PART
A
OF
THE
SUPPORTING
STATEMENT
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
Metal
Coil
Surface
Coating
Plants."
This
is
a
new
ICR
and
an
EPA
tracking
number
is
1957.02.

(
b)
Short
Characterization.

Respondents
are
owners
or
operators
of
89
existing
metal
coil
surface
coating
plants.
Respondents
subject
to
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
are
required
by
law
(
40
CFR
Part
63,
Subpart
A)
to
submit
one­
time
notifications
and
one­
time
reports
on
compliance
status
and
performance
test
results.
Respondents
also
must
develop
and
implement
a
Startup,
Shutdown,
and
Malfunction
Plan
and
make
semiannual
reports
if
an
event
is
inconsistent
with
the
plan.

Semiannual
reports
are
required
for
periods
of
operation
during
which
measured
emissions
exceed
an
applicable
limit
or
control
device
operating
parameters
are
outside
of
the
established
ranges.
General
recordkeeping
requirements
applicable
to
all
NESHAP
require
records
of
applicability
determinations;
test
results;
startup,
shutdown,
or
malfunction
events;
exceedances;

performance
test
reports,
monitoring
records,
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
2
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
major
sources,
identify
any
non­
major
sources
not
subject
to
the
standards,
and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
MACT
standards
are
being
achieved.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.

(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new
or
reconstructed
sources
subject
to
the
standards;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Based
on
the
reported
information,
EPA
can
decide
which
plants,

records,
or
processes
should
be
inspected.

3.
Nonduplication,
Consultation,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
computer
search
of
the
Federal
Information
Locator
System
indicated
that,
with
the
exception
of
the
existing
New
Source
Performance
Standard
(
NSPS)
for
Metal
Coil
Surface
Coating
Plants
(
40
CFR
Part
60,
Subpart
TT),
there
are
no
similar
information
requests
being
carried
out
by
the
Federal
government.
A
similar
search
of
EPA's
ongoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.
The
NSPS
and
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.

This
section
is
not
applicable
because
this
is
a
rulerelated
ICR.

(
c)
Consultations.

The
standard
was
developed
under
EPA's
MACT
Partnership
program
for
regulatory
development.
Under
this
approach,
EPA
3
works
with
State
regulatory
agencies
and
tribal
governments
to
discuss
major
issues
while
working
in
a
cooperative
effort
with
industry
and
professional
organizations
to
identify
data
needs
and
to
collect,
exchange,
and
analyze
the
information
and
data.

For
example,
on
this
project,
several
meetings
with
State
partners
and
industry
representatives
(
including
the
National
Coil
Coaters
Association,
the
Steel
Decking
Institute,
and
the
Aluminum
Association)
were
held
in
the
period
leading
to
proposal.
No
major
problems
regarding
monitoring,
recordkeeping,

or
reporting
procedures
were
encountered
nor
were
major
issues
raised
regarding
these
procedures
in
comments
on
the
proposed
standards.
The
non­
EPA
persons
consulted
prior
to
proposal
of
the
standards
are
identified
in
Table
1.

TABLE
1.
PERSONS
CONSULTED
ON
THE
PROPOSED
INFORMATION
COLLECTION
ACTIVITIES
Contact
Organization
Telephone
Number
Greg
Gemgnani
National
Coil
Coaters
Association
(
610)
797­
5200
Peter
Kehays
Steel
Decking
Institute
(
908)
735­
9049
Bob
Strieter
Aluminum
Association
(
202)
862­
5132
(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,

EPA
would
not
be
reasonably
assured
that
a
plant
is
in
compliance
with
the
standards.

(
e)
General
Guidelines.

None
of
the
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
f)
Confidentiality.

All
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
4
B
­­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
28,

1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,

1979).

(
g)
Sensitive
Questions.

This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Codes.

Respondents
are
owners
or
operators
of
new
or
existing
metal
coil
surface
coating
facilities.
The
primary
SIC
code
for
the
respondents
affected
by
the
standards
is
3479.

(
b)
Information
Requested.

(
i)
Data
items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
proposed
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
standards
are
identified
in
Table
2
and
introduced
in
Section
6(
a).

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
3
and
introduced
in
Section
6(
c).

(
b)
Collection
Methodology
and
Management.

