SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Polymeric Coating of Supporting Substrates Facilities

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR
part 60, subpart VVV) (Renewal)

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations at 40
CFR part 60, subpart VVV were proposed on April 30, 1987 and promulgated
on September 11, 1989.  These regulations apply to each coating
operation and any on-site coating mix preparation equipment used to
prepare coatings for the polymeric coating of supporting substrates at
existing facilities and new facilities.  New facilities include those
that commenced construction, modification or reconstruction after the
date of proposal.  This information is being collected to assure
compliance with 40 CFR part 60 subpart VVV.

In general, all New Source Performance Standards (NSPS) 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 53 respondents are currently subject to the regulation,
and it is estimated that one additional respondent will become subject
to the regulation in each of the next three years.

OMB approved the currently active ICR without any “Terms of
Clearance.”

The term, “Affected Public”, applies to private sector businesses or
other for-profits that perform polymeric coating of supporting
substrates.  The burden to the “Affected Public” may be found in
Table 1: Annual Respondent Burden and Cost, NSPS for Polymeric Coating
of Supporting Substrates Facilities (attached).  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, NSPS for Polymeric Coating of
Supporting Substrates Facilities (attached).

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/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 compounds (VOC)
emissions from polymeric coating of supporting substrates facilities
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 VVV.

2(b)  Practical Utility/Users of the Data

The control of emissions of VOCs from polymeric coating of supporting
substrates facilities requires not only the installation of properly
designed equipment, but also the operation and maintenance of that
equipment.  Emissions of VOCs from polymeric coating of supporting
substrates facilities are generated by each coating operation and the
associated onsite coating mix preparation equipment used to prepare
coatings for the polymeric coating of supporting substrates.  These
standards rely on: the capture of VOC emissions by a partial or total
enclosure around the coating operation (“alternative standard”),
and/or by covers on each piece of affected mix preparation equipment;
the reduction of VOC emissions to the atmosphere from the coating
operation to a control device (“emission reduction standard”),
and/or from the affected covered equipment to a control device; and the
recovery of VOC emissions at one coating operation if the liquid
material balance is used to demonstrate compliance.

The required notifications are used to inform the Agency or delegated
authority when a source becomes subject to the standard.

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act. The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility's initial capability to comply with the emission standard(s). 
Continuous emission monitors are used to ensure compliance with the
standards at all times.

The notifications required in the standards 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 standards are being met. 
Operating conditions that may be noted include: a measure of the gaseous
volumetric flow rates; VOC emissions from the coating operation; capture
efficiency of the control device; amount of coating applied at the
coating applicator after all ingredients have been added to the coating;
VOC content of all coatings; a measure of the cumulative amount of VOC
recovered by the control device over a nominal 

1-month period; the average inward face velocity across all natural
draft openings of a total enclosure; and other parameters that
demonstrate a total enclosure has been properly installed.  The
performance test may also be observed.

The required quarterly/semiannual reports are used to determine periods
of excess emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested is required under 40 CFR part
60, subpart VVV.

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 (72 FR 10735) on March 9, 2007. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

In order to obtain information on the burden for this ICR, EPA consulted
Jeff Rose of Cytec Engineered Materials, 501 West 3rd Street, Winona,
Minnesota 55987 (507-312-8824).  EPA also consulted its AIRS Facility
Subsystem (AFS) to identify sources subject to the standard.

	3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the required 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 in 5 CFR 1320.5.

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 (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.

The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are
polymeric coating of supporting substrates facilities including:

Regulation: 40 CFR, Part 60, Subpart VVV

SIC Codes	NAICS Codes

2241	313221

2295	31332

2296	314992

2394	314912

3052	32622

3053	339991

3069	31332

315299

315999

339113

33992

339932

326192

326299



4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 60, subpart VVV.

