SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Magnetic Tape Manufacturing Operations (40 CFR part 63,
subpart EE) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Magnetic Tape Manufacturing Operations (40 CFR part 63,
subpart EE), OMB Control Number 2060-0326, EPA ICR Number 1678.06.

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 63, subpart EE were
proposed on March 11, 1994 and promulgated on December 15, 1994.  These
regulations apply to the following magnetic tape manufacturing
operations located at major sources of hazardous air pollutants (HAP):
solvent storage tank, mix preparation equipment, coating operation,
waste handling device, and condenser vent in solvent recovery commencing
construction or reconstruction after March 11, 1994.  Exceptions include
research or laboratory facilities, and coating operations that produce a
quantity of magnetic tape that is one percent or less of total
production.  This information is being collected to assure compliance
with 40 CFR part 63, subpart EE.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports.  Owners, or operators also are
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
NESHAP.

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
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.

Approximately six sources currently are subject to the standard, and it
is estimated that no (zero) additional sources per year will become
subject to the regulation in the next three years.  It is assumed that
three coating lines are to be constructed at existing sources over the
next three years, creating one new source per year.

	The “Affected Public” are private sector businesses, or other
for-profits that manufacture magnetic tape.  The burden to the
“Affected Public” may be found in Table 1: Annual Respondent Burden
and Cost.  The burden to the “Federal Government” is attributed
entirely to work performed by Federal employees, or government
contractors, and may be found in Table 2: Annual Agency Burden and Cost.

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, 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, HAP emissions from magnetic tape
manufacturing operations cause, or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, NESHAP for this source category were promulgated at 40 CFR
part 63, subpart EE.

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

2(b)  Practical Utility/Users of the Data

 

The control of emissions of HAP from magnetic tape manufacturing
operations requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of methyl ethyl ketone, toluene, methyl isobutyl ketone,
xylene and ethyl benzene, and magnetic particles containing chromium
dioxide and cobalt compounds from magnetic tape manufacturing operations
are the result of operation of the facilities.  The subject standards
are achieved by the capture of methyl ethyl ketone, toluene, methyl
isobutyl ketone, xylene and ethyl benzene, and magnetic particle
emissions using carbon absorbers, incinerators, or condensers, or
reduction using reduced HAP coating mix.  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 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 standard, and serve as a record
of the operating conditions under which compliance was achieved.  Each
compliance emission monitor (CEM) shall record the inlet and outlet
concentrations when determining percent efficiency if this is applied to
the control device.  Thermal incinerators and catalytic incinerators
require thermocouples to measure the minimum combustion temperature and
temperature across the catalyst bed as established as site-specific
operating parameters.  Each thermocouple calibration must be verified,
or replaced every three months.  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
NESHAP continue to operate the control equipment in 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 also is 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 are required under 40 CFR part
63, subpart EE.

3(a)  Nonduplication

 If the subject standards have not been delegated, the information is
sent 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 (71 FR 58853) on October 5, 2006. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

EPA’s Office of Air Quality Planning and Standards (OAQPS) conducted a
review and discussions with industry during the Magnetic Tape
Manufacturing Residual Risk Assessment.  Results from that activity were
used in preparation of this ICR.

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 violates any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

 	These standards require affected facilities 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 and NAICS Codes

The respondents of the recordkeeping and reporting requirements are
owners, or operators of magnetic tape manufacturing operations. 

Standard	SIC Codes	NAICS Codes

40 CFR part 63, subpart EE	3695	334613 (Magnetic and Optical Recording
Media)

40 CFR part 63, subpart EE	2675	322226 (Die-cut Paper and Paperboard and
Cardboard)



4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 63, subpart EE.

A source must make the following reports:

Notification Reports

Notification of intent to construct or reconstruct	63.5(b), 63.9(b),
63.707(a)

Notification and report of construction date	63.9(b)(4), 63.707(a)

Notification of anticipated startup	63.9(b)(4), 63.707(a)

Actual startup notification	63.9(b)(4), 63.707(a)

Notification of applicability of the standard	63.9(b)(2)-(3), 63.707(a),
(b), (c)

Develop startup, shutdown, malfunction plan, submit reports	63.6(e)(3),
63.10(d)(5), 63.707(a), 63.707(i)

Develop quality control plan for CMS	63.8(d), 63.707(a)

Notification and report of performance tests and results	63.7(b),
63.8(e), 63.9(e), (g), 63.10(d)(2), (e)(2), 63.707(a)

Report of when exceeds HAP usage cutoff or when area source becomes
major	63.9(b), 63.9(h), 63.707(j)

Notification and report of compliance status	63.9(h)(2)-(3), 63.707(a)

Notification and report for waiver application	63.7(h), 63.707(a)

Semiannual reports of no excess emissions	63.10(e)(3), 63.707(a), (i)

