1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NEW
SOURCE
PERFORMANCE
STANDARD
(
NSPS)
Subpart
SSS,
MAGNETIC
TAPE
MANUFACTURING
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
SSS,
Magnetic
Tape
Manufacturing.

1(
b)
Short
Characterization/
Abstract
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,
in
general,
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
2
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
EPA
Regional
Office.

The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
SSS,
2
Magnetic
Tape
Manufacturing
were
proposed
on
The
New
Source
Performance
Standards
(
NSPS)
for
the
magnetic
tape
manufacturing
industry
were
proposed
on
January
22,
1986,
and
promulgated
on
October
3,
1988.
These
standards
apply
to
each
coating
operation
and
each
piece
of
coating
mix
preparation
equipment
for
which
construction,
modification
or
reconstruction
commenced
after
January
22,
1986.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
SSS.

Approximately
10
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
an
additional
3
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

This
information
was
developed
from
the
Agency's
IDEA
data
base
and
in
discussions
with
the
Electronic
Industries
Association.

Volatile
organic
compounds
(
VOC's)
are
the
pollutants
regulated
under
this
Subpart.

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,

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
nonair
quality
health
and
environmental
impact
and
3
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.

In
the
Administrator's
judgment,
Volatile
Organic
Compound
emissions
from
Magnetic
Tape
Manufacturing
cause
or
contribute
to
4
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
SSS.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
Volatile
Organic
Compounds
(
VOCs)
from
Magnetic
Tape
Manufacturing
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOCs
from
Magnetic
Tape
Manufacturing
are
the
result
of
operation
of
coating
equipment,
and
operation
of
coating
mix
preparation
equipment.
These
standards
rely
on
the
recovery
or
destruction
of
VOC
emissions
by
control
devices.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
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
standard,
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.

The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
5
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
is
necessary
to
ensure
compliance
with
these
standards,
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
is
required
under
40
CFR
Part
60
Subpart
SSS.

3(
a)
Nonduplication
If
the
standard
has
not
been
delegated
the
information
is
sent
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
their
own
similar
regulation
to
implement
the
Federal
Regulation,
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
Standard.
Therefore,
no
duplication
exists.

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
March
31,

2000.
6
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
required
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
in
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
7
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
of
the
recordkeeping
and
reporting
requirements
are
magnetic
tape
manufacturers
(
SIC
Code
3695)

which
commenced
construction,
modification,
or
reconstruction
after
January
22,
1986.

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
SSS,
Magnetic
Tape
Manufacturing.

Reports
for
NSPS
SUBPART
SSS
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)

Initial
performance
test
60.8(
d)

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

Physical
or
operational
change
60.7(
a)(
4)
8
Recordkeeping
for
NSPS
SUBPART
SSS
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Records
are
required
to
be
retained
for
2
Years.
Records
must
be
kept
onsite.
60.717
ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
a
device
to
indicate
cumulative
VOC
recovered
(
when
monthly
liquid
balance
is
to
be
performed)
(
40
CFR
60.713(
b)(
1)).

Monthly
liquid
material
balance
(
40
CFR
60.714(
b)).

Maintain
records
of
projected,
and
actual
solvent
consumption
(
40
CFR
60.714(
a),
40
CFR
60.717(
b),(
c)).

Install,
calibrate,
maintain,
and
operate
monitoring
devices
to
track
control
system
parameters
(
40
CFR
60.714(
c)
through
(
g)).

Maintain
records
of
periods
when
control
device
not
operating
(
40
CFR
60.714(
h)).

Monthly
determination
of
average
VOC
content
of
coatings
(
40
CFR
60.714(
j)).

Reports
of
projected
and
actual
solvent
consumption
(
40
CFR
60.717(
b)).

Semiannual
reports
when
no
quarterly
reports
required
(
40
CFR
60.717(
e)).

Quarterly
reports
of
monitoring
40
CFR
60.717(
d)
exceedances
and
periods
of
noncompliance
recorded
under
(
40
CFR
60.714).

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.
Respondent
Activities
9
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
Aerometric
Information
Retrieval
System
(
AIRS)
database.

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
10
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
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
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
There
are
very
few
if
any
small
businesses
affected
by
this
standard,
however,
any
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
In
addition,
the
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
a
small
collection
of
process
equipment
and
reflect
the
burden
on
11
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
Even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

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
each
of
the
subparts
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.
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
12
estimated
at
3,891(
total
from
industry
table
2)
person­
hours.

These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
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
technical
labor
rates
of
$
54.94
per
hour.

These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.

The
rates
are
from
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
CEMs.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor.
Total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
27,000.
13
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:

Total
annualized
capital/
startup
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.
The
one
new
CEM
would
cost
$
25,000.
A
new
thermocouple
costs
$
2,000
for
the
new
facility,
making
total
annual
capital
start­
up
cost
$
27,000.

The
total
annualized
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
66,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.
Thermocouples
have
an
O&
M
cost
of
$
1,800
per
year.
The
10
existing
facilities
X
$
1,800
equals
$
18,00
for
annual
O&
M
costs
for
thermocouples.
Operation
and
maintenance
(
O&
M)
costs
for
the
CEMs
is
estimated
to
be
$
7,000
per
year.
It
is
estimated
that
sixty
percent
of
existing
sources
need
CEMs,
(
or
6
sources),
therefore,
6
X
$
7,000
equals
$
42,000
for
CEMs.
This
makes
the
total
annualized
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
to
be
$
66,000
($
18,000
+

$
48,000).

The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
cost
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
93,000
($
66,000
+$
27,000).

This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:

Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
14
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
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
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
9,753(
from
table
1).
This
cost
is
based
on
an
average
wage
of
a
(
GS
10
step
1
employee
rate,
($
17.09
hr
+
110%
overhead
=
$
35.89
or
if
previous
ICR
has
specific
breakdowns
use
them)
.
This
rate
is
from
OPM's
2000
General
Schedule,
excluding
locality
pay,
basic
rates
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondant
Universe
Regulation
Title
(
A)
#
new
sources
per
year
(
B)
#
of
initial
reports
for
new
sources
(
C)
#
existing
sources
(
D)
#
of
reports
for
existing
sources
(
E)
total
annual
responses
(
AXB)+(
CXD)

3
2
10
5
56
The
number
of
total
respondents
is
13.
It
is
shown
on
the
15
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.

Approximately
10
sources
are
currently
subject
to
the
standard,

and
it
is
estimated
that
an
additional
3
new
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

The
total
annual
responses
is
56.
This
number
is
in
column
E
of
the
Respondant
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
213,785.

This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
c.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
93,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.
These
costs
are
detailed
in
section
6
b
(
iii)

Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Tables
1
and
2.

6(
f)
Reasons
for
Change
in
Burden
The
decrease]
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
This
decrease
in
burden
is
due
to
more
accurate
estimates
of
existing
and
anticipated
new
sources.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
16
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
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

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
the
Director,

Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460;

and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
17
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1135.07
and
OMB
control
number
2060­
0171
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