This
section
is
not
relevant
to
this
information
collection
request.

(
c)
Small
Entity
Flexibility.

Nineteen
existing
metal
coil
coating
companies
are
classified
as
small
entities.
The
EPA
does
not
expect
that
any
metal
coil
surface
coating
plants
subject
to
the
standards
would
experience
adverse
impacts.
The
ICR
requirements
are
the
minimum
necessary
to
demonstrate
compliance.

(
d)
Collection
Schedule.
5
Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Compliance
Data
System
operated
and
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
enforcement
and
compliance
programs.
A
schedule
for
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
and
recordkeeping
are
triggered
by
action
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
annual
burden
estimates
for
reporting
and
recordkeeping
are
presented
in
Table
2.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

Since
this
rule
does
not
require
any
continuous
emission
monitoring
or
electronic
data
submittal,
the
only
capital
costs
associated
with
reporting
and
recordkeeping
activities
are
expected
to
be
associated
with
performance
testing
by
outside
parties.
It
is
assumed
that
all
Metal
Coil
Surface
Coating
facilities
will
contract
a
testing
company
to
provide
sampling
and
analytical
services
required
to
demonstrate
that
emission
control
systems
achieve
the
required
emission
reductions.

Estimates
for
these
costs
were
taken
from
the
ESD
Regulatory
Procedures
Manual
(
Volume
X,
Sec.
2.2,
Table
4.
Burden
of
Performance
Tests
and
Continuous
Monitoring
System
(
CMS)

Demonstrations.
October
1990.)

The
only
continuous
monitoring
requirements
for
Metal
Coil
Surface
Coating
facilities
are
for
parametric
monitoring
of
control
device
operating
parameters
at
facilities
achieving
compliance
through
the
use
of
control
devices.
These
systems
are
already
in
place,
therefore
no
new
equipment
would
be
required
by
the
recordkeeping
and
reporting
requirements.

The
information
collection
activities
for
sources
subject
to
the
standards
are
presented
in
Table
2.
Because
much
of
the
data
6
are
already
collected
by
respondents
or
required
by
existing
law,

minimal
respondent
development
costs
are
associated
with
the
information
collection
activities
for
the
standards.
Labor
rates
and
associated
costs
are
based
on
the
U.
S.
Department
of
Labor
Bureau
of
Labor
Statistics
(
BLS)
Employer
Costs
for
Employee
Compensation
report
(
March
1999,
Table
12),
and
estimated
hourly
rates
are
as
follows:
technical
at
$
31.68,
management
at
$
48.08,

and
clerical
at
$
19.13.
The
BLS
costs
include
fringe
benefits
and
a
factor
of
10
percent
has
been
added
to
account
for
overhead/
profit.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
the
MACT
standards,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program,
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Table
3.
Labor
rates
and
associated
costs
are
based
on
the
U.
S.
Department
of
Labor
Bureau
of
Labor
Statistics
Employment
Cost
Trends
report
(
June
1999,
Table
4),
and
estimated
hourly
rates
are
as
follows:

technical
at
$
22.88,
management
at
$
35.08,
and
clerical
at
$
17.88.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.
7
The
EPA
estimates
that
89
facilities
will
provide
the
onetime
notifications
and
semi­
annual
reports
during
the
period
covered
by
this
ICR.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.
The
total
labor
burden
is
provided
in
Table
2
and
is
estimated
as
281
hours/
year
per
facility.
The
total
cost
of
reporting
and
recordkeeping,
given
in
Table
2,
is
$
8,810/
year
per
facility.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
2,
and
summarized
in
Table
4,

are
calculated
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
The
estimated
total
nationwide
burden
for
regulated
major
sources
in
the
first
three
years
of
the
Metal
Coil
Surface
Coating
NESHAP
would
be
an
estimated
25,048
total
labor
hours
per
year
at
a
cost
of
$
784,210
per
year
for
major
sources.
The
total
annual
hours
are
281
hours/
year
per
facility.