A source must make the following reports:

Notification Reports

Requirement	Regulation reference

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) 

Projected and actual VOC use, if VOC use is less than 95.0 Mg/yr or less
than 130 Mg/yr.	60.747

Excess emissions or periods of noncompliance quarterly.	60.747(d)(1)-(6)
and 60.747(e)(2)

No excess emissions/no deviations from operating parameters
semiannually.	60.747(d)(7) and 60.747(e)(1)



A source must maintain the following records:

Recordkeeping

Record startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	60.7(b) 

Records for performance test measurements.	60.8(a)

Record projected VOC use and actual 12-month VOC use, operating
parameters (e.g., concentration level of organic compounds, periods of
actual coating operations, system efficiency, average combustion
temperature, gas temperature before and after the catalytic bed) of the
control device (e.g., carbon absorption system, thermal incinerator, and
catalytic incinerator) and other parameters depending on the compliance
method being used.	60.747

Records for sources with continuous monitoring systems.	60.7(f)

Records are required to be retained for two years.  The first two years
of records must be kept onsite.	60.747(h)



Electronic Reporting

At the present, respondents are using monitoring equipment that
automatically records parameter data, e.g., temperature, pressure drop,
leaks and spills of mercury, etc.  Although personnel at the affected
facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate required monitoring devices to
monitor the concentration level of organic compounds, the combustion
temperature, gas temperature or other value of the chosen parameter,
depending on the control device used.

Monitor projected and actual VOC use.

Perform performance tests and use the appropriate reference methods:
Reference Method 24 test to determine VOC content in coating or
formulation data (if approved by Administrator); Reference Method 25 (or
alternative methods 18, or 25A) to determine incinerator VOC gas streams
concentration, the efficiency of a fixed-bed carbon adsorption system;
Method 1 or 1A for sample and velocity traverses; Method 2, 2A, 2C or 2D
for velocity and volumetric rates; Method 3 for gas analysis; and Method
4 for stack gas moisture measurements.

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,
and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (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, 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 quarterly reports of noncompliance and semiannual reports
of compliance 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 more than 125,000 industrial and
government-owned facilities.  EPA uses AFS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, and
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

There is a distribution of business sizes affected by this regulation. 
However, the impact on small entities (i.e., small businesses) was taken
into consideration during the development of the regulation.  Any
affected facility for which the amount of VOC used is less than 95 Mg
per 12-month period is subject only to the requirements of 40 CFR,
Sections 60.744(b), 60.747(b) and 60.747(c) which require reports and
records of VOC use.  This reduces regulatory requirements for smaller
facilities.  The Agency considers these requirements the minimum needed
to ensure compliance and, therefore, cannot reduce them further for
small entities.  To the extent that larger businesses can use economies
of scale to reduce their burden, the overall burden will be reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1. Annual Respondent Burden and Cost,
NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR
part 60, subpart VVV).

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
each of the subparts 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 (40 CFR part 60, section
60.747).

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 12,623
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the standards
or test methods, 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 the following labor rates: 

Managerial	$95.32   ($45.39 + 110%)

Technical	$64.60   ($30.76 + 110%)

Clerical	$40.09   ($19.09 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2003, “Table 2. Private industry, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

(ii)  Estimating Capital and Operation and Maintenance Costs

 

The type of industry costs associated with the information collection
activities 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. Operation and Maintenance (O&M) Costs

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M

(E X F)

VOC monitor	40,000	1	40,000	8,500	53	450,500

Temperature monitor	8,500	1	8,500	2,000	53	106,000



The total capital/startup costs for this ICR are $48,500.  This is the
total of column D in the above table.

The total operating and maintenance (O&M) costs for this ICR are
$556,500.  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 are estimated to be $605,000.  The continuous monitoring costs
that are included in this section consist only of those capital/startup
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 $30,478, see Table 2. Annual Agency Burden and Cost,
NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR
part 60, subpart VVV).

This cost is based on the average hourly labor rate as follows:

Managerial	$54.66   (GS-13, Step 5, $34.16 x 1.6)

Technical	$40.56   (GS-12, Step 1, $25.35 x 1.6)

Clerical	$21.95   (GS-6,   Step 3, $13.72 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2004
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2. Annual Agency Burden and
Cost, NSPS for Polymeric Coating of Supporting Substrates Facilities (40
CFR part 60, subpart VVV).

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

Based on our research for this ICR, approximately 53 existing sources
are currently subject to the standard.  It is estimated that an
additional one source will become subject to the standard 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

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents 1	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	5	51	0	4	52

2	5	52	0	4	53

3	5	53	0	4	54

Average	5	52	0	4	53

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

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 53.