Quarterly reports of monitoring exceedances and excess emissions
63.10(e)(3), 63.707(a), (i)



A source must keep the following records:

Recordkeeping

Five-year retention of records	63.10(b)(1), 63.706(a), (h)

Records of monitored values, maintenance, startup, shutdown, malfunction
63.10(b)(2), 63.10(c), 63.6(e), 63.706(a)

Records of the freeboard ratio	63.10(b)(2), 63.706(b)

Records of CMS maintenance, calibration	63.8(c), 63.8(d)(3),
63.10(b)(2), 63.10(c), 63.706(a)

Records of performance tests	63.10(b)(2), 63.705, 63.706(a)

Records of material balance calculation	63.10(b)(2), 63.706(a), (d)

Records of HAP usage	63.10(b)(2), 63.706(e)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., inlet and outlet
concentrations when determining percent efficiency.  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 still are not widely used by the regulatory
agencies.  It is estimated that approximately 10 percent of the
respondents use electronic reporting.

ii.  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CEM for volatile organic
compound (VOC) inlet/outlet concentration to measure efficiency of
control device, and thermocouples to measure minimum combustion
temperature and temperature across catalyst bed for site-specific
operating parameters.  Maintain records of coating mix HAP concentration
and measure freeboard ratio.

Perform initial performance test, EPA Method 24 for VOC content in
coatings, EPA Method 18 or EPA Method 25A to determine HAP or VOC
concentrations of air exhaust streams, EPA Method 22 to determine
visible emissions, 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.



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,
excess emissions reports, startup, shutdown, malfunction plan, and
quality control plan for CMS 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. 
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, 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 five years.

5(c)  Small Entity Flexibility

There are no small businesses affected by this regulation at present,
and no small businesses are expected to become subject to the regulation
in the next three years. 

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost.

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 at 3,395
person-hours.  These hours are based on an Agency review and discussions
with the industry during initiation of the Magnetic Tape Manufacturing
Residual Risk Assessment, Agency studies and background documents from
the development of the regulation, Agency knowledge and experience with
the NESHAP program, and the previously approved ICR.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses a Technical Labor Rate of $64.13 per hour.  This rate is
from the United States Department of Labor, Bureau of Labor Statistics,
June 2003, “Table 10. Private industry, by occupational and industry
group.”  The rates are from column 1, “Total compensation.”  The
rate has been increased by 110 percent to account for the benefit
packages available to those employed by private industry.

(ii)  Estimating Capital and Operations and Maintenance Costs

This section covers the costs associated with all types of continuous
monitoring equipment (e.g., CEMS and continuous parameter monitors). 
The type of industry costs associated with the information collection
activity in the subject standards are both labor costs which are
addressed elsewhere in this ICR, and the costs associated with
continuous monitoring.  The capital/startup costs are one-time costs
when a facility becomes subject to the regulation.  The annual operation
and maintenance costs are the ongoing costs to maintain the monitor(s)
and other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operating and Maintenance (O&M) Costs

Capital/Startup vs. Operating 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 Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Total enclosure	$11,000	1	$11,000	0	0	0

VOC CEM	0	0	0	$8,000	3	$24,000

Thermo-couples	0	0	0	$2,000	6	$12,000

 

The total Capital/Start-up costs for this ICR are $11,000.  This is the
total of column D in the above table.  

 

The total Operating and Maintenance (O&M) Costs for this ICR are
$36,000.  This is the total of column G.

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 $47,000.  The continuous monitoring costs
that are included in this section consist only of those capital/start-up
and O&M costs that a source incurs as a result of the standard.  Some
continuous monitoring costs may not be included in this section.  For
instance, if a particular industry typically utilizes a control device
that must have a continuous monitor (e.g., temperature, pressure drop,
etc.) to function properly, and the recordation of additional
measurements beyond the minimum are required by the standard, then there
is no capital/startup, or O&M cost, but there is a labor cost to record
the additional readings.  Such a cost would not appear in this section,
but in the industry burden Section 6(d) below.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
estimated to be $1,817 [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.  These rates are 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 and Cost, below.

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

Based on our research for this ICR, there are approximately six existing
sources currently subject to the standard.  It is estimated that no
(zero) additional sources per year will become subject to the regulation
in the next three years.

Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

Year	(A)

Number of New Respondents 	(B)

Number of Existing Respondents	(C)

Number of 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	6	0	1	6

2	1	6	0	1	6

3	1	6	0	1	6

Average	1	6	0	1	6



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 six.  

The total number of annual responses per year is calculated using the
following table:

Total Annual Responses

(A)

Number of New Respondents	(B)

Number of Reports for New Sources	(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 

E=(AxB)+(CxD)+F

1	4	6	2.2	0	17.2



The number of Total Annual Responses is 17 (rounded).  