The
total
annualized
capital
and
startup
cost
reflects
the
estimated
capital
costs
for
equipment
required
to
comply
with
recordkeeping
and
reporting
activities
associated
with
the
major
source
provisions
of
the
proposed
standards.
There
are
not
expected
to
be
any
capital
costs
resulting
from
this
rule
for
existing
major
sources
except
those
associated
with
performance
testing
by
outside
parties
(
as
described
in
Section
6b),
because
operating
parameter
monitoring
devices
are
an
integral
part
of
the
existing
control
devices,
and
there
are
no
capital
costs
associated
with
the
recordkeeping
used
to
demonstrate
compliance
through
the
use
of
compliant
coatings.
Because
there
are
no
requirements
in
the
rule
for
continued
performance
tests
after
the
initial
one,
costs
associated
with
performance
testing
were
distributed
over
the
expected
life
of
the
control
equipment
(
15
years)
at
7
percent
interest.
This
resulted
in
annualized
capital/
startup
costs
of
$
232,080.
8
The
total
annual
estimated
operating
and
maintenance
costs
(
O&
M)
were
calculated
based
on
the
estimated
storage,
filing,

photocopying,
and
postage
costs
for
the
241
estimated
total
annual
responses
associated
with
the
provisions
of
the
Metal
Coil
Surface
Coating
NESHAP.
Storage,
filing,
and
photocopying
costs
per
response
were
estimated
as
0.5
hour
of
clerical
labor
at
a
rate
of
$
19.13/
hr
per
response
for
multiple
copies.
First
class
postage
was
estimated
at
$
6.94
per
response
for
mailing
of
a
one
pound
package
and
two
half­
pound
packages
to
regulatory
agencies.

The
postage
rates
were
based
on
data
from
U.
S.
Postal
Services
Internet
web
site
(
http://
www.
usps.
com/),
accessed
December
13,

1999.
Thus,
the
total
storage,
filing,
photocopying,
and
postage
cost
per
response
was
$
16.51,
for
an
annual
estimated
total
of
$
4020.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
3,
are
calculated
as
in
the
respondent
table,
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
total
annual
hours
are
4453
hours/
year.
The
total
annual
cost
is
$
103,450/
year.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
ICR.

(
g)
Burden
Statement
The
average
annual
respondent
burden
for
each
of
the
89
metal
coil
coating
plants
is
estimated
as
281
hours.
This
estimate
includes
time
for
preparing
and
submitting
notices,

gathering
information
(
e.
g.,
conducting
emission
performance
tests),
submitting
reports,
and
maintaining
records.

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
9
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
10
TABLE
2A.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
FIRST
YEAR
AFTER
PROMULGATION
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
80
0.11
b
8.8
49
c
431.2
21.56
43.12
15522
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
89
356
17.8
35.6
12815
B.
Required
activities
Initial
oxidizer
performance
test
280
0.11
b
30.8
65
d
2002
100.1
200.2
72066
Repeat
oxidizer
performance
test
280
0.11
b
30.8
13
e
400.4
20.02
40.04
14413
Initial
capture
performance
test
215
0.11
b
23.65
84
f
1986.6
99.33
198.66
71512
Repeat
capture
performance
test
215
0.11
b
23.65
16.8
e
397.32
19.866
39.732
14302
Emission
rate
limit
compliance
determination
16
0
0
0
0
0
0
0
Startup,
shutdown,
malfunction
plan
40
1
40
49
c
1960
98
196
70554
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Initial
notification
2
1
2
89
178
8.9
17.8
6407
Notification
of
constr./
reconstr.
2
1
2
1
2
0.1
0.2
72
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
11
Notification
of
anticipated
startup
2
1
2
1
2
0.1
0.2
72
Notification
of
actual
startup
2
1
2
1
2
0.1
0.2
72
Compliance
status
notification
4
1
4
89
356
17.8
35.6
12815
Performance
test
notification
2
0.11
b
0.22
49
c
10.78
0.539
1.078
388
Performance
test
report
40
0.11
b
4.4
49
c
215.6
10.78
21.56
7761
Report
of
monitoring
exceedances
16
2
g
32
4.9
h
156.8
7.84
15.68
5644
Report
of
no
excess
emissions
8
2
g
16
44.1
i
705.6
35.28
70.56
25399
Startup,
shutdown,
malfunction
report
8
2
g
16
4.9
j
78.4
3.92
7.84
2822
Report
operating
and
maintenance
0.5
4.3
k
2.15
89
NA
l
NA
l
195.8
l
6431
m
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4B
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
4
52
208
49
c
10192
509.6
1019.2
366881
F.
Time
to
train
personnel
N/
A
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
transmit
or
disclose
information
0.25
2
0.5
49
c
24.5
1.225
2.45
882
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
12
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
19457
973
2142
706830
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
31.68,
management
at
$
48.08,
and
clerical
at
$
19.13.

