SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60

, Subpart RR ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60,

Subpart RR) (Renewal) , EPA ICR Number 0658.11 , OMB Control Number 2060

- 0004

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Pressure Sensitive Tape and Label

Surface Coating Operations ( 40 CFR part 60, subpart RR ) were proposed on December 30, 1980

, promulgated on October18, 1983 , and amended on October 17, 2000 . These regulations apply to

coating lines us ed in the manufacture of pressure sensitive tape and label materials. E xisting

facilities and new facilities are both subject to the se regulations , except those facilities that input

45 mega grams (MGs) of volatile organic compounds (VOC) or less per 12 month period. New

facilities include those that commenced construction, modification or reconstruction after

December 30, 1980. This information is being collected to assure compliance with 40 CFR part

60, subpart RR

.

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 sta rtup, 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 affect ed facilities 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 t wo years following the date of such measurements,

maintenance reports, and records. Al l 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 U

. S

. 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 each plant site has only one respondent (i.e.,

the owner/operator of the plant site).

Over the next three years, an average of 39 respondents per year will be subject to the

standard s

, while one additional respondent per year will become subject to the standard s

.

The “A ffected Public” are coating lines used in the manufacture of pressure sensitive tape

and label materials

. The burden to the “Affected Public” may be found below in Table 1 :2

Annual Respondent Burden and Cost

– N SPS for Pressure Sensitive Tape and Label Surface

Coating Operations (40 CFR Part 60 , Subpart RR ) (Renewal)

. T he burden to the Federa l

Government burden is attributed entirely to work performed by either F ederal employees or

government contractor s

. “Federal government” burden is associated with the review of reports

submitted by the respondent , a s shown below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60,

Subpart RR) (Renewal)

.

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 111 of the Clean Air Act (CAA), as amended,

to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous

emissions reduction which (taking into consideration the cost of

achieving such emissions reduction, or any non

- air quality health

and environmental impact and energy requirements) the

Administrat or determines has been adequately demonstrated.

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT).

Section 111 also requires that the Administrator review and, if appropriate, revise su ch 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 moni toring 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 Admini strator may

reasonably require.

In the Administrator's judgment, volatile organic compound (VOC) emissions from

coating lines used in the manufacture of pressure sensitive tape and label materials cause or3

contribute to air pollution that may reasonably be anticipated to endanger public health or

welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60,

subpart RR.

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. During th e 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 se standard s are used to inform the Ag ency 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

, that low solvent coatings are being used

, and the standard s 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 f or compliance

determinations.

3. Non

- duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart

RR

.

3(a) Non

- duplication

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,

duplication does not exist.

3(b) Publ ic 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 ( 77 FR 63813 ) on October 17, 2012

. No comments were received on the

burden published in the Fed eral 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 System (OTIS ) which is operated

and maintained by EPA's Office of Compliance. OTIS 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.

I ndustry trade associations and other interested partie s were provided an opportunity

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

standard s ha ve previously been reviewed to determine the minimum information needed for

compliance purposes. In developing this ICR, we c ontact ed : 1) the Pressure Sensitive Tape

Council (PSTC)

, at (630) 544

- 5048 ; and 2) the American Forest and Paper Association

, at (202)

463

- 2436

.

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 f irst Federal Register n otice. 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

T hese 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 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, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EP A 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.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 (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

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 pressure sensitive

tape and label surface coating operations . The United States Standard Industrial Classification

( SIC ) code for the respondents affected by the standards is SIC 2672

, which corresponds to the

North American I ndustry Classification System (NAICS ) code 322220 for Paper Bag and Coated

and Treated Paper Manufacturing

.

4(b) Information Requested

(i) Data Items

I n this ICR , all the data that is recorded or reported is required by the NSPS for Pressure

Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal)

.

