SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Metal
Coil
Surface
Coating
(
Subpart
TT)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Metal
Coil
Surface
Coating
(
Subpart
TT)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
the
regulations
published
at
40
CFR
Part
60,
Subpart
TT
were
proposed
on
January
5,
1981
and
promulgated
on
November
1,
1982.
These
regulations
apply
to
the
following
surface
coating
lines
in
the
metal
coil
surface
coating
industry:
each
prime
coat
operation,
each
finish
coat
operation,
and
each
prime
and
finish
coat
operation
cured
simultaneously
where
the
finish
coat
is
applied
wet
on
wet
over
the
prime
coat.
These
regulations
apply
to
metal
coil
coating
facilities
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
TT.

In
general,
all
NSPS
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
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
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
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
United
States
Environmental
Protection
Agency
(
EPA)
Regional
Office.

Approximately
161
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
an
additional
four
(
4)
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
These
numbers
are
based
on
previous
experience
with
the
industry
and
a
recent
search
of
the
Agency's
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
data
base.
2
The
"
Terms
of
Clearance"
for
the
previously
approved
Information
Collection
Request
(
ICR)
stated:

This
ICR
is
approved
for
three
years.
Before
resubmission
of
this
ICR
for
extension,
the
agency
should
revisit
the
estimate
of
the
number
of
respondents
and
demonstrate
to
OMB
that
the
estimates
are
consistent
with
agency
experience.
In
addition,
the
agency
should
revise
wage
estimates
to
reflect
guidance
provided
by
EPA
and/
or
OMB,
especially
with
respect
to
appropriate
calculation
of
wage
overhead.

The
AFS
data
search
was
used
to
determine
the
number
of
facilities
covered
by
the
rule
and
the
industry
and
Agency
wage
rates
were
updated
to
use
the
most
recently
available
rates
and
overheads.

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
four
years.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
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.
3
In
the
Administrator's
judgment,
Volatile
Organic
Compounds
(
VOC)
emissions
from
surface
coating
of
metal
coils
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60,
Subpart
TT.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
VOC
from
surface
coating
of
metal
coils
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC
from
surface
coating
of
metal
coils
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
capture
and/
or
reduction
of
VOC
emissions
using
pollution
control
devices.
The
notifications
required
in
the
applicable
regulations
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
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.

The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
EPA
reduced
the
reporting
frequency
for
this
information
from
quarterly
to
semiannually
in
a
December
1990
Federal
Register
Notice.
The
reduction
in
reporting
frequency
was
in
response
to
the
Office
of
Management
and
Budget's
(
OMB)
previous
questions
regarding
the
need
for
quarterly
versus
semiannual
reporting.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
are
required
under
40
CFR
Part
60,
Subpart
TT.

3(
a)
Nonduplication
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
have
adopted
their
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,
no
duplication
exists.
4
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
on
June
20,
2002.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
facilities
which
conduct
surface
coating
of
metal
coils.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
3479
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
332812
for
Metal
Coating,
Engraving
(
Except
Jewelry
and
Silverware),
and
Allied
Services
to
Manufacturing.
5
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60,
Subpart
TT.

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
60,
Subpart
TT
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
results
60.8(
a),
60.465(
b)

Initial
performance
test
60.8(
d),
60.465(
b)

Demonstration
of
continuous
monitoring
system
60.7(
a)(
5)

Physical
or
operational
change
60.7(
a)(
4)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
60,
Subpart
TT
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Excess
emissions
report
60.7(
c),
60.465(
c),
60.465(
d)

Monthly
performance
test
of
volume­
weighted
average
emissions
of
VOCs
kg/
l
of
coating
solids
applied
60.463(
b),
60.463(
c)

Record
average
VOC
content
of
coatings
applied
monthly
60.464(
a),
60.464(
b)

For
thermal
incineration:
install,
calibrate,
maintain,
and
operate
temperature
monitoring
device
60.464(
c)

Records
are
required
to
be
retained
for
2
years.
The
first
two
years
of
records
must
be
retained
at
the
facility.
60.7(
f),
60.465(
e)

For
catalytic
incineration:
maintain
daily
records
of
upstream
and
downstream
gas
temperature
60.465(
e)

Maintain
daily
records
of
incinerator
combustion
temperature,
or
amounts
of
solvent
recovered
60.464(
c),
60.465(
e)
6
(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
a
device
that
continuously
records
the
combustion
temperature
of
any
effluent
gases
incinerated
to
achieve
compliance.

Perform
initial
performance
test,
Reference
Method
24
,
Reference
Method
25,
or
data
provided
by
the
formulator
of
the
coating,
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.

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.