b
Occurs
one
time
during
first
3
years
of
standard.
Results
in
one­
time
start­
up
costs
associated
with
initial
compliance
determination
and
acquisition,
installation
and
utilization
of
technology
and
systems
needed
to
support
record
keeping
and
reporting.
The
one­
time
start­
up
costs
are
amortized
over
the
15­
year
life
of
control
equipment
at
7%
interest.

For
computational
purposes,
the
number
of
occurrences
per
respondent
per
year
is
amortized
over
15
years.

c
Represents
number
of
facilities
already
reporting
compliance
with
proposed
emission
limits.

d
Assumes
facilities
already
reporting
98
percent
overall
control
efficiency
will
choose
to
demonstrate
compliance
by
conducting
initial
oxidizer
performance
tests
during
the
first
year
after
promulgation,
requiring
performance
tests
on
65
oxidizers.
Assumes
facilities
requiring
replacements
or
upgrades
will
act
in
year
three.

e
Assumes
20
percent
of
the
respondents
repeat
performance
test.

f
Assumes
facilities
already
reporting
98
percent
overall
control
efficiency
will
chose
to
demonstrate
compliance
by
conducting
initial
capture
performance
tests
during
the
first
year
after
promulgation,
requiring
performance
tests
on
84
coating
rooms.
Assumes
facilities
requiring
replacements
or
upgrades
will
act
in
year
three.

g
Assumes
semiannual
reports
are
required.

h
Assumes
10
percent
of
respondents
for
first
year
after
promulgation
fail
to
meet
the
standard.

i
Assumes
90
percent
of
respondents
for
first
year
after
promulgation
meet
the
standard.

j
Assumes
10
percent
must
file
startup,
shutdown,
malfunction
report.

k
Average
number
of
reports
submitted
per
respondent
in
the
first
year.

l
Assumes
storage,
filing,
and
photocopying
of
reports
are
performed
by
clerical
staff.

m
Cost
includes
clerical
labor
and
first
class
postage
of
$
16.51
per
response.

N/
A
=
Not
Applicable.
13
TABLE
2B.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
SECOND
YEAR
AFTER
PROMULGATION
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
80
0.11
b
8.8
49
c
431.2
21.56
43.12
15522
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
0
0
0
0
0
B.
Required
activities
Initial
oxidizer
performance
test
280
0.11
b
30.8
65
d
2002
100.1
200.2
72066
Repeat
oxidizer
performance
test
280
0.11
b
30.8
13
e
400.4
20.02
40.04
14413
Initial
capture
performance
test
215
0.11
b
23.65
84
f
1986.6
99.33
198.66
71512
Repeat
capture
performance
test
215
0.11
b
23.65
16.8
e
397.32
19.866
39.732
14302
Emission
rate
limit
compliance
determination
16
0
0
0
0
0
0
0
Startup,
shutdown,
malfunction
plan
40
1
40
0
0
0
0
0
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Initial
notification
2
1
2
0
0
0
0
0
Notification
of
constr./
reconstr.
2
1
2
1
2
0.1
0.2
72
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
14
Notification
of
anticipated
startup
2
1
2
1
2
0.1
0.2
72
Notification
of
actual
startup
2
1
2
1
2
0.1
0.2
72
Compliance
status
notification
4
1
4
0
0
0
0
0
Performance
test
notification
2
0.11
b
0.22
49
10.78
0.539
1.078
388
Performance
test
report
40
0.11
b
4.4
49
215.6
10.78
21.56
7761
Report
of
monitoring
exceedances
16
2
g
32
4.9
h
156.8
7.84
15.68
5644
Report
of
no
excess
emissions
8
2
g
16
44.1
i
705.6
35.28
70.56
25399
Startup,
shutdown,
malfunction
report
8
2
g
16
4.9
j
78.4
3.92
7.84
2822
Report
operating
and
maintenance
0.5
2.3
k
1.15
49
NA
l
NA
l
58.8
l
1,895
m
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4B
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
4
52
208
49
c
10192
509.6
1019.2
366881
F.
Time
to
train
personnel
N/
A
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
transmit
or
disclose
information
0.25
2
0.5
49
c
24.5
1.225
2.45
882
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
15
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
16607
830
1720
599710
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
31.68,
management
at
$
48.08,
and
clerical
at
$
19.13.