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

Total Annual Responses

(A)Information Collection Activity	(B)

Number of Respondents 	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Notification of construction/ reconstruction	5	1	0	5

Notification of actual startup	5	1	0	5

Notification of initial performance test	5	1	0	5

Notification of VOC use at the end of the initial year	1	1	0	1

Report of performance test	5	1	0	5

Report of performance retest	1	1	0	1

Report of monitoring exceedances and periods of noncompliance	11	4	0	44

Report of no excess emissions	42	2	0	84

Report when 1st projected VOC use exceeds the applicable cutoff	2	1	0	2

Notification of changes	1	1	0	1



	Total	153



The number of Total Annual Responses is 153.  Note that four respondents
have been double counted in the above table because they have both
existing affected facilities and new affected facilities.

The total annual labor costs are $805,367.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost,
NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR
part 60, subpart VVV), attached.

The total annual capital/startup and O&M costs to the regulated entities
are $605,000.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The average annual Agency burden and cost over next three years is
estimated to be 771 labor hours at a cost of $30,478.  See Table 2.
Annual Agency Burden and Cost, NSPS for Polymeric Coating of Supporting
Substrates Facilities (40 CFR part 60, subpart VVV), attached.

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

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

The total annual labor costs are $805,367.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost,
NSPS for Polymeric Coating of Supporting Substrates Facilities (40 CFR
part 60, subpart VVV), attached.  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 83 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $605,000.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 771 labor hours at a cost of $30,478.  See Table 2.
Annual Agency Burden and Cost, NSPS for Polymeric Coating of Supporting
Substrates Facilities (40 CFR part 60, subpart VVV), attached.

6(f)  Reasons for Change in Burden

There are no changes in the labor hours or costs in this ICR compared to
the previous ICR (see rounding-off adjustment below).  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.

The labor hour and cost burden in this ICR are the same as in the
previous ICR, however, there is an adjustment.  The Annual Cost Burden
as shown in Part II, Block 12 of the ICRAS (Information Collection
Request, Review and Approval System) form is reduced (-$1,000) to
account for rounding up/down in the previous ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 83 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-2007-0033.  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) 566-1752.  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-HQ-OECA-2007-0033 and OMB Control Number 2060-0181 in any
correspondence. 

Part B of the Supporting Statement

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

TABLE 1. Annual Respondent Burden and Cost:  NSPS for Polymeric Coating
of Supporting Substrates Facilities (40 CFR part 60, subpart VVV)

Burden item	

(A)

Person-hours per occurrence	

(B)

Number of occurrences per year	

(C)

Technical person-hours per respondent per year (C=A*B)	

(D)b

Respondents per year	

(E)

Technical person-hours per year (E=C*D)	

(F)

Management person-hours per year (F=E*0.05)	

(G)

Clerical person-hours per year (G=E*0.1)	

(H)

Respondent person-hours per year

(H=E+F+G)	

(I)

Cost, $a



1.	Applications	N/A	

	

	

	

	

	

	

	





2.	Surveys and Studies	N/A	

	

	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	

	

	





A.	Read instructions	1	1	1	5b+c+d	5	0.3	0.5	6	$367



B.	Required activities	

	

	

	

	

	

	

	

	





● Initial performance test	280	1	280	5	1,400	70	140	1,610	$102,725



● Repeat of performance test	280	1	280	1e	280	14	28	322	$20,545



● Monthly compliance test	90	12	1080	1f	1,080	54	108	1,242	$79,245



C.	Create information	included in 3B	

	

	

	

	

	

	

	





D. 	Gather existing information	included in 3E	

	

	

	

	

	

	

	





E.	Write report	

	

	

	

	

	

	

	

	





       New Affected Facilities	

	

	

	

	

	

	

	

	





 ● Notification of construction/

  reconstruction	

2	

1	

2	

5	

10	

0.5	

1	

12	

$734



● Notification of actual startup	2	1	2	5	10	0.5	1	12	$734



● Notification of initial performance test	2	1	2	5	10	0.5	1	12	$734



      ● Notification of VOC use at the end of the initial year	

2	

1	

2	

1g	

2	

0.1	

0.2	

2	

$147



● Report of performance test	included in 3B	

	

	

	

	

	

	

	





       New and Existing Affected Facilities	

	

	

	

	

	

	

	

	





     ● Report of monitoring exceedances and periods of  non-compliance


16	

4	

64	

11h	

704	

35	

70	

810	

$51,656



     ● Report of no excess emissions	8	2	16	42i	672	34	67	773	$49,308



     ● Report when 1st projected VOC use exceeds the applicable cutoff


2	

1	

2	

2	

4	

0.2	

0.4	

5	

$294



    ● Report when 1st actual 12-month VOC use                   
exceeds the applicable cutoff	