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
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.
7
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
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
entered
into
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AFS
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
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
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
requirements
the
minimum
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.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
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
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.
8
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
14,530.5
(
Total
Labor
Hours
from
Table
2).
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
a
Technical
Labor
Rate
of
$
57.12
per
hour.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2001,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
The
recordkeeping
and
reporting
requirements
in
NSPS
Subpart
TT
were
designed
to
be
performed
by
technical
staff.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
and
Continuous
Emission
Monitors
(
CEMs).
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
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
($)
for
One
Affected
Facility
(
C)
Number
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
(
F)
Number
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Temperature
7,000
4
28,000
1,800
161
289,800
The
total
capital/
startup
costs
for
this
ICR
are
$
28,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.
9
The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
289,800.
This
is
the
total
of
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
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
$
317,800.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
38,116
[
see
Table
1
in
Section
6(
e)].
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
38.35.
This
rate
is
from
the
Office
of
Planning
and
Management's
(
OPM)
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
1,
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
and
Number
of
Responses/
Year
Regulation
Citation
(
A)
Number
of
New
Sources/
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Sources
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Recordkeepers
that
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
New
and
no
exceedence
4
4
161
2
338
Excess
emission
132
0.5
66
The
number
of
total
respondents
is
165.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.
10
The
number
of
Total
Annual
Responses
is
404.
This
is
the
number
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
in
block
13(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
are
$
829,982.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Respondent
Burden
and
Cost.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
317,800.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
decrease
in
the
number
of
new
sources
each
year.
The
change
in
burden
for
new
and
existing
facilities
is
also
due
to
a
reduced
cost
for
monitoring
equipment.
The
primary
reason
for
the
burden
decrease
is
due
to
an
error
in
Tables
1
and
2
which
over
estimated
the
number
of
responses
per
year
from
existing
sources.
Instead
of
2
responses
for
emission
reports
per
year,
the
previous
ICR
used
2.5
reports
per
year.
In
addition,
the
number
of
responses
due
to
excess
emission
reports
was
calculated
as
twice
per
year
rather
than
the
correct
one­
half
times
per
year.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating
and
verifying
information,
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
standards
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
11
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
Number
and
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
12
TABLE
1:
ANNUAL
AGENCY
BURDEN
AND
COST:
NEW
SOURCE
PERFORMANCE
STANDARD
(
NSPS)
­
METAL
COIL
SURFACE
COATING
FACILITIES,
40
CFR
PART
60,
SUBPART
TT
REPORTING/
RECORDKEEPING
REQUIREMENT
EPA
Hours/
Occurrence
(
A)
Occurrence
/
Plant/
Year
(
B)
EPA
Hours/
Year
(
C=
A*
B)
(
C)
Plants/
Year
(
D)
EPA
Hours/
Year
(
E=
C*
D)
(
E)

INITIAL
PERFORMANCE
TESTS
New
Plant
24
1
24
4
96
REPEAT
PERFORMANCE
TEST
New
Plant
24
0.2
4.8
4
19.2
REPORT
REVIEW
New
Plant
Notification
of
Construction
2
1
2
4
8
Notification
of
Initial
Startup
0.5
1
0.5
4
2
Notification
of
Actual
Startup
0.5
1
0.5
4
2
Notification
of
Initial
Test
0.5
1.2
0.6
4
2.4
Review
Test
Results
8
1.2
9.6
4
38.4
Existing
Plant
VOC
Emissions
Reports
2
2
4
165
660
Temperature
Reports
2
0.5
1
132
132
TOTAL
ANNUAL
HOURS
960
ANNUAL
TRAVEL
EXPENSES
(
1
person
x
2
plants/
year
x
3
d/
plant
x
$
100
per
diem)
+
($
350
round
trip/
plant
x
2
plant/
yr)
=
$
1,300.00
SALARY
BURDEN
(
per
year)

1
person
x
960
h/
yr
x
$
38.35/
h
=
$
36,816.00
TOTAL
ANNUAL
BURDEN
$
38,116.00
TABLE
1:
ANNUAL
AGENCY
BURDEN
AND
COST:
NEW
SOURCE
PERFORMANCE
STANDARD
(
NSPS)
­
METAL
COIL
SURFACE
COATING
FACILITIES,
40
CFR
PART
60,
SUBPART
TT
13
Assumptions
Number
of
new
plants
(
per
year)
4
Rate
of
failed
performance
tests
20%

No
net
growth
in
number
of
facilities.
New
sources
will
replace
existing
sources.