b
Occurs
one
time
during
first
3
years
of
standard.
Results
in
one­
time
start­
up
costs
associated
with
initial
compliance
determination
and
acquisition,
installation
and
utilization
of
technology
and
systems
needed
to
support
record
keeping
and
reporting.
The
one­
time
start­
up
costs
are
amortized
over
the
15­
year
life
of
control
equipment
at
7%
interest.

For
computational
purposes,
the
number
of
occurrences
per
respondent
per
year
is
amortized
over
15
years.

c
Represents
number
of
facilities
already
reporting
compliance
with
proposed
emission
limits.

d
Assumes
no
facilities
will
choose
to
demonstrate
compliance
by
conducting
initial
oxidizer
performance
tests
in
year
two;
includes
amortized
costs
for
initial
oxidizer
performance
tests
conducted
in
year
one.

e
Assumes
20
percent
of
the
respondents
repeat
performance
test.

f
Assumes
no
facilities
will
choose
to
demonstrate
compliance
by
conducting
initial
capture
performance
tests
in
year
two;
includes
amortized
costs
for
initial
capture
performance
tests
conducted
in
year
one.

g
Assumes
semiannual
reports
are
required.

h
Assumes
10
percent
of
respondents
for
second
year
after
promulgation
fail
to
meet
the
standard.

i
Assumes
90
percent
of
respondents
for
second
year
after
promulgation
meet
the
standard.

j
Assumes
10
percent
must
file
startup,
shutdown,
malfunction
report.

k
Average
number
of
reports
submitted
per
respondent
in
the
second
year.

l
Assumes
storage,
filing,
and
photocopying
of
reports
are
performed
by
clerical
staff.

m
Cost
includes
clerical
labor
and
first
class
postage
of
$
16.51
per
response.

N/
A
=
Not
Applicable.
16
TABLE
2C.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
THIRD
YEAR
AFTER
PROMULGATION
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
80
0.11
b
8.8
76
c
668.8
33.44
66.88
24075
4.
Reporting
Requirements
A.
Read
instructions
4
1
4
0
0
0
0
0
B.
Required
activities
Initial
oxidizer
performance
test
280
0.11
b
30.8
100
d
3080
154
308
110871
Repeat
oxidizer
performance
test
280
0.11
b
30.8
18.8
e
579.04
28.952
57.904
20844
Initial
capture
performance
test
215
0.11
b
23.65
133
f
3145.45
157.2725
314.545
113227
Repeat
capture
performance
test
215
0.11
b
23.65
26.6
e
629.09
31.4545
62.909
22645
Emission
rate
limit
compliance
determination
16
12
192
11
2112
105.6
211.2
76026
Startup,
shutdown,
malfunction
plan
40
1
40
27
1080
54
108
38877
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Initial
notification
2
1
2
0
0
0
0
0
Notification
of
constr./
rrconstr.
2
1
2
1
2
0.1
0.2
72
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
17
Notification
of
anticipated
startup
2
1
2
1
2
0.1
0.2
72
Notification
of
actual
startup
2
1
2
1
2
0.1
0.2
72
Compliance
status
notification
4
1
4
0
0
0
0
0
Performance
test
notification
2
0.11
b
0.22
76
16.72
0.836
1.672
602
Performance
test
report
40
0.11
b
4.4
76
334.4
16.72
33.44
12037
Report
of
monitoring
exceedances
16
2
g
32
7.6
h
243.2
12.16
24.32
8754
Report
of
no
excess
emissions
8
2
g
16
68.4
i
1094.4
54.72
109.44
39395
Startup,
shutdown,
malfunction
report
8
2
g
16
7.6
j
121.6
6.08
12.16
4377
Report
operating
and
maintenance
0.5
2.95
k
1.5
76
NA
l
NA
l
114
l
3,737
m
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4B
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
all
info.
required
by
standards
4
52
208
76
15808
790.4
1580.8
569041
F.
Time
to
train
personnel
N/
A
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
transmit
or
disclose
information
0.25
2
0.5
76
38
1.9
3.8
1368
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
a
18
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
28957
1448
3010
1046090
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
31.68,
management
at
$
48.08,
and
clerical
at
$
19.13.

