**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for**  **Rubber Tire Manufacturing (40 CFR Part**  **60 , Subpart**  **BBB ) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NSPS for Rubber Tire Manufacturing (40 CFR Part 6 0 , Subpart BBB ) (Renewal), EPA I CR Number 1158.11 , OMB Control Number 2060

- 0156 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Rubber Tire Manufacturing were : 1) proposed on January

20, 1983 ; 2) promulgated on September 15, 1987 ; and 3) last amended on October 17, 2000. These regulations apply to all facilities with the following processes: undertread cementing operations, sidewall cementi ng operations, tread end cementing operations, bead cementing operations, green tire spraying operations, Michelin

- A operations, Michelin

- B operations, and Michelin

- C automatic operations. Affected facilities include those that commenced construction, modification , or reconstruction after January 20, 1983 . This information is being collected to assure compliance with 40 CFR part 60, subpart BBB

. In general, all NSPS standards require initial notifications , performance tests, and periodic reports by

the o wners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of an y startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is in operative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurem ents, 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 41 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the se standard s
. While some rubber tire manufacturing plants may conduct operational changes, these changes will not trigger applicability

of this rule. We are also assuming that all plants are now using the water

based spray s that meet the NSPS green tire spr ay limits without having to use add

- on control equipment. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance ”

. T he “Affected Public” is rubber tire manufacturing plants in the United States, all of2

which are both publicl y - owned and

- operated by private, for

- profit businesses. None of the plants are owned b y state, local, tribal, or the Federal government. The “burden ” to the Affected P ublic may

be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60 , Subpart BBB ) (Renewal)

. T he “burden ” to the Federal Government is attributed entirely to work performed by either F ederal employee s or government contractor s and can be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collectio**  **n** 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 sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y 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 e very 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 informat ion as the Administrator may reasonabl y require. In the Administrator's judgment, volatile organic compound (VOC) emissions from rubber tire manufacturing plants cause or contribute to air pollution that may reasonabl y be anticipated to endanger public h ealth or welfare. Therefore, the NSPS were promulgated for this3

source category

at 40 CFR part 60, subpart BBB

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order t o determine an affected facility ’ s i nitial capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may b e recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard s 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 properl y installed and operated , leaks are being detected and repaired , and the standard is being met. The perfor

mance test may

also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consult**  **ations, and Other Collection Criteria** The requested recordkeeping and reporting are required under 40 CFR part 60, subpart BBB

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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, duplication does not exist. **3(b) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 78 FR 334 09 ) on June 4, 2013 . No comments were received on the burden estimates published in the Federal Register

.4

**3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (OTIS ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested partie s were provided an opportunity to comment on the burden associated with the standard s as they w ere being developed and the standard s have been reviewed previously to determine the minimum information needed for compliance purposes. Indeveloping this ICR, we contacted : 1) the Rubber Manufacturers Association , at (202) 682

- 4800 ; and 2) Goodye ar , at (330) 796

- 2121

. It is our policy

to respond after a thorough review of comments received since the last I CR renewal as well as those submitted in respons e to the f irst Federal Register n otice. Comments from Goodyear were received on September 26, 2013. The comments indicated that plants now operate on average 350 day s a year, because they have increased their operating hours to seven day s a week, 24 hours a day , with holiday s off. **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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 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, Septemb er 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

**3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a)**  **Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are rubber tire manufacturing plants . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 3011, which cor responds to the North American Industry Classification Sy stem (NAICS ) code 32621 for Tire Manufacturing. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB). A source must make the following reports:

**Notification s**  Notification to construct/reconstruct 60.7(a)(1) Notification of anticipated startup 60.7(a)(2) Notification of actual startup 60.7(a)(3) Initial performance test results 60.8(a) Initial compliance report that includes initial performance test, monthly schedule to be used in making compliance determinations, design and equipment specifications and compliance method 60.8(a), 60. 8(d), 60.546(a

- e) Demonstration of continuous monitoring sy stem 60.7(a)(5) Notification of ph ys ical or operational change 60.7(a)(4) Periodic startup, shutdown, malfunction reports, and periods where the continuous monitoring s ys tem is inoperative 60.7(b) Seeking to compl y with an alternative method, from use of applicable percent emission reduction requirement to applicable total (uncontrolled) monthly