A source must make the following reports:

Notifications

Notif ication of c onstruction/reconstruction 60.7(a)(1)

Notification of a ctual startup 60.7(a)(3)

Notification of p hysical or operational change 60.7(a)(4)

Notification of continuous monitoring system (CMS) demonstration 60.7(a)(5)

Initial performance test 60.8(d)6

Reports

Initial performance test results 60.8 (a)

Excess emissions report 60.7(c

- d ), 60.447(b

- c)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, and periods where the

continuous monitoring system is inoperative. 60.7(b)

Maintain calendar month record of all coatings used 60.445(a)

Maintain calendar month and 12

- month record of solvent applied in

coating 60.445(b

- d )

Maintain calendar month record of solvent recovered for

facility using a solvent recovery device 60.445(c)

Maintain continuous record of exhaust g as temperature for facility

using a thermal incineration solvent destruction device 60.445(e )

Maintain continuous record of upstream and do w nstream gas

temperature for facility using a catalytic incineration solvent

destruction device 60.445(f)

Records are required to be retained for two years. The most recent

two years of records must be retained at the facility 60.7(f), 60.445(h)

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 c ooperation with the respondents continue to create reporting

systems to transmit data electronically. However, electronic reporting systems are still not

widely used. At this time, it is estimated that approximately 10 percent of the respon dents use

electronic reporting.7

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for temperature monitoring of the exhaust gases

at a thermal incineration solvent destruction device; a CMS for temperature monitoring of the

gas upstream and downstream of the catalyst bed at a catalytic incineration solvent destruction

device; if applicable, install a monitoring device which continuously indicates that the hood or

enclosure that captures fugitive VOC emissions is operating.

Perform initial performance test, Reference Method 2 4 and 25 test s , 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.

Currently sources are using monitoring and reporting equipment that provide parameter

data in an automated way ( e.g., continuous parameter monitoring system. ) Although personnel

at the source still need to evaluate the data, this type of monitoring equipm ent 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, analysis,

storage, and distribution of the required information.8

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

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 pro perly installed and operated. Performance

test reports are used by the Agency to discern a source ’ s initial capabi lity to com ply 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 compli ance and

enforcement programs. The semiannual repor ts are used for problem identification, as a check on

source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and

maintained by EPA's Office of Compliance. OTIS is E PA ’ s database for the collection,

maintenance, and retrieval of compliance data for approximately 125,000 industrial and

government

- owned facilities. EPA uses the OTIS for tracking air pollution compliance and

enforcement by local and state regulatory age ncies, EPA regional offices and EPA headquarters.

Both EPA and its delegated a uthorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two

years.

5(c) Small Entity Fl exibility

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 invo lving 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 an d, 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 number of small entities potentially subject to the requirements of this information

collection request is estimated to be 29 percent of the respondent universe

, or 11 facilities.

This estimate is based on the percent of plants in this industry that were classified as small

entities during the development of this ru le (see BID document : EPA

- 450/3

- 80

- 003a, p. 8

- 30).9

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

– NSPS for Pressure Sensitive

T ape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal)

.

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and

reporting requirements applicab le 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 ver appropriate, specific tasks and

major ass umptions 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 record

keeping and reporting requirement s is estimated to be 3,6 5 2 hours ( Total Labor Hours from

Table 1 below ). T hese hours are based on Agenc y studies and background documen ts from the

development of the regulation, Agency knowledge and experience with the NSPS program, the

previously

- approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

Thi s ICR 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 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 costs10

associated with conti nuous monitoring. The capital/startup costs are one time costs when a

facility becomes subject to the regulation. The annual operation and maintenance costs are the

ongoing costs to maintain the monitor(s) and other costs su ch as photocopying and postage

.

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

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

(A)

Continuous

Monitoring

Device (B)

Capital/Startup

Cost for One

Respondent (C)

Number of

New

Respondents (D)

Total

Capital/Startup

Cost, (B X C) (E)

Annual O&M

Costs for One

Respondent (F)

Number of

Respondents

with O&M (G)

Total O&M,

(E X F)

Temperature $7

, 000 1 $7,000 $1,800 39 $ 70,200

The total capital/startup costs for this ICR are $ 7,000 . This is the total o f column D in

the above table.

The total operation and maintenance (O&M) costs for this ICR are $ 70,200

. 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 $ 77,200

.

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 i ncl udes activities such as the

examination of records maintained by the responden ts, 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

$ 14,440

.

This cost is based on the average hourly 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 2 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 e stimate is

based appear below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Pressure

Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal).11

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

3 8 existing respondents will be subject to the standard. It is estimated that an additional one

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

in the table below, is 39 per year.

The number of respondents is calculated using the following table that addresses the three

years covered by this ICR.

