SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Magnetic Tape Coating Facilities (40 CFR part 60, subpart SSS)
(Renewal),

EPA ICR Number 1135.10, OMB Control Number 2060-0171

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the Magnetic Tape
Coating Facilities (40 CFR part 60, subpart SSS) 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 commencing construction, modification or
reconstruction after the date of proposal. This information is being
collected to assure compliance with these regulations.

Approximately six sources are currently subject to the standard, and it
is estimated that no additional sources will become subject to the
regulation in the next three years.  It is further assumed that two
coating lines per year are to be constructed at existing sources over
the next three years.  There is a reduction in the number of sources due
to industry consolidation.

The current ICR is based on the most recently approved Information
Collection Request (ICR).  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.

OMB approved the currently active ICR without any “Terms of
Clearance”.

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every 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 (VOC)
emissions from magnetic tape manufacturing either cause or contribute to
air pollution that may reasonably be anticipated to endanger public
health or welfare.  Therefore, the 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 the operation of coating equipment, and the operation of
coating mix preparation equipment.  The subject standards are achieved
by the recovery, or destruction of VOC emissions by control devices.  

The recordkeeping and reporting requirements in the standard ensures
compliance with the applicable regulations which where 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.
Continuous emission monitors are used to ensure compliance with the
standard at all times.

The notifications required in the standard 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 standards are being met.  The performance test may also
be observed. 

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, 

subpart SSS.

3(a)  Non-duplication

 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state, or local agency. 
If a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state, or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, 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 July 8, 2009 (74 FR 32581).  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

For this information collection, the previous ICR renewal was used to
obtain burden estimates since this ICR renewal was processed under the
“Expedited Approach” option provided in May 1, 2008 guidance.  Per
this guidance, all data and assumptions from the previous ICR renewal
were used as the basis for estimating the hourly and cost burdens
associated with this renewal.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.  In this case, no comments were received.
 

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violates any of
the regulations established by OMB at 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).

3(g)  Sensitive Questions

The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC and NAICS Codes

The respondents to the recordkeeping and reporting requirements are
magnetic tape manufacturers.  The SIC code for the respondents affected
by the standards is SIC (United States Standard Industrial
Classification) 3695 which corresponds to the NAICS (The North American
Industry Classification System) 334613 for magnetic and optical
recording media manufacturing.

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.

A source must make the following reports:

Notifications



Construction/reconstruction	

60.7(a)(1)



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)

A source must keep the following records:

Recordkeeping



Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	

60.7(b) 



Records are required to be retained for two years.  Records must be kept
onsite.	

60.717



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., inlet and outlet
concentrations when determining percent efficiency.  Although personnel
at the source still need to evaluate the data, this type of monitoring
equipment has significantly reduced the burden associated with
monitoring and recordkeeping.  In addition, some regulatory agencies are
setting up electronic reporting systems to allow sources to report
electronically which is reducing the reporting burden.  However,
electronic reporting systems are still not widely used by the regulatory
agencies.  It is estimated that approximately 10 percent of the
respondents use electronic reporting.

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, Section 60.713(b)(1)].



Monthly liquid material balance [40 CFR, Section 60.714(b)].



Maintain records of projected, and actual solvent consumption [40 CFR,
Section 60.714(a), 

40 CFR, Section 60.717(b), (c)].



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



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



Monthly determination of average VOC content of coatings [40 CFR,
Section 60.714(j)].



Reports of projected and actual solvent consumption [40 CFR, Section
60.717(b)].



Semiannual reports when no quarterly reports required [40 CFR, Section
60.717(e)].



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



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



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 Air Facility System (AFS).



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.  

