SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal), EPA ICR 

Number 1951.06, OMB Control Number 2060-0511. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paper and 

Other Web Coating were proposed on September 13, 2000 and promulgated on December 4, 

2002. These regulations apply to existing facilities and new paper and to other web coating 

facilities, including web coating lines engaged in the coating of metal webs used in flexible 

packaging, and web coating lines engaged in the coating of fabric substrates for use in pressure 

sensitive tape and abrasive materials. New facilities include those that commenced construction 

or reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR Part 63, Subpart JJJJ.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They 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 affected facilities subject to NESHAP.

Any owner/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.

 Based on our consultations with industry representatives, there is an average of one

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

All of the paper and other web coating facilities in the United States are owned and 

operated by the paper and other web coating industry (the “Affected Public”). None of the 

facilities in the United States are owned by state, local, tribal or the Federal government. 

They are privately-owned, for-profit businesses. The burden to the “Affected Public” may be 

found in Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other Web 

Coating (40 CFR Part 63, Subpart JJJJ) (Renewal). The burden to the “Federal Government” is 

attributed entirely to work performed by federal employees or government contractors and can 
2

be found in Table 2: Average Annual EPA Burden and Cost – NESHAP for Paper and Other 

Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal).

Over the next three years, approximately 251 respondents per year will be subject to the 

standard, and 6 additional respondents per year will become subject to the standard. The 

respondent universe and growth rate are based estimates from the previous ICR renewal, and are 

verified through consultation with industry and OAQPS. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any Terms of Clearance.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 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/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, particulate emissions from paper and other web coating 

facilities cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NESHAP standards were promulgated for this source 

category at 40 CFR Part 63, Subpart JJJJ.

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.
3

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in the standard 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, leaks are being detected and repaired, and the standard are being met. 

The performance 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. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

JJJJ.

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 (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry 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 Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO 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. 
4

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted both the American Forest & Paper Association at 

(202) 463-2581 and the National Paper Trade Association at (312) 321-4092.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

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 proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents 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. The retention of records for five years allows EPA to establish the compliance history

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

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
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The 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 paper and other web 

coating facilities. The United States Standard Industrial Classification (SIC) codes for the 

respondents affected by the standards and the corresponding North American Industry

Classification System (NAICS) codes are listed below:

Standard (40 CFR, Part 63, Subpart JJJJ) SIC 

Codes

NAICS 

Codes

Corrugated and Solid Fiber Box Manufacturing 2653 322211

Folding Paperboard Box Manufacturing 2657 322212

Coated and Laminated Packaging Paper and Plastics Film 

Manufacturing 2671 322221

Coated and Laminated Paper Manufacturing 2672 322222

Plastics, Foil, and Coated Paper Bag Manufacturing 2673 322223

Uncoated Paper and Multiwall Bag Manufacturing 2674 322224

Surface-Coated Paperboard Manufacturing 2675 322226

All Other Converted Paper Product Manufacturing 2675,

2679

322299

Coated and Laminated Paper Manufacturing 2679 322222

Commercial Gravure Printing 2754 323111

Manifold Business Form Printing 2761 323116

Un-laminated Plastics Film and Sheet (except packaging) 

Manufacturing 3081 326113

Laminated Plastics Plates, Sheet (except packaging), and Shape 

Manufacturing 3083 326130

Abrasive Products Manufacturing 3291 327910

Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 3497 322225

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Paper 

and Other Web Coating (40 CFR Part 63, Subpart JJJJ).
6

A source must make the following reports:

Notifications

Initial notification 63.9(b), 63.3400(b)

Notification of performance test 63.7, 63.9(e), 

63.3400(d)

Notification of compliance status 63.9(h), 63.3400(e)

Notification of performance tests results 63.13(f)

Reports

Performance test report 63.3400(f)

Startup, shutdown, and malfunctions report 63.10(d)(5), 

63.3400(g)

Semiannual compliance report 63.3400(c)

A source must keep the following records:

Recordkeeping

Records to demonstrate compliance 63.10(b)(2), 

63.3410(a)(1)

Records for each CMS 63.3410(a)(2)

Records are required to be retained for five years 63.10(b)(1)

Electronic Reporting

Some of the respondents 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. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements. 