2	

1	

2	

0j	

0	

0	

0	

0	

$0



      ● Notification of changes	

4	

1	

4	

5d	

20	

1	

2	

23	

$1,468



4.	Recordkeeping Requirements	

	

	

	

	

	

	

	

	





      New and Existing Affected Facilities	

	

	

	

	

	

	

	

	





A.	Read instructions	

included in 3A	

	

	

	

	

	

	

	





B.	Plan activities	

included in 3B	

	

	

	

	

	

	

	





C.	Implement activities	

included in 3B	

	

	

	

	

	

	

	





D.	Develop record system	

N/A	

	

	

	

	

	

	

	





E.	Time to enter information	

	

	

	

	

	

	

	

	





● Records of startups, shutdowns, malfunctions, etc.	

1.5	

25k	

37.5	

53	

1,988	

99	

199	

2,286	

$145,833



● Records of operating parameters	0.25	350l	87.5	53	4,638	232	464
5,333	$340,277



● Records of semiannual estimate of projected VOC use	

1	

2m	

2	

11	

22	

1	

2	

25	

$1,614



      ● Records of 12 month actual VOC use	1	12m	12	11	132	7	13	152
$9,686



F.	Train personnel	

N/A	

	

	

	

	

	

	

	





 	G.    Audits	

N/A	

	

	

	

	

	

	

	





ONE-TIME BURDEN AND COST (SALARY) NATIONWIDEa	

	

	

	

	

10,976	

549	

1,098	

12,623	

$805,367



Footnotes

a	Costs assume a rate of $64.60/hour for technical labor, $95.32/hour
for management labor, and $40.09/hour for clerical labor.

b	There are a total of 53 existing plants subject to this NSPS.  Assume
that each existing plant has one solvent-borne coating operation subject
to this NSPS.  Assume that a total of 4 new coating lines per year will
be installed at existing plants.

c	Assume one additional solvent-borne coating operation with VOC usage
greater than 95Mg/yr per year will be installed at a new plant each year
and will become subject to the standard in the next three years.  

d	Assume that changes constituting modification or reconstruction making
an existing coating operation and/or a coating mix preparation equipment
(e.g., changes to an existing coating mix preparation equipment such as
the replacement of a coating applicator or the oven and installing a new
part) will not occur frequently.  Therefore, we assume that each year 4
existing plus 1 new polymeric coating plants will undertake a change
that constitutes modification or reconstruction.

e	Assume 20 percent of initial performance tests must be repeated due to
failure (5 x 20% = 1).

f		If an affected facility is complying with the liquid-liquid material
balance compliance method, monthly compliance determination are required
to determine VOC used and recovered (by Method 24), and 	percent
emission reduction.  Assume that 3 lines over the three year period (one
line per year) will demonstrate compliance with a liquid material
balance method.  Therefore, will be required to conduct 	monthly
compliance tests.  This method can only be used when a VOC recovery
device controls only those emissions from one affected coated operation.

g	An affected facility claiming to use less than 95Mg per year or less
than 130 Mg per year of VOC in the first year of operation shall submit
actual VOC records at the end of the initial year.  Assume  there is one
new water-borne line per year (which uses less than 95 Mg of VOC per
year) being installed at existing plants over the 3 year period.  This
existing plant would be required to submit a notification of VOC use at
the end of the initial year of operation of its new coating line.  Also
we assume that the new solvent-borne lines being installed use at least
130 Mg of VOC per year and are not required to notified actual VOC use
at the end of the initial year.

h	Assume that 20 percent of the affected facilities (either complying
with the emission reduction standard, the alternative standard and/or
coating mix preparation equipment standard) report monitoring
exceedances or periods of noncompliance quarterly. [53 x 20% = 11
(rounded)].                

i		Assumes 80 percent of solvent-borne lines report no excess emissions
semiannually. [53 x 80% = 42 (rounded)]. 

j		No lines with projected VOC consumption of less than 95 Mg/yr or less
than 130 Mg of VOC are expected to exceed the cutoff value in the
future.

k	Assume one occurrence of malfunction/shutdown per 2 weeks (50 weeks
per year).

l	Assume operating parameters recorded 350 days per year.  	m	Assume
that 20 percent of the existing coating lines or “affected
facilities” [53 x 20% = 11 (rounded)] claiming use of less than 95 Mg
of VOC per year or less than 130 Mg of VOC per year, as well as the new
water-borne line being installed per year are required to record
semiannual estimates of the projected amount of VOC to be use for the
manufacture of polymeric coated substrates at the affected coating
operation that year and of actual 12-month VOC use. TABLE 2.  Annual
Agency Burden and Cost:  NSPS for Polymeric Coating of Supporting
Substrates Facilities (40 CFR part 60, 

subpart VVV).