VOC use limit 60.546(h)6 **Reports** Initial and annual formulation data or Method 24 results to verify VOC content of water

- based spray s 60.546(j) Excess emissions report 60.546(f

- g) A source must keep the following records: **Recordkeeping** Maintain records of startups, shutdowns, malfunctions, and periods where the continuous monitoring s ys tem is inoperative 60.7(b) Maintain a file of all measurements including performance tests, and all other information required by this part and recorded in a permanent file suitable for inspection. The file shall be retained for at least two ye ars. 60.7(f) Maintain records of operating parameters of monitoring device results for cataly tic or thermal incinerator, or carbon absorber 60.545(a

- c)
Maintain records of monthly VOC use, number of day s in compliance period, and other information needed to verify results of all monthly

tests 60.545(d

- e)
Maintain records of formulation data or results of Method 24 anal ys is of water

- based spray s containing less th an 1.0 percent of VOC 60.545(f)
Electronic Reporting Some of the r espondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that app roximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate a temperature monitoring device with a continuous recorder, an organics monitoring device with a continuous recorder to detect the concentration level of organic compounds, or a recovery device, as applicable.7 **Respondent Activities** Perform initial performance test, Reference Method 24 test or formulation data anal ys is for the determination of the VOC content of cements or green tire spray materials. Method 25A for the determination of the VOC concentration if using a c ontrol device, Method 2 for the determination of the flow rate at the stack gas, monthly performance test or formulation data anal ys is of the spray

material, and repeat performance test 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem ) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Method ology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S).8

**5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to compl y 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compl iance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Smal l Entity Flexibility**  A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical consid erations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements 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 ea ch information collection activity within this request is shown below in Table 1: Annual Respond ent Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal)

. **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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

.9

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 req

uirement s is estimated to be 17,684 hours ( Total Labor Hours from Table 1 below ). T hese 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 IC R, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 3

. 0 4 ($5 8

. 59 + 110%) Technical $ 10 1

. 2 2 ($4 8

. 2 0 + 110%) Clerical $ 5 1

. 1 8 ($2 4

. 37 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 201 3 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the inform ation collection activities in the subject standard are labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. Th e capital/startup costs are one

- time costs when a facility becomes subject to the regulati on. 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**10

**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 1 (G)

Total O&M, (E X F)

VOC (organics) mo nitor $35,000 0 $0 $7,500 0 $0

Tem perature monitors at thermal and catalytic incinerators $7,500 0 $0 $4,000 4.1 $16,400

Total $0 $16,400

1 An estimated 10 percent of respondents use a temperature monitor The total capital/startup costs for this I CR are zero. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $16,400. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $16,400

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program i ncludes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distributio n of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $18,809. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 2013 General Schedule ,11

which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Tabl e 2: Average Annual EPA Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 41 existing respondents will be subject to the standard s . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 41 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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 4.1 4.1 36.9 4.1 41
2 4.1 4.1 36.9 4.1 41 3 4.1 4.1 36.9 4.1 41 Average 4.1 4.1 36.9 4.1 41 1 New respondent include sources with constructed, reconstructed and modified affected facilities (10% x 41 = 4.1)

. The remainder must keep records (90% x 41 = 36.9)

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 41

. The total number of annual responses per ye ar is calculated using the following table:12 **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 Method 25A test 3 1 0 3 Report of physical/operational changes 4.1 1 0 4.1 Notification of change in spray materials formulation 4.1 1 0 4.1 Semiannual report of excess emissions 13.7 2 0 27.4 Annual report of formulation data/Method 24 41 1 0 41
**Total 79.6** 
The number of Total Annual Responses is 80 (rounded)

. The total annual labor costs are $1, 729 , 807

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal)

. **6(e) Bottom Line 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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 1 7,684 hours at a cost of $1,729,807

. Details regarding these estimates may

be found below in Table 1. Annual Respondent Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 221 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $16,400

. 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 41713

labor hours at a cost of $18,809 . See below Table 2: Average Annual EPA Burden and Cost

– NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal)

