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 0658.12, 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 were proposed on December 30, 1980, promulgated on October 18, 

1983, and amended on October 17, 2000. These regulations apply to coating lines used in the 

manufacture of pressure sensitive tape and label materials. Existing facilities and new facilities

are both subject to these 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 the date of proposal. This 

information is being collected to assure compliance with 40 CFR Part 60, Subpart RR.

In general, all NSPS standards require initial notification reports, 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 NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file containing 

these documents, and retain the file for at least two years following the generation date of such 

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 U.S.

Environmental Protection Agency (EPA) regional office.

The “Affected 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: Annual 

Respondent Burden and Cost – NSPS for Pressure Sensitive Tape and Label Surface Coating 

Operations (40 CFR Part 60, Subpart RR) (Renewal). The Federal Government’s burden is 

attributed entirely to work performed by either Federal employees or government contractors and 

may be found 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). 

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

affected facility at each plant site and that each plant site has only one respondent (i.e., the 
2

owner/operator of the plant site).

Over the next three years, approximately 42 respondents per year will be subject to these

standards, and one additional respondents per year will become subject to these same standards.

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 

Administrator determines has been adequately demonstrated.

Section 111(a)(l).

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

111 also requires that the Administrator review and, if appropriate, revise such standards every 

eight years. In addition, section 114(a) states that the Administrator may require any 

owner/operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, VOC emissions from coating lines used in the 

manufacture of pressure sensitive tape and label materials either cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, 

the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart RR.
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2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

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

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

ensure compliance with these standards 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 these standards are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and that the standards 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. 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) 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 (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register. 
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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 these standards, is the Integrated Compliance Information System (ICIS). ICIS is 

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

industrial- and government-owned facilities. The growth rate for the industry is based on our 

consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity 

to comment on the burden associated with these standards as they were being developed. In 

developing this ICR, we contacted: 1) the Pressure Sensitive Tape Council (PSTC), at (630) 544-

5048; 2) the American Forest and Paper Association, at (202) 463-2436; and 3) the Adhesive and 

Sealant Council, at (301) 986-9700.

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.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).
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3(g) Sensitive Questions

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 owners and 

operators of coating lines used in the manufacture of pressure sensitive tape and label materials.

The United States Standard Industrial Classification (SIC) code for the respondents affected by 

the standards is SIC 2672, which corresponds to the North American Industry Classification 

System (NAICS) 322220 for Paper Bag and Coated and Treated Paper Manufacturing.

4(b) Information Requested

(i) Data Items

In 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).

A source must make the following reports:

Notifications

Notification of construction/reconstruction 60.7(a)(1)

Notification of actual startup 60.7(a)(3)

Notification of physical or operational change 60.7(a)(4)

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

Initial performance test 60.8(d)

Reports

Initial performance test results 60.8(a), 60.447(a)

Excess emissions report 60.7(c-d), 60.447(bc)
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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 gas temperature for facility 

using a thermal incineration solvent destruction device 60.445(e)

Maintain continuous record of upstream and downstream 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 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.

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.
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Respondent Activities

Perform initial performance test, Reference Method 24 and 25 test, 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

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 Enforcement and Compliance History Online (ECHO) 

and ICIS. 

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 
8

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

emission standards, and note the operating conditions under which compliance was achieved.

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

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 both 

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 two 

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.

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 12 facilities. 

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

entities during the development of this rule (see BID document: EPA-450/3-80-003a, p. 8-30).

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost – NSPS for Pressure Sensitive 

Tape 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 applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with 
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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

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 3,970 (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 NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $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(s) and other costs such as photocopying and postage.
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(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 42 $75,600

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

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

above table. 

The total operation and maintenance (O&M) costs for this ICR are $75,600. 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 $82,600.

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 such activities 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 

$15,600.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

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 – NSPS for Pressure 

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

41 existing respondents will be subject to these standards. It is estimated that an additional one

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

in the table below, is 42 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 1 40 0 N/A 41

2 1 41 0 N/A 42

3 1 42 0 N/A 43

Average 1 41 0 N/A 42

1 New respondents include sources with constructed, reconstructed and modified 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 42. 

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

Notification of actual startup 1 1 N/A 1

Notification of initial 

performance test 1 1 N/A 1

Report of performance test and 

repeat performance test 1.2 1 N/A 1.2
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Total Annual Responses

VOC Emission Reports 42 2 N/A 84

Temperature Reports 1 33.6 2 N/A 67.2

Total 155.4

1 We have assumed that 80 percent of sources will use incineration to control emissions (42x0.8=33.4).

The number of Total Annual Responses is 155.