b
Occurs
one
time
during
first
3
years
of
standard.
Results
in
one­
time
start­
up
costs
associated
with
initial
compliance
determination
and
acquisition,
installation,
and
utilization
of
technology
and
systems
needed
to
support
record
keeping
and
reporting.
The
one­
time
start­
up
costs
are
amortized
over
the
15­
year
life
of
control
equipment
at
7%
interest.

For
computational
purposes,
the
number
of
occurrences
per
respondent
per
year
is
amortized
over
15
years.

c
Thirteen
facilities
are
permitted
as
synthetic
minors
and
therefore
are
not
subject
to
the
emission
limits
in
the
standard.

d
Assumes
facilities
requiring
replacements
or
upgrades
will
choose
to
demonstrate
compliance
by
conducting
initial
oxidizer
performance
tests
during
the
third
after
promulgation,

requiring
performance
tests
on
100
oxidizers;
includes
amortized
costs
for
initial
oxidizer
performance
tests
conducted
in
year
one.

e
Assumes
20
percent
of
the
respondents
repeat
performance
tests.

f
Assumes
facilities
requiring
replacements
or
upgrades
will
choose
to
demonstrate
compliance
by
conducting
initial
capture
performance
tests
during
the
third
year
after
promulgation,
requiring
performance
tests
on
133
coating
rooms;
includes
amortized
costs
for
initial
capture
performance
tests
conducted
in
year
one.

g
Assumes
semiannual
reports
are
required.

h
Assumes
10
percent
of
respondents
for
third
year
after
promulgation
fail
to
meet
the
standard.

i
Assumes
90
percent
of
respondents
for
third
year
after
promulgation
meet
the
standard.

j
Assumes
10
percent
must
file
startup,
shutdown,
malfunction
report.

k
Average
number
of
reports
submitted
per
respondent
in
the
third
year.

l
Assumes
storage,
filing,
and
photocopying
of
reports
are
performed
by
clerical
staff.

m
Cost
includes
clerical
labor
and
first
class
postage
of
$
16.51
per
response.

N/
A
=
Not
Applicable.
19
TABLE
3A.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
FINAL
STANDARD
FIRST
YEAR
AFTER
PROMULGATION
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
test
495
495
4.9b
2425.5
121.275
242.55
64087
Repeat
performance
test­
Retesting
preparation
4
4
4.9c
19.6
0.98
1.96
518
Repeat
performance
­
Retesting
495
495
4.9c
2425.5
121.275
242.55
64087
Litigation
2080
2080
0.49d
1019.2
50.96
101.92
26929
Excess
Emissions
Enforcement
Activities
120
120
4.9e
588
29.4
58.8
15536
Report
Review
Notification
of
applicability
Notification
of
constr./
reconstr.

Notification
of
anticipated
startup
Notification
of
actual
startup
Notification
of
special
compliance
requirements
Notification
of
initial
performance
test
Notification
of
compliance
status
Review
of
initial
performance
test
report
Review
of
repeat
performance
test
report
Review
of
excess
emissions
report
Review
of
no
excess
emissions
report
Review
of
NESHAP
waiver
application
Review
of
startup,
shutdown,
malfunction
report
2
2
2
2
N/
A
2
2
8
8
8
2
N/
A
2
2
2
2
2
2
2
8
8
8
2
2
89
1
1
1
49
89
49
4.9
4.9
44.1
f
9.8
g
178
2
2
2
98
178
392
39.2
39.2
88.2
19.6
8.9
0.1
0.1
0.1
4.9
8.9
19.6
1.96
1.96
4.41
0.98
17.8
0.2
0.2
0.2
9.8
17.8
39.2
3.92
3.92
8.82
1.96
4,703
53
53
53
2,589
4,703
10,357
1,036
1,036
2,330
518
TOTAL
BURDEN
AND
COST
(
SALARY)
7516
376
752
198,588
Travel
Expenses
for
Tests
Attended
(
1
person
x
4.9
plants/
yr
x
1
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
4.9
round
trips/
yr)
=
$
2205
TOTAL
ANNUAL
COST
$
198,588
+
$
2205
=
$
200,790
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
22.88,
management
at
$
35.08,
and
clerical
at
$
17.88.