Activity	

(A)

Hours per occurrence	

(B)

Hours per line per year	

(C)

Respon-

dents

per year	

(D)

Technical person-hours per year (D=B*C)	

(E)

Management person-hours per year (E=D*0.05)	

(F)

Clerical person-hours per year (F=D*0.1)	

(G)

Total person-hours per year

(G=D+E+F)	

(H)

Cost,

$a



New Affected Facilities	

	

	

	

	

	

	

	





● Attend initial performance testb+c	12	12	5d	60	3	6	69	$2,729



● Attend repeat performance teste	12	12	1f	12	0.6	1	14	$546



● Review of notification of construction/reconstruction	

2	

2	

5	

10	

0.5	

1	

12	

$455



● Review of notification of actual startup	2	2	5	10	0.5	1	12	$455



● Review of notification of initial performance testb+c+g	

2	

2	

5	

10	

0.5	

1	

12	

$455



● Review of notification of VOC use at the end of the initial yearg	

2	

2	

1	

2	

0.1	

0.2	

2	

$91



● Review of performance test resultsb+c	8	8	5	40	2	4	46	$1,820



New and Existing Affected Facilities







	

	

	

	





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ጀ monitoring exceedances and periods of noncompliance	

8	

32	

11h	

352	

18	

35	

405	

$16,012



● Semiannual reports of no excess emissions	2	4	42j	168	8	17	193
$7,642



● Report when 1st projected VOC use exceeds the applicable cutoff	

2	

2	

2	

4	

0.2	

0.4	

5	

$182



● Report when 1st actual 12-month VOC use exceeds the applicable
cutoff	

2	

2	

0j	

0	

0	

0	

0	

$0



● Notification of changes	2	2	1	2	0.1	0.2	2	$91



TOTAL BURDEN AND COSTg	

	670	34	67	771	$30,478



Footnotes	

a	Costs assume a rate of $40.56/hour for technical labor, $54.66/hour
for management labor, and $21.95/hour for clerical labor.

b	There are a total of 53 existing plants subject to this NSPS.  Assume
that each existing plant has one solvent-borne coating operation subject
to this NSPS.  Assume that a total of 4 new coating lines per year will
be installed at existing plants.

c	Assume one additional solvent-borne coating operation with VOC usage
greater than 95Mg/yr per year will be installed at a new plant each year
and will become subject to the standard in the next three years.  

d	A total of 5 new solvent-borne lines per year perform initial
performance test.

e	Assume 20 percent of initial performance tests must be repeated due to
failure (5 x 20% = 1).

f  	Assume retests are attended by EPA personnel.

g	An affected facility claiming to use less than 95Mg per year or less
than 130 Mg per year of VOC in the first year of operation shall submit
actual VOC records at the end of the initial year.  Assume there is one
new water-borne line per year (which uses less than 95 Mg of VOC per
year) being installed at existing plants over the 3 year period.  This
existing plant would be required to submit a notification of VOC use at
the end of the initial year of operation of its new coating line.  Also
we assume that the new solvent-borne lines being installed use at least
130 Mg of VOC per year and are not required to notify actual VOC use at
the end of the initial year.

h	Assume that 20 percent of the affected facilities (either complying
with the emission reduction standard, the alternative standard and/or
coating mix preparation equipment standard) report monitoring
exceedances or periods of noncompliance quarterly. [53 x 20% = 11
(rounded)].                

j		Assumes 80 percent of solvent-borne lines report no excess emissions
semiannually. [53 x 80% = 42 (rounded)]. 

k	No lines with projected VOC consumption of less than 95 Mg/yr or less
than 130 Mg of VOC are expected to exceed the cutoff value in the
future.

 PAGE   

 14 

