**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF)**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal), EPA I CR Number 1157.10, OMB Control Number 2060

- 0073

. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Flexible Vinyl and Urethane Coating and Printing ( CFR part 60, subpart FFF ) were : 1) proposed on January 18, 1983 ; 2) promulgated on June 29, 1984 ; and 3) amended on October17, 2000 . These regulations appl y to facilities with rotogravure printing lines used to print or coat flexible vinyl or urethane products for which construction, modification or reconstruction commenced after January 18, 1983. This information is being collected to assure compliance with 40 CFR part 60, subpart FFF

. In general, all NSPS 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 an y period during which the monitoring s ys tem is inoperative. These notifications, reports , and records are essential in determining compliance, and are required of all affected fac ilities subject to NSPS

. Any owner/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 repo rts 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 24 respondents per ye ar will be subject to the standard, and it is estimated that one additional source will become subject over the next three ye ars of this ICR. The Office of Management and Budget ( OMB ) approve d the currentl y active I CR without any “ Terms of Clearance. ” The “Affected Public” are owners or operators of flexible vinyl and urethane coating and printing facilities

. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Flexible Vinyl and Urethane Coating and Printing (402

CFR Part 60, Subpart FFF) (Renewal)

. T he burden to the “Federal Government” is attributed entirely to work performed by

federal employees or government contractor s , and may be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)

. **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 sy stem 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 adequatel y demonstrated. Section 111(a)(l). The Agency

refers to thi s 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

o wner/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 ac cordance 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 whe n 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 Admini strator may reasonabl y require. In the Administrator's j udgment, volatile organic compounds (VOC) emissions from the printing and coating of flexible vinyl and urethane products either cause or contribute to air pollution that may

reasonably

be anticipated to endanger both public health or welfare. Therefore, the N SPS were promulgated for this source category at 40 CFR part 60 , subpart FFF

.3

**2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where 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. Continuous emission monitors are used to ensure compliance with the standard at all times. 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 properl y installed and operated and the standard is 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. Non**
**- duplication, Consultations, and**  **Other Collection Criteria** The requested recordkeeping an d reporting are required under 40 CFR part 60 , subpart FFF

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA re gi onal 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 cop y of the report submitted to the state or local a gency 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 I CR was published in the Federal Register ( 77 FR 63813 ) o n October 1 7 , 2012

. No comments were received on the burden published in the Federal Register. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and4

reporting provisions in the standard, is OTI S , which is operated and maintained by the EPA Office of Compliance. OTI S is the EPA database for the collection, maintenance, and retrieval of all compliance data. Based on data from OTIS, we estimate that 24 sources are currentl y subject to this standard s . Consultations with industry representatives (i.e., respondents) were conducted to determine if there is an y way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply . In developing this I CR, the EPA contacted : 1) the Chemical Fabrics and Film Association (CFFA) , at (216) 241

- 7333 ; and 2) the Wallcoverings Association , at ( 312 ) 321

- 5166

. EPA did not receive any comments from the consultations. 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. **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. I f 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** 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. 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

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar s tatute 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, an y pattern of non

- compliance, and to determine the appropriate level of enforcement action. E PA has found that the most flagrant violators have violations extending beyond the five years. In addition, EPA would be prevented from pursuing the violators due to either 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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,5

1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** T he reporting or recordkeeping requirements in the standard s 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 facilities with rotogravure printing lines used to print or coat flexible vinyl or urethane products, and for which construction, modification or reconstruction commenced after January 18, 1983. The United States Standard Industrial Classification (SI C) codes and corresponding North American Industry Classification Sy stem (NAICS) codes for the respondents affected by the standard are provided in the following table.

**Standard (**  **40 CFR Part 60, S ubpart**  **FFF )**  **SIC Codes NAICS Codes**  Fabric Coating Mills 2295 313320 Coated and Laminated Paper Manufacturing 2679 322222 All Other Converted Paper Product Manufacturing 2679 322299 **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 Flexible Vinyl and Urethane Coating and Printing (40 CFR P art 60, S ubpart FFF)

. A source must make the following notifications/reports:
**Notification s**  **/Reports** Notification of construction/reconstruction 60.7(a)(1) Notification of physical or operational change 60.7(a)(4) Notification of i nitial performance test 60.8(d) , 60. 7(a)(6) , 60.7(a)(7) Notification of delay and reschedule of initial performance test 60.8(d)6
**Notification s**  **/Reports** Notification of d emonstration of continuous monitoring sy stem performance 60.7(a)(5)
Semiannual reports 60.7(c), 60.7(d) , 60.585(b) A source must keep the following records: **Recordkeeping** Startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative 60.7(b) , 60.584(d)
Records for sources with continuous monitoring systems 60.7( f ) (1) , 60.7(f)(2) Records of all measurements 60.7( f ) , 60.583(b) , 60.583(c) Records of performance test conditions 60.8(c) Records of operating conditions for control equipment (i.e., temperature or VOC concentration) 60.584(a)(2) ,60.584(b)(2) , 60.584(c)(2) 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 recordke eping at a plant site. Also, regulatory

agencies , in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems are still not widely

used. At this time, it is estimated that approximately 20 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for VOC concentration or temperature. Perform initial performance test, Reference Method s 24, 25, 1, 2, 3, and 4 tests , and repeat7 **Respondent Activities** 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 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. D evelop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust existing way s to comply with an y previously applicable instructions and requirements. 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 type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping

. **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, analy sis, 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, anal yz e, and maintain data in the OTIS

.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 init ial capability to comply with the emission standard , and to note the operating conditions (VOC concentration or temperature) 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 operat ed and maintained by

EPA's Office of Compliance. 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 OTI S for tracking air pollution compl iance 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 th ese regulation s must be retained by the owner/operator for five ye ars. **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. Based on a small entity impact analy sis condu cted b y EPA during rule development (see background information document : EPA

- 450/3

- 81

- 016a) , the number of small entities potentially subject to the requirements of this ICR is estimated to be five percent of the respondent universe, or one facility

. Due to technical considerations 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. The specific frequency

for each info rmation collection activity within this request is shown below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)

. **6. Estimating the Burden and Co st 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 consi stent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and9

major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 775 ( 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 p rogram, the previously approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ 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 p ercent 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 information collection activ ities in the subje ct 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 mai ntenance (O &M) costs are the ongoing costs to maintain the monitor and other costs su ch as photocopying and postage.10 **(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) Tem perature or feed rate monitor $20,000 0.33 $6,600 $9 , 0 00 2 4 $ 216 , 0 00
The total capital/startup costs for this I CR are $ 6,600 . This is the total o f column D in the above table. The total O&M costs for this I CR are $ 216 ,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 IC R is estimated to be $ 222 ,600

. These are recordkeeping costs

. **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 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 $ 5, 435

. 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) , 20 1 1 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 Cos t

– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)

.11

**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 24 existing respondents will be subject to the standard s . It is estimated that an additional 0.33 respondents per ye ar will become subject. The overall average number of respondent s, as shown in the table below, is 24. 33 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**

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 0.33 2 3.66 0 0 24 2 0.33 2 4 0 0 2 4

. 33 3 0.33 24. 33 0 0 24. 66 Average 24

. 33 1 New respondent include sources with constructed, reconstructed and modified affected facilities. 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 24 (rounded)

. The total number of annual responses per ye ar 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 0.33 1 0 0.33 Notification of initial performance test 0.33 1 0 0.33 Semiannual Reports 24 2 0 48
Total 48.66 The number of Total Annual Responses is 4 9 (rounded)

.12

Th e total annual labor costs are $ 75,06 4

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

– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (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 (below) , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 775 hours at a cost of $75,06 4

. Details regarding these estimates may

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

– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 16 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 222,600

. 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 123 la bor hours at a cost o f $ 5, 43 5 . See below Table 2 : Average Annual EPA Burden and Cost

– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part 60, Subpart FFF) (Renewal)

. **6(f) Reasons for Change in Burden** There is an overall increase in the total estimated respondent and Agency burden as currentl y identified in the OMB Inventory of Approved Burdens. The change in burden from the most recentl y approved ICR is not due to any program changes. It is primarily due to an increase in the number of sources subject to the standard, which has been adjusted to reflect current information obtained from OTI S. There is also a corresponding increase in the total O&M costs because more sources are now subject to the stan dard. Additionally , this ICR references updated labor rates from the Bureau of Labor Statistics and the OPM in all burden calculations , which attribute to an increase in costs. There are additional changes in respondent and Agency burden estimates that are attributed to the correction of mathematical discrepancies identified in the previous I CR

. When estimating respondent and Agency technical person

- hours per occurrence for each burden item, the previous ICR applied a labor burden adjustment factor of 87 percent to each estimate. Since13

the previous ICR did not provide supporting rationale to justify the adjustment, and since it is not consistent with the estimation methodology used in other ICRs, we have revised respondent and Agency burden calculations in this I CR to reflect the full, unadjusted labor burden for each estimate. Additionally , there is an apparent decrease in the total Agency labor cost as a result of a mathematical correction made to the most recently approved ICR. The previous I CR doubl e counted annual salary

burdens for Agency

employees. To address this discrepancy , we have revised the cost accordingl y. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to avera ge 16 h ours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 c omment 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 IC R under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0657 . 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 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), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Cente r Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 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

- 2012

- 0657 and OMB Control Number 2060

- 0073 in any correspondence.14

**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 Flexible Vinyl and Urethane Co**  **ating and Printing (40 CFR Part 60,**  **Subpart FFF) (Renewal)**

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per**  **respondent per year**  **Technical**