Number of Respondents

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 1 37 0 N/A 38

2 1 38 0 N/A 39

3 1 39 0 N/A 40

Average 1 38 0 N/A 39

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 year period of this ICR is 39

.

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

Total Annual Responses

(A)

Information Collection Activity (B)

Number of

Respondents (C)

Number of

Responses (D)

Number of Existing

Respondents That

Keep Records But Do

Not Submit Reports (E)

Total Annual Responses

E=(BxC)+D

Notification of construction/

reconstruction 1 1 N/A 1

VOC Emission Reports 39 2 N/A 78

Temperature Reports 31 2 N/A 62

Total 14 112

The number of Total Annual Responses is 14 1

.

The total annual labor costs are $350,762

. Details regarding these estimates may be

found below in Table 1 : Annual Respondent Burden and Cost

– NSPS f or Pressure Sensitive

Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal)

.

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost c alculations for the respondents and the

Agency are shown in Tables 1 and 2 below , respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 3,6 5 2 hours , at a cost of $350,762

. Details regarding

these estimates may be found below in Table 1 : Annual Resp ondent Burden and Cost

– NSPS

f or Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR)

(Renewal)

.

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

informa tion is estimated to average 2 6 hours per response (rounded)

.

The total annual capital/startup and O&M costs to the regulated entity are $77,200

. 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 320

labor hours at a cost of $ 14,440 . See below Table 2: Average Annual EPA Burden and Cost

– NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60,

Subpart RR) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated burden as currently identified in

the OMB Inventory of Approved Burdens. This increase is not due to any program changes.

The adjustment increase in burden from the most recently approved ICR is due to an increase

in the numbe r of sources and an increase in labor rates. The increase in the number of sources

subject to the standard also results in an increase in the total o peration and m aintenance (O&M)

c osts as calculated in section 6(b)(iii) since the previous ICR.

However, t here is an adjustment decrease in the total Agency burden costs . The reason

for the change in the EPA’s burden is related to a mathematical error in the calculations, which

led to double counting of Agency costs in the previous ICR

.13

6(g) Burden Statem ent

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

is estimated to average 2 6 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, proces sing 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

s ources; 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 Con trol 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 t his ICR under

Docket ID Number EPA

- HQ

- OECA

- 2012

- 0643 . 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 te lephone

number for the docket center i s (202) 566

- 17 52

. 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 i nclude the EPA Docket ID

Number EPA

- HQ

- OECA

- 2012

- 0643 and OMB Control Number 2060

- 0004 in any

correspondence.

Part B of the Supporting Statement

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

information.14

Table 1: Annual Respondent Burden and Cost

– NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40

CFR Part 60 , Subpart RR ) (Renewal)

Burden item (A)

Person

hours per

o ccur r ence (B)

N o. of

o ccu r rences

per

respondent

per y ear

(C)

Person

hours per

r e spondent

per year

(C=Ax B) (D)

Respondents

per y ear a (E)

Technical

person

hours per

y ear

(E=Cx D) (F)

Management

person

- hours

per y ear

( Ex 0.05) (G)

Clerical

person

hours per

y ear

(Ex 0.1) (H)

Total

c osts per

Year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read i nstructions c 0.87 1 0.87 1 0.87 0.04 0.09 $96.83

B. Req uired a ctivities

Initial performance test 52.17 1 52.17 1 52.17 2.61 5.22 $5,809.72

Repeat performance test d 52.17 1 52.17 0.2 10.43 0.52 1.04 $1,161.94

C. Create i nformation

------------------------ Included in 3b

----------------------------

D. Gather existing i nformation

------------------------ Included in 3e

----------------------------

E. Write r eport

Notification of construction/reconstruction 1.74 1 1.74 1 1.74 0.09 0.17 $193.66

Notification of actual startup 1.74 1 1.74 1 1.74 0.09 0.17 $193.66

Notification of initial performance test 1.74 1 1.74 1 1.74 0.09 0.17 $193.66

Report of performance test

------------------------ Included in 3b

----------------------------

Excess emission r eports

VOC emission reports e 4.35 2 8.7 39 339.3 16.96 33.9 3 $37,763.18

Temperature reports f 3.48 2 6.96 31 215. 76 10.7 9 21.5 8 $24,013.51

S ubtotal for Reporting Requirements 717 .31

4. Recordkeeping Requirements

A. Read i nstructions

------------------------ Included in 3a

----------------------------

B. Plan a ctivities

------------------------ Included in 4c

----------------------------

C. Implement a ctivities

------------------------ Included in 3b

----------------------------

Monthly performance test g 0.87 12 10.4 4 39 40 7

. 1 6 20.3 6 40.7 2 $45,315.82

D. D evelop record system N/A15

Burden item (A)