b
Assume
EPA/
State
personnel
will
attend
10
percent
of
the
performance
tests
at
the
total
of
49
plants
(
0.1
x
49
=
4.9).

c
Assume
20
percent
fail
the
initial
performance
test
and
half
repeat
the
performance
test
(
0.2
x
49/
2).

d
One
plant
in
100
will
be
involved
in
litigation
(
0.01
x
49
=
0.49).

e
Assume
10
percent
of
the
49
plants
(
4.9)
have
excess
emissions.

f
Assume
90
percent
of
the
49
plants
(
44.1)
do
not
have
excess
emissions.
20
g
Assumes
20
percent
of
the
plants
per
year
(
9.8)
will
report
a
startup,
shutdown,
malfunction
incident.
21
TABLE
3B.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
FINAL
STANDARD
SECOND
YEAR
AFTER
PROMULGATION
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
test
495
495
0b
0
0
0
0
Repeat
performance
test­
Retesting
preparation
4
4
0c
0
0
0
0
Repeat
performance
­
Retesting
495
495
0c
0
0
0
0
Litigation
2080
2080
0d
0
0
0
0
Excess
Emissions
Enforcement
Activities
120
120
0e
0
0
0
0
Report
Review
Notification
of
applicability
Notification
of
constr./
reconstr.

Notification
of
anticipated
startup
Notification
of
actual
startup
Notification
of
special
compliance
requirements
Notification
of
initial
performance
test
Notification
of
compliance
status
Review
of
initial
performance
test
report
Review
of
repeat
performance
test
report
Review
of
excess
emissions
report
Review
of
no
excess
emissions
report
Review
of
NESHAP
waiver
application
Review
of
startup,
shutdown,
malfunction
report
2
2
2
2
N/
A
2
2
8
8
8
2
N/
A
2
2
2
2
2
2
2
8
8
8
2
2
0
1
1
1
0
0
0
0
4.9
44.1f
9.8g
0
2
2
2
0
0
0
0
39.2
88.2
19.6
0
0.1
0.1
0.1
0
0
0
0
1.96
4.41
0.98
0
0.2
0.2
0.2
0
0
0
0
3.92
8.82
1.96
0
53
53
53
0
0
0
0
1,036
2,330
518
TOTAL
BURDEN
AND
COST
(
SALARY)
153
8
15
4,043
Travel
Expenses
for
Tests
Attended
(
1
person
x
0
plants/
yr
x
1
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
0
round
trips/
yr)
=
$
0
TOTAL
ANNUAL
COST
$
0
+
$
4,043
=
$
4,040
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
22.88,
management
at
$
35.08,
and
clerical
at
$
17.88.

b
Assume
EPA/
State
personnel
will
attend
10
percent
of
the
performance
tests.

c
Assume
20
percent
fail
the
initial
performance
test
and
half
repeat
the
performance
test.

d
One
plant
in
100
will
be
involved
in
litigation.

e
Assume
10
percent
of
the
plants
have
excess
emissions.

f
Assume
90
percent
of
the
plants
do
not
have
excess
emissions.

g
Assume
20
percent
of
the
plants
per
year
will
report
a
startup,
shutdown,
malfunction
incident.
22
TABLE
3C.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
FINAL
STANDARD
THIRD
YEAR
AFTER
PROMULGATION
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
test
495
495
2.7
b
1336.5
66.825
133.65
35313
Repeat
performance
test­
Retesting
preparation
4
4
2.7
c
10.8
0.54
1.08
285
Repeat
performance
­
Retesting
495
495
2.7
c
1336.5
66.825
133.65
35313
Litigation
2080
2080
0.27
d
561.6
28.08
56.16
14839
Excess
Emissions
Enforcement
Activities
120
120
2.7
e
324
16.2
32.4
8561
Report
Review
Notification
of
applicability
Notification
of
constr./
reconstr.