 	The total annual labor costs are $ 217,722.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost,
NESHAP for Magnetic Tape Manufacturing Operations. 

 

Note that the total annual capital and O&M costs to the regulated entity
are $47,000.  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 appear below.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 200
(rounded) hours per response.

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR compared to
the previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for the industry is very low, negative or non-existent, so there is
no significant change in the overall burden.

Since there are no changes in the regulatory requirements and there is
no significant industry growth, the labor hours and cost figures in the
previous ICR are used in this ICR and there is no change in burden to
industry.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 200 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-2006-0036.  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
docket center is (202) 566-1927.  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
Officer for EPA.  Please include the EPA Docket ID Number
EPA-OECA-2006-0036 and OMB Control Number 2060-0326 in any
correspondence. 

Part B of the Supporting Statement

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

Burden Item  (a)	(A)

Person-Hours Per Occurrence	(B)

Number of Occurrences Per Year	(C)

Person-Hours Per Respondent Per Year

(C=AxB)	(D)

Respondents Per Year	(E)

Person-Hours Per Year (E=CxD)	(F)

Cost  ($ b)

1.  Applications	N/A





	2.  Surveys and Studies	N/A





	3.  Reporting Requirements







     A.  Read instructions  (c) 	1	1	1	0	0	0

     B.  Required activities







Tests







      Initial performance test-APCD   (d) 	445	1	445	0	0	0

      Conduct performance test method audits  (d)	27	1	27	0	0	0

      Repeat initial performance test-APCD  (e)	445	1	445	0	0	0

      Repeat performance test method audits  (e)	27	1	27	0	0	0

      Initial performance test--total enclosure  (f)	215	1	215	1	215
13,788

      Repeat initial performance test--total enclosure  (e)	215	1	215
0.2	43	2,758

      Performance test for VOC CEMs  (g)	175	1	175	0	0	0

      Quarterly VOC CEM audits  (g)	10	4	40	3	120	7,696

     C.  Create information	Included in 3B and 4E





	     D.  Gather existing information	Included in 3B and 4E





	     E.  Write report







      Notification of intent to construct/reconstruct   (f)	6	1	6	1	6
385

      Notification of construction date  (f)	2	1	2	1	2	128

      Actual startup notification  (f)	2	1	2	1	2	128

     Notification of applicability of the standard existing sources (c)
2	1	2	0	0	0

      Notification of applicability of the standard new/reconstructed   
   sources  (f)	2	1	2	1	2	128

      Notification of initial performance test  (h)	2	1	2	0	0	0

      Report of initial test	Included in 3B





	      Notification of compliance status  (i)	4	1	4	0	0	0

      Submit startup, shutdown, malfunction plan  (i)	20	1	20	0	0	0

      Develop and implement quality control plan for continuous         
 monitoring systems (CMS)   (i)	50	1	50	0	0	0

      Report when exceed HAP usage cutoff (or report area source        
becoming major sources   (j)	2	1	2	0	0	0

      Waiver application   (c)	6	1	6	0	0	0

      Report of monitoring exceedances and periods of                   
      noncompliance, including inconsistencies with startup,            
     shutdown, malfunction plan   (k)	16	4	64	0.6	38	2,437

     Report of no excess emissions, including startup, shutdown,        
 malfunction reports   (k)	4	2	8	5.4	43	2,758

4. Recordkeeping Requirements







   A. Read instructions	Included in 3A





	   B. Plan activities	N/A





	   C. Implement activities	Included in 4D





	   D. Develop record system   (i, l)	40	1	40	0	0	0

   E. Time to enter information







      Facilities above cutoff, including records associated with        
      startup, shutdown, malfunction, maintenance of APCD, and         
measurement of freeboard ratio   (m)	0.5	350	175	6	1,050	67,337

      -maintain, adjust, and calibrate CMS and maintain records of      
   this and any CMS malfunction that occurs  (n) 	6	52	312	6	1,872
120,051

      Facilities below cutoff  (o)	2	1	2	1	2	128

    F. Time to train personnel	N/A





	    G. Time for audits	N/A





	TOTAL BURDEN AND COST NATIONWIDE:



	3,395	217,722

    Average cost per facility   (p)





36,287



		Footnotes:

		a.  Numbers, other than respondents per year are rounded to avoid
fractions, for both Table 1 and Table 2.

		b.  Person-hours are charged at $30.54/hr. plus 110 percent overhead
costs which equals $64.13/hr.

		c.  This cost was incurred during the first year.

	d.  Hours associated with the initial performance test include
preparation of a site-specific test plan.  Hours for performance test
method audits are estimated as 6 percent of the performance test hours. 
No facility is expected to conduct testing for the air pollution control
device (APCD) and CEM(s.

		e.  Assumes 20 percent of sources will have to be retested (equals
zero).

