and
maintained by EPA’s Office of Compliance.  AFS is the Agency’s
database for the collection, maintenance and retrieval of all compliance
data.  In consultation with the Agency’s industry experts and the AFS
database, we have determined that there has been no growth in the number
of respondents since the last ICR.

	In determining the correct burden estimate associated with this ICR,
industry trade associations and other interested parties have been
provided an opportunity to comment on the burden associated with the
standard as it was being developed and in subsequent renewals of the
ICR.  It is our policy to carefully review any comments received since
the last ICR renewal, including those submitted in response to the first
federal register notice, and respond appropriately. Per this guidance,
all data assumptions from the previous ICR renewal were used as the
basis for estimating the hourly and cost burdens associated with this
renewal.  One correction was made to the assumption entered for the
frequency of temperature reports. 

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 is 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 1320.6.

3(f)  Confidentiality

The required information consists of emissions data and other
information that have been determined not to be private.  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, Chapter 1, Part 2, Subpart B - Confidentiality of Business
Information (CBI) (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
pressure sensitive tape and label surface coating operations, and on
which construction or reconstruction commenced after December 30, 1980. 
The SIC code for the respondents affected by the standards is SIC (U.S.
Standard Industrial Classification) 2672 which corresponds to the NAICS
(North American Industry Classification System) 322222 for coating lines
used in the manufacture of pressure sensitive tape and label materials.

4(b)  Information Requested 

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
NSPS for the Pressure Sensitive Tape and Label Surface Coating
Operations, 40 CFR Part 60, Subpart RR. 

A source must make the following reports:

Reports for 40 CFR part 60, subpart RR



Construction/reconstruction	

60.7(a)(1)



Actual startup	

60.7(a)(3)



Initial performance test results	

60.8 (a)



Initial performance test	

60.8(d)



Demonstration of continuous monitoring system	

60.7(a)(5)



Physical or operational change	

60.7(a)(4)



Excess emissions report	

60.7(c),

60.447(b-c)



A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart RR



Startups, shutdowns, malfunctions, periods where the                    
          continuous monitoring system is inoperative.	

60.7(b)



Maintain calender month record of all coatings used	

60.445(a)



Maintain calendar month record of solvent applied in coating	

60.445(b)



Maintain calendar month record of solvent recovered for                 
        facility using a solvent recovery device	

60.445(c)



Maintain calendar month record of exhaust gas temperature for           
   facility using a thermal incineration solvent destruction device	

60.445(e)



Records are required to be retained for two years.  The most recent two
years of records must be retained at the facility	

60.445(h)



(ii) Respondent Activities	

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate CMS for temperature monitoring
of the exhaust gases at a thermal incineration solvent destruction
device; a CMS for  temperature monitoring of the gas upstream and
downstream of the catalyst bed at a catalytic incineration solvent
destruction device; if applicable, install a monitoring device which
continuously indicates that the hood or enclosure that captures fugitive
VOC emissions is operating.



Perform initial performance test, Reference Methods 24 and 25 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 the existing ways to comply with any previously applicable
instructions and                      requirements.



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





Transmit, or otherwise disclose the information.



Electronic Reporting

Presently sources are using monitoring equipment that provides parameter
data in an automated way (e.g., temperature monitoring).  Although
personnel at the source still needs 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.  At this time it is estimated that approximately 10% of the
respondents use electronic reporting.

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 AIRS (Aerometric Information
Retrieval              System) Facility Subsystem (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 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 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 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
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.

The number of small entities potentially subject to the requirements of
this information collection request is estimated to be 29 percent of the
respondent universe.  This estimate is based on the percent of plants in
this industry that were classified as small entities during the
development of this rule (see BID document EPA-450/3-80-003a, p. 8-30).

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 2: Annual Industry Burden for NSPS for
Pressure Sensitive Tape and Label Coating Operations (40CFR part 60,
subpart RR).