Perform initial performance test, Reference Method Reference Methods 1, 1A, 2, 2A, 2C, 2D, 
7

Respondent Activities

2F, 2G, 3, 3A, 3B, 4, 24, 25, 25A tests, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

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 Integrated Compliance Information System (ICIS) and 

ECHO. 

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 properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 
8

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 reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS 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/operator for five 

years.

5(c) Small 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 considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these 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 each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other 

Web Coating (40 CFR Part 63, Subpart JJJJ) (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 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
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The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 13,800 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP 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 $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “Table 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 for 

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 

subject standard 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 and other costs such as photocopying and postage.

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

Parametric 

monitoring 

(contractor)

$10,000 5 $50,000 $25 222 $5,550

Continuous 

emission 

monitoring 

system 

(CEMS)

$183,500 1 $183,500 $26,700 29 $774,300

Total cost

(rounded) $234,000 $780,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

We estimate an average of 251 sources during the three-year period of this ICR. We also estimate that 6 new 

sources per year will become subject to the rule. Of the new sources, one source will be using solvent recovery 

devices and will use CEMS to monitor emissions. 

The total capital/startup costs for this ICR are $234,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $780,000. 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 ICR is estimated to be $1,010,000. These are 

recordkeeping costs. 

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 

$413,000. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 
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Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Paper and 

Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

245 existing respondents will be subject to the standard. It is estimated that an additional 6

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 251 per year.

The number of respondents is calculated using the following table that 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 6 239 0 0 245

2 6 245 0 0 251

3 6 251 0 0 257

Average 6 245 0 0 251

1

New respondents include sources with constructed and reconstructed affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 251.

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

Initial Notification 6 1 0 6

Notification of performance test 6 1 0 6

Notification of compliance status 6 1 0 6

Performance test reports 6 1 0 6

SSM reports 222 0.2 0 44.4

Semiannual report 251 2 0 502

Total 570.6

Note: SSM reports are typically submitted with the semiannual reports. However, we assume the 222 sources 

conducting parametric monitoring will submit an additional report of non-conforming SSM 20% of the time. 

The number of Total Annual Responses is 571

The total annual labor costs are 1,380,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other 

Web Coating (40 CFR Part 63, Subpart JJJJ) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 13,800. Details regarding these estimates may be found 

in Table 1. Annual Respondent Burden and Cost – NESHAP for Paper and Other Web Coating

(40 CFR Part 63, Subpart JJJJ) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 24 hours per response.
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The total annual capital/startup and O&M costs to the regulated entity are $1,010,000. 

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 

9,080 labor hours at a cost of $413,000. See Table 2: Average Annual EPA Burden and Cost –

NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent and Agency burden, including the 

respondent O&M cost. The increase is not due to any program changes. Rather, it is due to an 

increase in the estimated number of sources subject to the rule. Based on information from 

previous ICR renewals and past industry analyses conducted by the Agency, we assume a linear 

growth rate of 6 new sources per year for this sector. The growth in the number of sources 

subject to this NESHAP results in an increase in the total estimated burden hours and costs. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 24 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 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 
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Docket ID Number EPA-HQ-OECA-2014-0511. 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-HQ-OECA-2014-0077 and OMB Control Number 2060-0511 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) 

(Renewal)

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) 

Person 

hours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person 

hours per 

respondent 

per year 

(C=AxB)

Respondents 

per year a

Technical 

personhours per 

year 

(E=CxD)

Management 

person hours 

per year 

(Ex0.05)