Notification
of
anticipated
startup
Notification
of
actual
startup
Notification
of
special
compliance
requirements
Notification
of
initial
performance
test
Notification
of
compliance
status
Review
of
initial
performance
test
report
Review
of
repeat
performance
test
report
Review
of
excess
emissions
report
Review
of
no
excess
emissions
report
Review
of
NESHAP
waiver
application
Review
of
startup,
shutdown,
malfunction
report
2
2
2
2
N/
A
2
2
8
8
8
2
N/
A
2
2
2
2
2
2
2
8
8
8
2
2
0
1
1
1
27
0
27
2.7
2.7
24.3
f
5.4
g
0
2
2
2
54
0
216
21.6
21.6
48.6
10.8
0
0.1
0.1
0.1
2.7
0
10.8
1.08
1.08
2.43
0.54
0
0.2
0.2
0.2
5.4
0
21.6
2.16
2.16
4.86
1.08
0
53
53
53
1,427
0
5,707
571
571
1,284
285
TOTAL
BURDEN
AND
COST
(
SALARY)
3948
197
395
104,315
Travel
Expenses
for
Tests
Attended
(
1
person
x
2.7
plants/
yr
x
1
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
2.7
round
trips/
yr)
=
$
1215
TOTAL
ANNUAL
COST
$
1215
+
$
104,315
=
$
105,530
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
22.88,
management
at
$
35.08,
and
clerical
at
$
17.88.

b
Assume
EPA/
State
personnel
will
attend
10
percent
of
the
performance
tests
at
the
total
of
27
plants
(
0.1
x
27
=
2.7).

c
Assume
20
percent
fail
the
initial
performance
test
and
half
repeat
the
performance
test
(
0.2
x
27/
2).

d
One
plant
in
100
will
be
involved
in
litigation
(
0.01
x
27
=
0.27).

e
Assume
10
percent
of
the
27
plants
(
2.7)
have
excess
emissions.

f
Assume
90
percent
of
the
27
plants
(
24.3)
do
not
have
excess
emissions.

g
Assumes
20
percent
of
the
plants
per
year
(
5.4)
will
report
a
startup,
shutdown,
malfunction
incident.
23
TABLE
4.
SUMMARY
OF
INDUSTRY
BURDEN
FOR
THE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
METAL
COIL
SURFACE
COATING
(
YEARS
1
THROUGH
3
AND
AVERAGE)
Non­
Labor
Costs
Year
Technical
Hours
Management
Hours
Clerical
Hours
Total
Hours
Labor
Costs
Capital
Costs
O&
M
Costs
Total
Costs
Year
1
19,457
973
2,142
22,572
510,866
195,964
6,431
713,261
Year
2
16,607
830
1,720
19,157
403,746
195,964
1,895
601,605
Year
3
28,957
1,448
3,010
33,415
741,789
304,301
3,737
1,049,827
Average
Burden
25,050
552,130
232,080
4,020
788,230
24
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
NOTIFICATIONS
Applicability
63.5180(
b)(
1)
63.9(
b)(
1)­(
3)

Anticipated
startup
63.5180(
b)(
2)
63.9(
b)(
4)

Commencement
of
construction
63.5180(
b)(
2)
63.9(
b)(
4)

Actual
startup
63.5180(
b)(
2)
63.9(
b)(
4)

Intention
to
construct/
reconstruct
63.5180(
b)(
2)
63.9(
b)(
4)­(
5)

Performance
test
63.5180(
c)
63.9(
e)­(
g)

Compliance
status
63.5180(
d)
63.9(
h)

REPORTS
Initial
performance
test
report
63.5180(
e)
63.10(
d)(
2)

Startup,
shutdown,
malfunction
plan/
reports
63.5180(
f)
63.6(
e)(
3),
63.9(
d)(
5)

Excess
emissions
or
no
excess
emissions
reports
63.5180(
g)­(
i)
63.10(
e)(
5)

Recordkeeping
General
Provisions
general
requirements
63.5190(
b)(
1)­(
b)(
3)
63.10(
b)(
2)

Startup,
Shutdown,
and
Malfunction
Plan
63.5180(
f)
63.10(
b)(
2)

Documentation
of
corrective
action
procedures
63.5180(
f)
63.10(
b)(
2)