. **6(f) Reasons for Change in Burden** There is an adjustment increase in the respondent burden from the most recently approved ICR. Based on consultation comments received in development of this I CR, the frequency of occurrence for burden items “monitoring of VOC emissions and operations” and “recording startup, shutdown, and malfunction” were revised to account for 350 day s per year operation , which is t ypica l for current plant operation in the industry sector

. This results in an increase of respondent burden hours and costs. There is also a decrease of one burden hour for the Agency as a result of rounding. This ICR calculates all burden hours and costs t o two decimal places and presents a more precise estimate. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 221 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 ut ilize technology and sy stems for the purposes of collecting, validating, and verifying information, p rocessing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with an y previously

applicable instruct ions 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 regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for thi s 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 I CR under Docket ID Number EPA

- HQ

- O EC A

- 2013

- 0329 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 th e docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , 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), WJC 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 Fri day , excluding legal14

holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 20 13

- 0329 and OMB Control Number 2060

- 0156 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.15

**Table 1: Annual Respondent Burden and Cost**

**– NSPS for**  **Rubber Tire Manufacturin g (40 CFR Part 60, Subpart BBB)**  **(Renewal)**

**Burden item (A)**  **Person hours per**  **occurrenc e**  **(B)**

**No. of occurrences**  **per respondent**  **per year**  **(C)**

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person/ hours per**  **year (Ex0.05)**  **(G)**

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions 1 1 1 0 0 0 0 $0 B. Required activities c Initial performance test d 240 5 1,200 0 0 0 0 $0 Repeat initial performance test d 240 1 240 0 0 0 0 $0 Monitoring of VOC emissions and operations e 1 350 350 41 1 4 ,3 50 717.5 1, 435 $1, 614 , 231

. 50 Monthly performance tests e, j 2 12 24 0 0 0 0 $0 C. Create information See 3B D. Gather existing information See 3E E. Write report Notification of actual startup 2 1 2 0 0 0 0 $0 Notification of initial performance test 2 1 2 0 0 0 0 $0 Initial performance test results 2 1 2 0 0 0 0 $0 Notification of Method 25A test f 4 1 4 3 12 0.6 1.2 $1,349.88 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 Report of physical operational changes g 4 2 8 4.1 32.8 1.64 3.28 $3,689.67 Report of spray materials/formulation change h 4 2 8 4.1 32.8 1.64 3.28 $3, 689.67 Semiannual reports i 10 2 20 13.67 273.33 13.67 27.4 $ 30,747.27 Annual report of formulation data/Method 24 Results j 4 1 4 41 164 8.2 16.4 $ 18,448.36 **Subtotal for Reporting Requirements 1**  **7,09 4.74**  **$1,672,156 .35**  4. Recordkeeping requirements A Read instructions See 3A B Plan activities See 3B C Implement activities See 3B16

**Burden item (A)**  **Person hours per**  **occurrenc e**  **(B)**

**No. of occurrences**  **per respondent**  **per year**  **(C)**

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person/ hours per**  **year (Ex0.05)**  **(G)**

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

D Develop record system N/A E Time to enter and transmit information k Record of startup, shutdown, and malfunction 0.5 25 13 41 512.5 25.63 51.25 $ 57,651.13 Records of monthly performance test See 3B Records of emissions and operations See 3B F Time to train personnel N/A G Time for audits N/A **Subtotal for Recordkeeping Requirements 589**  **.38 $57,651**  **.13 TOTAL LABOR BURDEN AND COST (rounded)**  **1 7,684**  **$1, 729,807** 
**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 41existing sources one of whi ch mixes only rubber compound. There will be no additional sources over the three

- year period of this ICR. In addition, we have not included the reporting requirements burden for affected facilities exemptions under 40 CFR ' 60.676(d) in the table because their occurrence is very rare in practice. b This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and $51.18 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March, 2013 , T able 2. Civilian Workers, by Occupational and Industry group. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account fo r the benefit packages available to those employed by private industry.
c We have assumed that the rubber tire manufacturing plants will not construct or reconstruct an affected facility, however, they will conduct operational changes on 10 percent of the affected operations. d We have assumed that there will be no new sources expected over the three

