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 S tandards (NSPS) for Pressure Sensitive Tape and L abel

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. E xisting 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 NSP S 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.

An y 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 delegate d 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). T he Federal Government ’s burden is

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

may be found be low 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

affec ted facilit y at each plant site and that each plant site has only one respondent (i.e., the2

owner/operator of the plant site).

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

standard s , and one additional responde nts per year will become subject to the se same standard s

.

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 such standards eve ry 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 monito ring 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) ke ep 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

.3

2(b) Practical Utility/Users of the Data

The rec ordkeeping 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 standard s . Continuous emission monitors are used to

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

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

determine compliance in place of a continuous emission monitor.

The notifications required in the se standard s are used to inform the Age ncy 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 standard s 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 an d reporting are required under 40 CFR Part 60, Subpart

RR

.

3(a) Non

- duplication

If the subject standards have not been delega ted, 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 stan dards, 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

.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

p rovisions in the se standard s , 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 ind ustry 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 th es e standard s as they were being develop ed. 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 Collect ion

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 maintena nce 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 li kely.

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.

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).5

3(g) Sensitive Questions

T he reporting or recordkeeping requirements in the standard do not include sensitive

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are 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

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

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

A source must make the following reports:

Notification s

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)

Reports

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

Excess emissions report 60.7(c

- d ), 60.447(b

c)6

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 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 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.

(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.7

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, a cquiring, 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. Performance8

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

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

Data and records maintained by th e 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. IC IS 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 analyz e 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 requireme nts 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 1 2 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 inform ation 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 with9

the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and

major assumptions have been identified. Responses to this info rmation 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 averag e annual burden to industry over the next three years from these recordkeeping

and reporting requirement s is estimated to be 3,970 ( Total Labor Hours from Table 1). T hese

hours are based on Agency studies and background documen ts from the development of th e 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 $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 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 t ype 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 c osts 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

.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)

Temperature $7

, 000 1 $7,000 $1,800 42 $7 5

, 6 00

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 o f 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 i ncludes such activities a s the

examination of records maint ained by the respondents, periodic inspection of sources of

emissions, and the publication and distribution of collected information.

The average annu al 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 $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 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 go vernment 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).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

41 existing respondents will be subject to the se standard s

. It is estimated that an additional one respondent per year w ill become subject. The overall average number of responden ts, 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.

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 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 .212

Total Annual Responses

VOC Emission Reports 42 2 N/A 84

Temperature Reports 1 33.6 2 N/A 67.2

Total 1 55.4

1 We have assumed that 80 percent of sources will use incineration to control emissions (42x 0 .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 C oating 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 summariz ed below.

(i) Respondent Tally

The total annual labor hours are 3,970 hours

. Details regarding these estimates may be

found 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).

W e 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 req uired 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 a verage 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).13

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 t o 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 in structions 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 spo nsor, 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 fo r 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

- 201 2

- 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 comment s, 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 Roo m is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal14

holidays. 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

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

- 20 12

- 0643 and OMB Control Number 2060

- 0004 in any

corre spondence.

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 Pressure Sensitive Tape and Label Surface Coating Operations (40

CFR Part 60 , Subpart RR ) (Renewal)

Burden item (A)

Person

hours per

occurrence (B)

No. of

occurrences

per

respondent

per year

(C)

Person

- hours

per
respondent

per year
(C=AxB) (D)

Respondents

per year a (E)

Technical

person

hours per

year
(E=CxD) (F)

Management

person

hours per

year
(Ex0.05) (G)

Clerical

person

hours 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 3b16

Burden item (A)

Person

hours per

occurrence (B)

No. of

occurrences

per

respondent

per year

(C)

Person

- hours

per
respondent

per year
(C=AxB) (D)

Respondents

per year a (E)

Technical

person

hours per

year
(E=CxD) (F)

Management

person

hours per

year
(Ex0.05) (G)

Clerical

person

hours 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 20 14, Table 2. Civilian Workers, by

occupatio nal and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110 percent to ac count for the benefit

packages available to those employed by private industry.

c We have assumed that it will take 0.87 hours fo r 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 incineratio n 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 roun ded 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

person

hours per

occurrence (B)

No. of

occurrences

per plant

per year (C)

EPA

person

hours per

plant per

year

(C=AxB)

(D)

Plants

per Year

a (E)

Techni cal

person

hours per

year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

hours 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 agenc ies, 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 that19

Managerial hours ar e 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2016 Gen eral

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.