Percentage
of
sources
that
use
incineration.
80%

Time
required
to
participate
with
performance
test
(
hours
per
plant)
24
Time
require
to
review
construction
notification
(
hours)
2
Time
required
to
review
startup
and
initial
test
notifications
(
hours)
0.5
Time
required
to
review
performance
test
results
(
hours)
8
EPA
labor
rate
(
GS­
12
Step
1
x
1.6
overhead)
$
38.35
Percentage
of
new
plant
visits
10%

Round
trip
airfare
to
visit
plant
$
350
14
TABLE
2:
ANNUAL
RESPONDENT
BURDEN
AND
COST:
NEW
SOURCE
PERFORMANCE
STANDARD
(
NSPS)
­
METAL
COIL
SURFACE
COATING
FACILITIES,
40
CFR
PART
60,
SUBPART
TT
REPORTING/
RECORD
KEEPING
REQUIREMENT
Hours/
Occurrenc
e
(
A)
Occurrence/
Year
(
B)
Respondents/
Year
(
C)
Hours/
Year
(
D=
A*
B*
C)
(
D)
Costs/
Year
(
E)

1.
APPLICATIONS
N/
A
N/
A
N/
A
N/
A
N/
A
2.
SURVEY
AND
STUDIES
N/
A
N/
A
N/
A
N/
A
N/
A
3.
REPORTING
REQUIREMENTS
a.
Read
Instructions
1
1
4
4
$
228.48
b.
Required
Activities
Initial
Performance
Tests
60
1
4
240
$
13,708.80
Repeat
of
Performance
Tests
60
0.2
4
48
$
2,741.76
c.
Gather
Existing
Information
­­­­­­­­­­­­­­­­­­­­­­­­
Included
in
3b­­­­­­­­­­­­­­­­­­­­­­­­­­­­

d.
Write
Report
Notification
of
Construction/
R
econstruction
2
1
4
8
$
456.96
Notification
of
Anticipated
Startup
2
1
4
8
$
456.96
Notification
of
Initial
Performance
Test
2
1
4
8
$
456.96
Notification
of
Actual
Startup
2
1
4
8
$
456.96
Report
of
Performance
Test
­­­­­­­­­­­­­­­­­­­­­­­­
Included
in
3b­­­­­­­­­­­­­­­­­­­­­­­­­­­­

Emissions
Report
5
2
165
1650
$
94,248.00
Temperature
Variance
Report
4
0.5
132
264
$
15,079.68
TABLE
2:
ANNUAL
RESPONDENT
BURDEN
AND
COST:
NEW
SOURCE
PERFORMANCE
STANDARD
(
NSPS)
­
METAL
COIL
SURFACE
COATING
FACILITIES,
40
CFR
PART
60,
SUBPART
TT
15
REPORTING/
RECORD
KEEPING
REQUIREMENT
Hours/
Occurrenc
e
(
A)
Occurrence/
Year
(
B)
Respondents/
Year
(
C)
Hours/
Year
(
D=
A*
B*
C)
(
D)
Costs/
Year
(
E)

4.
RECORDKEEPING
REQUIREMENTS
a.
Read
Instructions
­­­­­­­­­­­­­­­­­­­­­­­­
Included
in
3a­­­­­­­­­­­­­­­­­­­­­­­­­­­­

b.
Plan
Activities
­­­­­­­­­­­­­­­­­­­­­­­­
Included
in
3b­­­­­­­­­­­­­­­­­­­­­­­­­­­­

c.
Implement
Activities
(
Monthly
Perf.
Test)
1
12
165
1980
$
113,097.60
d.
Develop
Record
System
N/
A
N/
A
N/
A
N/
A
N/
A
e.
Time
to
Enter
Information
Records
of
Operating
Parameter
0.25
250
165
10312.5
$
589,050.00
TOTAL
ANNUAL
BURDEN
14530.5
$
829,982.16
TABLE
2:
ANNUAL
RESPONDENT
BURDEN
AND
COST:
NEW
SOURCE
PERFORMANCE
STANDARD
(
NSPS)
­
METAL
COIL
SURFACE
COATING
FACILITIES,
40
CFR
PART
60,
SUBPART
TT
16
Assumptions
Number
of
facilities
reporting
(
per
year).
With
4
new
facilities
over
three
years,
the
average
number
of
facilities
reporting
will
be
165
=
161
+
(
3*
4)/
3)
165
Rate
of
failed
performance
tests
20%

Percentage
of
facilities
that
use
incineration.
80%

Number
of
new
facilities
(
per
year)
4
Each
plant
will
file
an
excess
emission
report
every
other
year
and
a
no
exceedence
report
twice
a
year.

Assume
operation
250
days
per
year
as
specified
in
the
NSPS
review
document.

Technical
labor
rate
(
Bureau
of
Labor
Statistics)
$
57.12