Clerical 

person 

hours per 

year (Ex0.1) Cost, $ b

1. Reporting requirements

 A. Familiarization with rule requirements 4 1 4 251 1,004 50.2 100.4 $116,108.08

 B. Gather information c

4 4 16 6 96 4.8 9.6 $11,101.97 

 C. Write reports c

 i. Initial notification 2 1 2 6 12 0.6 1.2 $1,387.75 

 ii. Notification of performance test 2 1 2 6 12 0.6 1.2 $1,387.75 

 iii. Notification of compliance status 2 1 2 6 12 0.6 1.2 $1,387.75 

 iv. Performance test reports 2 1 2 6 12 0.6 1.2 $1,387.75 

 v. SSM reports d

2 0.2 0.4 222 88.8 4.44 8.88 $10,269.32 

 vi. Semiannual summary report 4 2 8 251 2008 100.4 200.8 $232,216.16 

Subtotal for Reporting Requirements 3,732 $375,246.52

2. Recordkeeping requirements

 A. Familiarization with rule requirements c

4 1 4 6 24 1.2 2.4 $2,775.49 

 B. Plan activities c

15 1 15 6 90 4.5 9 $10,408.10 

 C. Implement activities for compliance 

coating use e5 12 60 21 1260 63 126 $145,713.33 

 D. Implement activities for control devices 

and process equipment c

 i. Design analysis 12 1 12 6 72 3.6 7.2 $8,326.48 

 ii. Performance test oversight 20 1 20 6 120 6 12 $13,877.46 

 E. Develop record system

 i. Develop startup, shutdown, 

malfunction plan c20 1 20 6 120 6 12 $13,877.46 

 ii. Develop plan for material used 10 1 10 21 210 10.5 21 $24,285.56 
16

 iii. Control equipment and maintenance 

plan c10 1 10 6 60 3 6 $6,938.73 

 F. Time to enter information

 i. Compliance calculation 2 12 24 21 504 25.2 50.4 $58,285.33 

 ii. Control equipment testing 1 1 1 222 222 11.1 22.2 $25,673.30 

 G. Time to train personnel

 i. Acquisition and installation c

15 1 15 6 90 4.5 9 $10,408.10 

 ii. Equipment inspection and monitoring 10 1 10 222 2220 111 222 $256,733.01 

 iii. Use of technology and systems f

10 1 10 222 2220 111 222 $256,733.01 

 H. Store, file and maintain records g

0.25 12 3 251 753 37.65 75.3 $87,081.06 

 I. Retrieve records/reports g

0.25 12 3 251 753 37.65 75.3 $87,081.06 

Subtotal for Recordkeeping Requirements 10,025.7 $1,008,197.47

TOTAL LABOR BURDEN AND COST (rounded): 13,800 $1,380,000

Capital and O&M Cost (see Section 6(b)(iii)): $1,010,000

TOTAL COST: $2,390,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 251. There will be eighteen additional new sources that will 

become subject to the rule over the three-year period of the ICR (i.e., six per year). 

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 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 

for the benefit packages available to those employed by private industry.

c

 We have assumed that this is a one-time activity for each new facility. 

d

 Startup, shutdown, malfunction (SSM) reports are to be submitted twice a year with the required semiannual report. However, as estimated 20 percent of the 

respondents using parametric monitoring will submit an additional report for a non-conforming SSM.

e

 We have assumed that it would take 21 respondents to record 

activities for compliance coating use.

f

 We have assumed that 222 respondents for this activity. 

g

 We have assumed that 251 respondents will be involved in the storage, filing, maintenance and retrieval of records and reports twelve times per year.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) 

(Renewal)

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person hours 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G)

Clerical 

person hours 

per year 

(Ex0.1)

(H)

Cost, $ b

1. Review initial notification c

8 1 8 6 48 2.4 4.8 $2,512.32 

2. Review notification of compliance status 10 1 10 6 60 3 6 $3,140.40 

3. Review SSM reports d

4 0.2 0.8 222 177.6 8.88 17.76 $9,295.58 

4. Review semiannual summary reports e

15 2 30 251 7530 376.5 753 $394,120.20 

5. Review notification of performance test c

4 1 4 6 24 1.2 2.4 $1,256.16 

6. Review test results c, f

10 1 10 6 60 3 6 $3,140.40 

TOTAL ANNUAL BURDEN AND COST (rounded) 9,080 $413,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be 251. There will be eighteen additional new sources that will 

become subject to the rule over the three-year period of the ICR (i.e., six per year). 

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for 

Managerial (GS-13, Step 5), $46.67 for Technical (GS-12, Step 1), and $25.25 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management 

(OPM) “2014 General Schedule” which excludes locality rates of pay.

c

 We have assumed that this is a one-time activity for each new facility.

d

 Startup, shutdown, malfunction (SSM) reports are to be submitted twice a year with the required semiannual report. However, as estimated 20 percent of the 

respondents using parametric monitoring will submit an additional report for a non-conforming SSM.

e

 It is assumed that each respondents will review summary reports twice per year.

f

 We have assumed that it will take each respondents ten hours to review test results.