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA’s Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the 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

There are no small businesses affected by this regulation at present,
and no small businesses are expected to become subject to the regulation
in the next three years.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost for NSPS for Magnetic Tape Coating Facilities (40 CFR part 60,
subpart SSS) (Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The Agency may not conduct, or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 2,017
(Total Labor Hours from Table 1 below).  The recordkeeping hours shown
in Table 1 are 1,051.8.  The reporting requirement hours shown in Table
1 are 965.6.  These hours are based on Agency studies and background
documents from the development of the regulation, Agency knowledge and
experience with the NSPS program, the previously approved ICR, and any
comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial	$114.49 ($54.52 + 110%)   

Technical	$98.20 ($46.76 + 110%)

Clerical	$48.53 ($23.11 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2009, “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 and Operations and Maintenance Costs

 

The type of industry costs associated with the information collection
activity in the standards are both labor costs which are addressed
elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one time costs when a new
line becomes subject to the standard.  The annual operations and
maintenance costs are the ongoing costs to maintain the monitor(s) and
other costs such as photocopying and postage

(iii)  Capital/Startup vs. Operating 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)



	CEM	

$29,000	

1	

$29,000	

$2,100	

4 (60% of sources)	

$4,800



Thermocouple	

$2,300	

2	

$4,600	

$8,000	

6	

$48,000



The total capital/startup costs for this ICR are $33,600.  This is the
total of column D in the above table. 

The total operation and maintenance costs for this ICR are $52,800. 
This is the total of column G. 

The total respondent costs 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 $86,400.  The continuous monitoring costs that are
included in this section consist only of those capital/startup and O&M
costs that a source incurs as a result of the standard.  Some continuous
monitoring costs may not be included in this section.  For instance,  if
a particular industry typically utilizes a control device that must have
a continuous monitor (e.g., temperature, pressure drop, etc.) to
function properly, and the recordation of additional measurements beyond
the minimum are required by the standard, then there is no
capital/startup or O&M cost, but there is a labor cost to record the
additional readings.  Such a cost would not appear in this section, but
in the industry burden Section 6(d) below.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $6,892.  

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Annual Agency Burden and Cost for NSPS
for Magnetic Tape Coating Facilities (40 CFR part 60, subpart SSS)
(Renewal).

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately six (6) existing
sources currently are subject to the standard.  It is estimated that an
additional zero sources per year will become subject to the regulation
in the next three years.  It is further assumed that two coating lines
per year are to be constructed at existing sources over the next three
years.

Number of respondents is calculated using the following table which
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 	

(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	

2	

6	

0	

2	

6



2	

2	

6	

0	

2	

6



3	

2	

6	

0	

2	

6



Average	

2	

6	

0	

2	

6



To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is six (6). 

The total number of annual responses per year is calculated using the
following table:

Total Annual Responses



(A)

Number of New Respondents	

(B)

Number of Reports for New Respondents	

(C)

Number of Existing Respondents	

(D)

Number of Reports for Existing Respondents	

(F)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	

(E)

Total Annual Responses 

E=(AxB)+(CxD)+F



2	

4	

6	

2.5	

0	

23



The number of Total Annual Responses is 23.  

The total annual labor costs are $190,824.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost for NSPS for Magnetic Tape Coating Facilities (40 CFR part 60,
subpart SSS) (Renewal).

 

Note that the total annual capital and O&M costs to the regulated entity
are $86,400.   These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 88
hours per response.

6(f)  Reasons for Change in Burden

There is no change in the labor hours to the respondents in this ICR
compared to the previous ICR because the regulations have not changed
over the past three years and are not anticipated to change over the
next three years. Since this ICR renewal was approved to be processed
under the “Expedited Approach” option, EPA has maintained the same
estimate for the number of sources currently subject to this standard as
indicated in the most recently approved ICR.  Therefore, the labor hours
figures in the previous ICR reflect the current burden to the
respondents and are reiterated in this ICR.  However, there is a
decrease number of respondents currently identified in the OMB Inventory
of Approved ICR Burdens.  This decrease was due to the number of
respondents being incorrectly assigned in the Information Collection
Request, Review, and Approval System (ICRAS).

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 88 hours per response.  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 valid OMB
control number.  The OMB control numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2009-0419. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system,   SEQ CHAPTER \h \r 1 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), EPA West, Room 3334, 1301 Constitution Ave., NW,
Washington, DC.  The EPA Docket Center Public Reading Room is open from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.
 The telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center Docket is (202) 566-1752.  Also, comments can be sent
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-2009-0419 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.

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