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **b**
1. A pplications N/A 2. S urvey and S tudies N/A 3. Reporting Requirements A. Read Instructions c 1 1 1 0.33 0.33 0.02 0.03 $ 37.01 B. Required Activities New Sources Initial performance test d 280 1 280 0.33 92.4 4.62 9.24 $ 10,289.0 1 Repeat performance test d, e 280 0.2 56 0.07 3.92 0.2 0.39 $ 436. 89 C. Create Information

------------------------ Included in 3B

---------------------------- D. Gather Existing Information

------------------------ Included in 3B

---------------------------- E. Write Report New Sources Notification of construction/reconstruction f 2 1 2 0.33 0.66 0.03 0.07 $ 73. 32 Notification of initial performance test e, g 2 1.2 2 .4 0.33 0.79 0.04 0.08 $ 88. 08 Report of initial performance test

------------------------ Included in 3B

---------------------------- Existing Sources Semiannual report h 4 2 8 24 192 9.6 19.2 $ 21,379.7 7 **Subtotal for Reporting Requirements 33**  **3.62 $**  **32,30 4**  **. 08**  4. Recordkeeping Requirements 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 Information16

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours per** **occurrence No. of** 

**occurrences per**  **respondent per year**  **Technical**

**person -**  **hours per respondent**  **per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **b** Records of startup, shutdown , and malfunctions i 1.5 2 3 24 72 3.6 7.2 $ 8,017.42 Records of VOC, temperature , and CMS maintenance j 0.25 52 13 24 312 15.6 31.2 $ 34,742.14 F. Audits N/A **Subtotal for Recordkeeping Requirements 44**  **1.6 $**  **42,759.5 6**  **TOTAL ANNUAL BURDEN AND COST ( rounded**  **) 775**  **$ 75,06**  **4** Assumptions:
a We estimate that an average of 24 existing respondent , and it is estimated that one additional source will become subject over the next three years of this ICR

. b. This ICR uses the following labor rates: $100.23 for technical, $121.44 for managerial , and $50.51 for clerical labor. These r ates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “T otal compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. We estimate it will take one hour to read instructions. This burden item applies to new sources only. d. We estimate each performance test will take 280 hours to complete.
e. We estimate 20 percent of respondents will need to repeat the initial performance test. f. We estimate it will take 2 hours to prepare the notification of construction/reconstruction. g. We estimate it will take 2 hours to prepare the notification of initial performance test. h. We estimate it will take 4 hours to compile data for semiannual reports. i. We estimate it will take 1.5 hours to record startups, shutdowns , and malfunctions. j. We estimate it will take 0.25 hours to record VOCs, temperature s, and CMS maintenance.17

**Table 2 : Average Annual EPA Burden and Cost** 

**– NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR Part**  **60, Subpart FFF) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H P**  **erson hours per**  **occurrence No. of** 

**occurrences per respondent**  **per year P**  **erson -**  **hours**

**per respondent per year**  **( C=** **AxB) Respondents** 

**per year a**  **Technical**

**person hours per**  **year (CxD)**  **Managem ent** 

**person**   ** hours** **per year (Ex0.05)**  **Clerical**

**person**   ** hours** **per year (Ex0.10)**  **Total cost**

**per year ($)**  **b**
Required Activities New Sources Initial performance tests c 24 1 24 0.33 7.92 0.40 0.79 $ 410.45 Repeat performance tests c , d 24 1 24 0.07 1.68 0.08 0.17 $ 102.67 Report Review New Sources Notification of construction/reconstruction e 2 1 2 0.33 0.66 0.03 0.07 $ 52.36 Notification of initial startup f 0.5 1 0.5 0.33 0.17 0.01 0.02 $ 27.95 Notification of actual startup g 0.5 1 0.5 0.33 0.17 0.01 0.02 $ 27.95 Notification of initial test d, h 0.5 1.2 0.6 0.33 0.20 0.01 0.02 $ 29.57 Revie w test results d , i 0.5 1.2 0.6 0.33 0.20 0.01 0.02 $ 29.57 Existing Sources Semiannual reports j 2 2 4 24 96 4.8 9.6 $ 4,754.86 ANNUAL SALARY BURDEN 123 $ 5,435.3 8 **TOTAL ANNUAL BURDEN AND COST ( rounded**  **) 123**  **$ 5,**  **43 5**  Assumptions:
a We estimate that an average of 24 existing respondent, and it is estimated that one additional source will become subject over the next three years of this ICR b This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial , and $25.01 for clerical labor. These rates are from th e Office of Personnel Management (OPM), 2011 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent t o account for the benefit packages available to government employees.
c We estimate it will take 24 hours to participate with each performance test.18

d We estimate 20 percent of respondents will need to repeat the initial performance test.
e We estimate it will take 2 hours to review construction/reconstruction notifications. f We estimate it will take 0.5 hours to review initial startup notifications. g We estimate it will take 0.5 hours to review actual startup notifications. h We estimate it will take 0.5 hours to review initial test notifications. i We estimate it will take 0.5 hours to review test results. j We estimate it will take 2 hours to review each semiannual report twice annually.

.