Person

hours per

o ccur r ence (B)

N o. of

o ccu r rences

per

respondent

per y ear

(C)

Person

hours per

r e spondent

per year

(C=Ax B) (D)

Respondents

per y ear a (E)

Technical

person

hours per

y ear

(E=Cx D) (F)

Management

person

- hours

per y ear

( Ex 0.05) (G)

Clerical

person

hours per

y ear

(Ex 0.1) (H)

Total

c osts per

Year b

D. Develop record s ystem N/A

E. Time to enter i nformation

Records of operating parameters h 0.22 250 55 39 2, 145 10 7

. 25 21 4

. 5 $236,019.89

F. Train p ersonnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 2,9 3 4.99

TOTAL LABOR BURDEN AND COST

(rounded) 3,6 5 2 $350,762

Assumptions:

a We have assumed that the average number of respondents potentially subject to this rule is 39. There will be one a dditional new source over the three

- year period

of this ICR.

b This ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per h our for Technical labor, and $50.51

per hour for Clerical labor. 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 by 110 perc ent to account for the benefit packages

available to those employed by private industry.

c We have assumed that it will take 0.87 hours for new respondent to read instructions.

d We have assumed that 20 percent will have to repeat performance tests because of failure.

e We have assumed that each source submits one excess emission report every year, in addition to the required semiannual report.

f We have assumed that 80 percent of sources will use incineration to control emissions (39x.8=31): 31.

g We assume that each respondent will take 0.87 hours once per month to record performance test.

h We assume that each respondent will take 0.22 hours 250 time per year to record operating parameters.16

Table 2: Average Annual EPA Burden and Cost

– NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40

CFR Part 60, Subpart RR) (Renewal)

Activity (A)

EPA

person

hours per

o ccur r ence (B)

N o. of

o ccur rences

per plant

per y ear (C)

EPA person

h ours per

plant per

year

(C=Ax B) (D)

Plants

per

Year a (E)

Technical

person

hours per

y ear

(E=Cx D) (F)

Management

person

- hours

per y ear

(Ex 0.05) (G)

Clerical

person

h ours per

y ea r

(Ex 0.1) (H)

Total

Cost, $ b

New facility

Initial performance test 20.87 1 20.87 1 20.87 1.04 2.09 $1,081.55

Repeat performance test/observed 20.87 1 20.87 0.2 4.17 0.21 0.42 $216.31

Review reports c

Notification of construction 1.74 1 1.74 1 1.74 0.09 0.17 $90.13

Notification of initial startup 0.43 1 0.43 1 0.43 0.02 0.04 $22.53

Notification of actual startup 0.43 1 0.43 1 0.43 0.02 0.04 $22.53

Notification of initial performance test 0.43 1 0.43 1 0.43 0.02 0.04 $22.53

Review test results 6.96 1 6.96 1 6.96 0.35 0.70 $360.52

Existing Plant

VOC emission reports d 1.74 2 3.48 39 135. 72 6.7 9 13.57 $7,03 3

. 81

Temperature reports e, f 1.74 2 3.48 31 107.8 8 5.39 10.78 $5,5 90

. 62

TOTAL ANNUAL BURDEN AND COST

(rounded) 320 $ 14,440

Assumptions:

a We have assumed that the average number of respondents potentially subject to this rule is 39. There will be one additional new source over the three

- year period

of this ICR.

b Labor rates for Federal agency personnel were applied to State/Local agencies, and are based on the average hourly labor rate as follows: Technical $46.21

(GS

- 12, Step 1, $28.88 + 60%); Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). This ICR assumes that

Managerial hour s are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2012 General Schedule,

which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit packages

available to government employees.

c We assume that each of the new facility will have to review reports

d We assume that e ach source submits one excess emission report every year, in addition to the required semiannual report.

e We assume that 80 percent of sources use incineration (39 x .8 = 31): 31.

f We assume that temperature reports are conducted two times per year.