The total annual labor costs are $399,000. 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 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 3,970 hours. Details regarding these estimates may be 

found in Table 1: Annual Respondent Burden and Cost – NSPS for Pressure Sensitive Tape and 

Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (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 26 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $82,600. 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 343

labor hours at a cost of $15,600. See 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).
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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 burden from the previous ICR, including increases 

in the respondent labor hours, O&M cost, and number of responses. This is due to an increase 

in the estimated number of sources subject to the standard. In this ICR, we assume the industry 

continues to grow at a rate of one new source per year. Additionally, there is a small change in 

the assumption where we assume all existing sources will need to re-familiarize with the 

regulatory requirements each year. This change in assumption also contributes to the increase 

in respondent labor hours. 

6(g) Burden Statement

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

is estimated to average 26 hours per response. “Burden” means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

either 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 

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), WJC West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 
14

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-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.
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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) 

Personhours 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 

personhours per 

year 

(Ex0.05) 

(G) 

Clerical 

personhours per 

year 

(Ex0.1) 

(H) 

Total costs per 

Year b  

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Familiarization with the regulatory requirements c 0.87 1 0.87 42 36.54 1.83 3.65 $4,225.69 

B. Required activities

Initial performance test 52.17 1 52.17 1 52.17 2.61 5.22 $6,033.23 

Repeat performance test d 52.17 1 52.17 0.2 10.43 0.52 1.04 $1,206.65 

C. Create information See 3b

D. Gather existing information See 3e

E. Write report

Notification of construction/reconstruction 1.74 1 1.74 1 1.74 0.09 0.17 $201.22 

Notification of actual startup 1.74 1 1.74 1 1.74 0.09 0.17 $201.22 

Notification of initial performance test 1.74 1 1.74 1 1.74 0.09 0.17 $201.22 

Report of performance test See 3b

Excess emission reports

 VOC emission reports e 4.35 2 8.7 42 365.4 18.27 36.54 $42,256.87 

 Temperature reports f 3.48 2 6.96 33.6 233.856 11.69 23.39 $27,044.39 

Subtotal for Reporting Requirements 809 $81,370.49

4. Recordkeeping Requirements

A. Familiarization with the regulatory requirements See 3a

B. Plan activities See 4c

C. Implement activities See 3b
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Burden item

(A) 

Personhours 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 

personhours per 

year 

(Ex0.05) 

(G) 

Clerical 

personhours per 

year 

(Ex0.1) 

(H) 

Total costs per 

Year b  

 Monthly performance test g 0.87 12 10.44 42 438.48 21.924 43.848 $50,708.24 

D. Develop record system N/A

D. Develop record system N/A

E. Time to enter information 

 Records of operating parameters h 0.22 250 55 42 2,310 115.5 231 $267,141.11 

F. Train personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 3,161 $317,849.34

TOTAL LABOR BURDEN AND COST (rounded) i 3,970 $399,000

Capital and O&M Cost (see Section 6(b)(iii)): i $82,600

TOTAL COST: i $482,000

Assumptions:

a

 We have assumed that the average number of respondents potentially subject to this rule is 42. There will be one additional new source over the three-year 

period of this ICR.

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 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

 The excess VOC emissions reports are submitted on a quarterly basis. If no excess emissions occur, the reports are submitted semiannually. We assume 

semiannual submission of such reports. 

f

 We have assumed that 80 percent of sources will use incineration to control emissions.

g We assume that each respondent will take 0.87 hours once per month to record performance test.
17

h

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

i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
18

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 

personhours per 

occurrence 

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year 

(C=AxB) 

(D) 

Plants 

per Year 

a

 

(E) 

Technical 

personhours per 

year 

(E=CxD) 

(F) 

Management 

person-hours 

per year 

(Ex0.05) 

(G) 

Clerical 

personhours per 

year 

(Ex0.1) 

(H) 

Total 

Cost, $ b

New facility

Initial performance test 20.87 1 20.87 1 20.87 1.04 2.09 $1,092.34 

Repeat performance test/observed 20.87 1 20.87 0.2 4.17 0.21 0.42 $218.47 

Review reports c

Notification of construction 1.74 1 1.74 1 1.74 0.09 0.17 $91.07 

Notification of initial startup 0.43 1 0.43 1 0.43 0.02 0.04 $22.51 

Notification of actual startup 0.43 1 0.43 1 0.43 0.02 0.04 $22.51 

Notification of initial performance test 0.43 1 0.43 1 0.43 0.02 0.04 $22.51 

Review test results 6.96 1 6.96 1 6.96 0.35 0.70 $364.29 

Existing Plant 

VOC emission reports d 1.74 2 3.48 42 146.16 7.31 14.62 $7,650.01 

Temperature reports e, f 1.74 2 3.48 33.6 116.93 5.85 11.69 $6,120.01 

TOTAL ANNUAL BURDEN AND COST (rounded) g 343 $15,600 

Assumptions:

a

 We have assumed that the average number of respondents potentially subject to this rule is 42. 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 $46.67 

(GS-12, Step 1, $29.17 + 60%);

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that
19

Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2016 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 each source submits these reports semiannually.

e We assume that 80 percent of sources use incineration.

f

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

g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.