6.  Estimating the Burden and Cost of the Collection

Table 2 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 3,353
(Total Labor Hours from Table 2).  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 $57.12 per hour.  This rate is
from the United States Department of Commerce Bureau of Labor
Statistics, March 2001, Table 10. Private Industry, by Occupational and
Industry Group.  The rate is from column 1, Total Compensation.  The
wage rate has been increased by 110% to account for the benefit packages
available to those employed by private industry.  The recordkeeping and
reporting requirements in NSPS subpart RR were designed to be performed
by technical staff.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection
activity in the regulations are labor and continuous emission monitors
(CEMs).  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)

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	

$7,000	

       1           	

$7,000	

        $1,800	

      36	

  $64,800

 	

The total capital/startup costs for this ICR are $7,000.  This is the
total of column D in the above table.  The total operation and
maintenance (O&M) costs for this ICR are $64,800.  This is the total of
column G.  

  

The total respondent non-labor costs 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 $71,800.  

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 3 years of the ICR is
estimated to be $12,140 [see Table 1 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 $38.30.  This rate is from the Office of
Planning and Management’s (OPM) 2002 General Schedule which excludes
locality rates of pay.  

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



Respondent Universe and Number of Responses/Year



Regulation Citation

40 CFR Part 60, Subpart RR	

(A)

Number  of  New Sources/

Year	

(B)

Number. of Reports for New Sources	

(C)

Number  of  Existing Sources	

(D)

Number  of Reports for Existing Sources	

(F)

Number of Recordkeepers that do not submit reports	

(E)

Total Annual   Responses =

(AxB)+(CxD)+ F



New and no exceedances	

         1                          	

         3	

    36	

           2	

 

         0	

       75



Excess emission	

	

	

    29	

           2	

	

       58



The number of total respondents is 37.  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., number
of new respondents per year multiplied by three years divided by two).  

The number of Total Annual Responses is 133.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table.  The total annual labor costs are $191,523.  Details upon which
this estimate is based appear in Table 2.  Annual Respondent Burden and
Cost, New Source Performance Standards for Pressure Sensitive Tape and
Label Coating Operations (40 CFR part 60, subpart RR).

 

The total annual capital and O&M costs to the regulated entity are
$71,800.  These costs are detailed in section 6(b)(iii), Capital/Startup
vs. Operating and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached in Tables 1 and 2.

6(f)  Reasons for Change in Burden

	The increase in burden from the most recently approved ICR is due to an
adjustment.  The adjustment increase in burden from the most recently
approved ICR is due to a correction made to the frequency of temperature
reports on sources that use incineration to control emissions.  The most
recently approved ICR assumed an annual frequency of 0.5.  However,
temperature reports are required to be submitted semi-annually.  A
semi-annual report indicates two reports per year, not 0.5 per year. 
The total labor costs have also increased since there was an adjustment
made to the burden.  Since this ICR renewal was approved to be processed
under the “renew without change” option, EPA has maintained the same
estimate for the number of sources currently subject to this standard as
indicated in the most recently approved ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 25 (rounded) hours per response.

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-2006-0414. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., 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 Docket is (202)
566-1514.  Also, you can send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include
the EPA Docket ID Number EPA-HQ-OECA-2006-0414 and OMB Control Number
2060-0004 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:  AVERAGE ANNUAL AGENCY BURDEN FOR NSPS FOR PRESSURE

SENSITIVE TAPE AND LABEL COATING OPERATIONS (40 CFR PART 60, SUBPART RR)

	

	                 EPA hrs/	                     Occurrences	           
EPA hr/	               Plants/	                   EPA

	               occurrences	                  plant/year	            
plant/year	              year 	                    hrs/year

Reporting/Recordkeeping Requirement                                     
  (A)                             (B)                       (C=AxB)     
            (D)                       (E=CxD)

________________________________________________________________________
____________________________________________________

Initial Performance Tests

     New Plant 		24	1	24	1	24

Repeat Performance Test  	            				                  	

     New Plant		24	1	4.8	0.2	  4.8

Report Review 

New Plant

Notification of construction		  2	1	2	1	 2

Notification of initial startup      	  	     0.5	1	0.5	1	    0.5

Notification of actual startup	 	     0.5	1	0.5	1	    0.5

Notification of initial test	  	     0.5	1	0.5	1	    0.5		

Review test results		  8	1	8	1	    8.0

Existing Plant 

VOC emission reports 		2	2	4	36	 144           

     Temperature reports [a]		 2	2	4	29	 116

TOTAL ANNUAL HOURS  		300

Travel expenses 

(1 person x 1 plant/year x 3 days/plant x $100 per diem) + ($350 round
trip/plant x 1 plant/year) = $650.00/year

Salary

(1 person x 300 hrs/year x $38.30/hrs ) = $11,490

TOTAL ANNUAL BURDEN = $12,140

________________________________________________________________________
_______________________________________________________

Assumptions:

Number of new plants (per year):  1.