	f.  It is projected that, on the average, new  coating lines will be
added at the rate of one per year.  These coating lines will be located
at existing facilities which will already be meeting the reporting and
recordkeeping requirements of the standard.  Also, additional emission
points are likely to be tied into the existing APCD.  Therefore, new
compliance tests for the APCD and continuous monitors will not be
necessary.  However, a new total enclosure would be built and must be
tested.

		g.  All facilities using VOC continuous emission monitors (CEM(s) will
have to perform quarterly audits of monitors, estimated at 3 facilities.

		h.  No facilities are expected to conduct an initial performance test.

	i.   No facilities are expected to be required to report on status, or
develop a startup, shutdown, malfunction plan, quality control plan for
CMS, or record system.

		j.  No existing area sources are expected to exceed the HAP usage
cutoff or become a major source.

	k. These reports will include data based on CMS performance and/or
material balance results.  It is assumed that 90 percent of the
facilities in this source category will have no excess emission:
reporting will therefore be semiannual.  Ten percent of the facilities
in this source category will have excess emissions; these facilities
will need to report quarterly each year.  All 6 facilities subject to
the control requirements will be submitting reports.

	l.  Activities that must be implemented at all facilities include
maintaining a 75 percent freeboard ration in wash sinks, the use of a
closed system for flushing fixed lines, and the use of a closed system
for particulate transfer.  A record system will need to be developed to
maintain records associated with the freeboard ratio, performance tests,
notifications, and CMS QA/QC program.

		m. All facilities subject to the control requirements of the standard
will be keeping records.

	n.  All but one of the 6 facilities subject to the rule will operate a
continuous monitoring system (CMS), as defined in Section 63.2 of the
proposed General Provisions.  The one facility that will not operate a
CMS has only one control device and will perform a materials balance to
show compliance.

	o.  Facilities that fall below the HAP usage cutoff will have to submit
an annual report certifying this usage.  One facility is expected to be
subject to this requirement.

	p.  The average facility burden is calculated by dividing the total
facility burden by the number of facilities (6) subject to the control
provisions of the standard. 

Table 2: Annual Agency Burden and Cost

	(A)

EPA Hours Per Occurrence	(B)

Occurrences Per Year	(C)

EPA Person-Hours Per Plant Per Year

(C=AxB)	(D)

Plants Per Year	(E)

EPA Person-Hours Per Year

(E=CxD)	(F)

Cost  ($ a)

Initial performance test  (b)	60	0	0	0	0	0

Repeat initial performance test  (c)







   1. Retesting preparation	16	0	0	0	0	0

   2. Retesting	60	0	0	0	0	0

Report review







   Notification of intent to construct/reconstruct  (d)	2	1	2	1	2	79

   Notification of construction date   (d)	2	1	2	1	2	79

   Notification of actual startup   (d)	2	1	2	1	2	79

   Notification of applicability--existing sources  (e)	2	0	0	0	0	0

   Notification of applicability--new/reconstruction sources  (d)	2	1	2
1	2	79

   Notification of initial performance test  (f)	2	1	2	1	2	79

   Report of initial test  (f)	8	1	8	1	8	316

   Notification of compliance status  (g)	4	0	0	0	0	0

   Startup, shutdown, malfunction plan  (h)	4	0	0	0	0	0

   Quality control plan for CMS  (h)	4	0	0	0	0	0

   Report of monitoring exceedances and periods of noncompliance  (i) 	8
1	8	0.6	5	198

   Report of no excess emissions  (i)	2	2	4	5.4	22	869

   Report for facilities below cutoff  (j)	1	1	1	1	1	39

  Report of area source becoming a major  source or exceeding HAP usage
cutoff (k)	8	0	0	0	0	0

   Waiver application  (l)	8	0	0	0	0	0

TOTAL BURDEN AND COST (SALARY)



	46	1,817



		Footnotes:

a.  Costs are 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.

		b.  Assumes 10 percent of the number of tests conducted are attended
by EPA.

		c.  Assumes that 20 percent fail the initial performance tests and
retest.

		d.  Assumes that one new coating line will be added per year.  This
line will be at an existing facility.

		e.  The notification of the applicability of the standard for existing
sources has already occurred.

		f.   Based on one facility conducting test, including retest.

		g.  Assumes no facilities require notification.

		h.  Assumes that EPA will review no startup, shutdown, malfunction
plans and CMS quality control plans.

i.   The number of noncompliance reports and reports of no excess
emissions correspond to the respondents per year reported in Table 1
(column D) multiplied by the number of occurrences per year reported in
Table 1 (column B).

		

		j.  One existing facility is expected to be below the solvent usage
cutoff.

		k. No existing area sources are expected to exceed the HAP usage
cutoff or become area sources.

		l.  Assumes all waiver applications have been submitted.

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Table 1: Annual Respondent Burdent and Cost

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