- year period of this ICR. e Sources are required to monitor and record monthly performance tests, VOC use, the number of days in each compliance period, control device efficiency, formulation data or the results of Method 24 test analysis conducted to verify the VOC content of the spray , monitoring device data and other operational data such as the number of tires processed. We have assumed that sources will operate approximately 350 days per year or 50 we eks. We have further assumed that the burden incurred to record these items is on e hour per occurrence since much of the required information would be currently recorded by the industry with or without regu lation. f We have assumed that three existing sources using control devices will conduct a Method 25 test once a year to determin e the VOC concentration in each stack (source using a capture system) both entering and leaving the control device. g We have assumed that 10 percent of the existing rubber tire manufacturing plants subject to this rule will make a physical/op erational ch ange by adding a green tire spray booth or a new

line. h A source is required to do Method 24 test or formulation data analysis if the operational change involves spray materials formulation changes, and results should be17

reported within 30 days. i We have assumed that one

- third of the sources will submit exceedance reports for each six month period. j We have assumed that all existing sources, will submit an annual Method 24 test report or an annual formulation data report t o verify the VOC content of e ach tread end cement and green tire spray material in lieu of conducting a monthly performance test. We have further assumed that 50 p ercent of the existing sources, will continue to use hazardous air pollutant (HAP) materials (VOC) in the spray at levels that meet the green tire VOC limitations in NSPS not needing to add on control devices. The remaining plants will use only water

- based sprays and are not required to perform monthly performance tests. We have assumed that the burden incurred to record these items is one hour per occurrence per source due to the nature of the control equipment used and its intermittent use. k We have assumed that there will be two occurrences of startup, shutdown, and/or malfunction per source every four weeks, whic h wil l yield and average of 25 occurrences per source per respondent in 50 we eks.18

**Table 2: Average Annual EPA Burden**
**- NSPS for**  **Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB**  **) (Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant**  **per year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total cost**  **per year**  **b**

Notification of actual startup c 2 1 2 0 0 0 0 $0 Notification of initial performance test c 2 1 2 0 0 0 0 $0 Report of performance test results c 2 1 2 0 0 0 0 $0 Notification of construction/reconstruction c 2 1 2 0 0 0 0 $0 Notification of Method 25A test d 8 1 8 3 24 1.2 2.4 $1,243.79 Notification of change in spray materials formulation e 2 1 2 4.1 8.2 0.41 0.82 $424.96
Semiannual reports f 4 2 8 13.7 109.33 5.47 10.93 $5,666.15 Annual report of formulation data/Method 24 test results g 5 1 5 41 205 10.25 20.5 $10.624.02 Report of physical/operational changes h 4 1 4 4.1 16.4 0.82 1.64 $849.92 **Subtotals Labor Burden and cost 362.93**  **18.15 36.29**  **$18,808.84 TOTAL LABOR BURDEN**  **AND COST (rounded) 417**  **$18,809**
**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 41 existing sources one of wh ich mixes only rubber compound. There will be no additional sources over the three

- year period of this ICR. b This cost is base d on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead exp enses: $62.27 for Managerial (GS

- 13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 for Cler ical (GS

- 6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) 201 3 General Schedule which excludes locality rates of pay. c We have assumed that there will be no new sources expected over the three

- year period of this I CR d We have assumed that three existing sources using control devices will conduct a Method 25 test once a year to determine the VOC concentration in each stack (source using a capture system) both enter and leaving the control device. e We have assumed that a source is required to do Method 24 or formulation data analysis if the operational change involves spray materials formulation changes and results should be reported within 30 days. f We have assumed that one

- third of sources will submit exceedanc e reports for each six month period. g We have assumed that all existing sources will submit an annual Method 24 test report or an annual formulation data report to verify the VOC content of each tread19

end cement and green tire spray material in lieu of c onducting a monthly performance test. We have further assumed that 50 percent of the existing sources will continue to use HAP materials (VOC) in the spray at levels that meet the green tire VOC limitations in NSPS not needing any a dd on control devices. The remaining plants use only water

- based sprays and are not required to do monthly performance tests. We have assumed that the burden incurred to record these items is five hour s per occurrence per source due to the nature of the control equipment used and its intermittent use. h We have assumed that ten percent of the existing rubber tire manufacturing plants subject to the rule will make a physical/op erational change due to adding a green tire spray booth or a new line.