Rate of failed performance tests:  20%.

Time required to participate with performance test (hours per plant): 
24.

Time required to review construction notification (hours):  2. 

Time required to review startup and initial test notifications (hours): 
0.5. 

Time required to review performance test results (hours):  8. 

80% of sources use incineration (36 x .8 = 29):  29.

EPA(s labor rate at a GS-12, Step 1 x 1.6 government overhead expenses: 
$38.30.

Percentage of new plants visited:  100%. 

Round trip airfare to visit plant:  $350. 

Each plant must submit q quarterly report on excess emissions every
other year, in addition to the required semiannual report.

Number of affected facilities is equal to the number of existing
affected facilities plus the number of new or modified sources that
become affected sources in the new three years.



TABLE 2: ANNUAL INDUSTRY BURDEN FOR NSPS FOR PRESSURE SENSITIVE TAPE AND
LABEL COATING OPERATIONS (40 CFR PART 60, SUBPART RR)

		Occurrences/	Hours/	

	Hours per	respondent/	Respondent/	Respondents	Hours	Cost/

	Occurrence	year	year	per year	per year	year a

	(A)	(B)	(C = A x B)	(D)	(E = C x D)	      (F=E x $57.12)

________________________________________________________________________
___________________________________________________ 

1.  APPLICATIONS		Not Applicable	

2.  SURVEY AND STUDIES		Not Applicable	

3.	REPORTING REQUIREMENTS

A.  Read Instructions	 1	1	    1	1	1	$57.12	

B.	Required Activities	

Initial performance test  	60	 1 	60	1	60	$3,427.20	   

Repeat performance test [c]	60	  1	60	0.2	12	$685.44

C.  Create Information		Included in 3B

D.  Gather Existing Information		Included in 3E

E.  Write Report	

     Notification of construction/	2	1	2	1	2	         $114.24

reconstruction	 						 	

Notification of 	 2	1	2	1	        2	$114.24

actual startup     	

Notification of initial	2	1	2	1	2	$114.24

performance test	

Report of performance test 		Included in 3B

Excess Emission Reports	9	

VOC Emission Reports [e]	5	     2[d]	10	36	360	$20,563.20

Temperature Reports [f]	4	    2 	8	29	232	$13,251.84		

SUBTOTAL						671	$38,327.52

4.	RECORDKEEPING REQUIREMENTS

A.	Read Instructions		Included in 3A

Plan Activities		Included in 4C

C.	Implement Activities		Included in 3B

Monthly performance test	1	12	12	36	432	$24,675.84

Develop Record System 	N/A	N/A	N/A	N/A	N/A	N/A

Time to Enter Information  

Records of operating 	0.25	250	62.5	36	2250	$128,520.00

parameters [g]

Train Personnel	N/A	N/A	N/A	N/A	N/A	N/A

Audits	N/A	N/A	N/A	N/A	N/A	N/A

TOTAL ANNUAL BURDEN					3,353	$191,523	

________________________________________________________________________
__________________________________

Assumptions:

a.  Number of new affected facilities per year:  1.	

b.  Technical labor rate (Bureau of Labor Statistics):  $57.12.

c.  Rate of failed performance tests:  20%.			   

d.  Each source submits one excess emission report every year, in
addition to the required semiannual report.

Average number of affected facilities is equal to the number of affected
facilities in existence plus the average of new affected facilities to
be 

constructed or modified over the next 3 years.

80% of sources use incineration to control emissions (36x.8 = 29):  29.

Operating 250 days per year as specified in NSPS review document.

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