SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT)
(Renewal)

EPA ICR Number 0660.11, OMB Control Number 2060-0107

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, amended on June 24, 1986, and
October 17, 2000.  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 New Source Performance Standards (NSPS) 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 158 sources are currently subject to the regulation, and
it is estimated that no additional sources per year will become subject
to the regulation in the next three years.  

In the United States, there are approximately 158 metal coil surface
coating facilities which are owned and operated by the metal coil
surface coating industry (the “Affected Public”).  These facilities
are privately owned for-profit businesses, and are not owned by state,
local, tribal, or the Federal government.  The burden to the “Affected
Public” is listed in Table 1: Annual Industry Burden and Cost – NSPS
for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal). 
The Federal government burden associated with the review of reports
submitted by the respondent is shown in Table 2: Average Annual EPA
Burden – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart
TT) (Renewal).

In the development of this Information Collection Request (ICR), we
addressed the Office of Management and Budget (OMB) “Terms of
Clearance (TOC)” on the active ICR.  The TOC are as follows:

This collection of information is approved for 3 years.  Before
resubmission of this ICR, the Agency should update wage estimates,
continuing to refer to most recently available data from Bureau of Labor
Statistics.  In addition, the agency should verify the number of
respondent entities.

EPA has addressed each item of concern in the TOC.  The updated labor
rates and the number of respondents have been thoroughly checked, and
all estimates have been updated.

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,   SEQ CHAPTER \h \r 1 volatile organic
compound (VOC) emissions from metal coil surface coating cause or
contribute to air pollution that may reasonably be anticipated to
endanger public health or welfare.  Therefore, the NSPS was promulgated
for this source category at 40 CFR part 60, subpart TT.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  In addition, the collected
information is 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.  During the performance tests, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

The required semiannual reports are used to determine periods of excess
emissions, to identify problems at the facility, to verify
operation/maintenance procedures and compliance.

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

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

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 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.

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 (76 FR 26900) on May 9, 2011.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed.  In developing this ICR, we reviewed information
available from the United States Census Bureau, and websites covering
metal coil surface coating.  We also consulted with the EPA Office of
Air Quality Planning and Standards, Information Transfer, and Program
Integration Division, the National Coil Coating Association at (216)
241-7333, and White Engineering Surfaces Corporation at (215) 968-5021.

After a thorough review, it is our policy to respond to comments
received since the last ICR renewal, as well as to those submitted in
response to the first Federal Register notice.

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

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

 	

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the part 70 permit program and the five-year statute of limitations
on which the permit program is based.  The retention of records for five
years allows the EPA to establish the compliance history of a source,
any pattern of non-compliance, and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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 Codes

The respondents to the recordkeeping and reporting requirements are bulk
gasoline terminals.  The United States Standard Industrial
Classification (SIC) code for the respondents affected by the standards
is SIC 3479 which corresponds to the North American Industry
Classification System (NAICS) 332812 for Metal Coating, Engraving
(Except Jewelry and Silverware), and Allied Service to Manufacturing.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT)
(Renewal).

A source must make the following reports:

Notifications

Notification of construction/reconstruction	60.7(a)(1)

Anticipated startup	60.7(a)(2)

Notification of 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 keep the following records:

Recordkeeping 

Maintain records of startup, shutdown, or malfunction period 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)



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are not widely used.  At this time, it is
estimated that approximately 10 percent of the respondents use
electronic reporting.

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.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way (e.g., continuous parameter
monitoring system).  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.

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,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
system (OTIS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect
the source to determine whether the pollution control devices are
properly installed and operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and to 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 OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA 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

The majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these to be the minimum
requirements needed to ensure compliance and, therefore, cannot reduce
them further for small entities.  To the extent that larger businesses
can use economies of scale to reduce their burden, the overall burden
will be reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NSPS for
Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (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.  Wherever 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 15,643
(Total Labor Hours from Table 1).  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	$119.36 ($56.84 + 110%)   

Technical	$99.18 ($47.23 + 110%)

Clerical	$49.35 ($23.50 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 2011, "Table 2. Civilian Workers, by
Occupational and Industry group."  The rates are from column 1, "Total
Compensation."  The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The types of industry costs associated with the information collection
activities in the subject standard are both labor costs, which are
addressed elsewhere in this ICR. and the costs associated with
continuous monitoring.  The capital/startup costs are one-time cost 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)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital / Startup Cost,  (B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents  with O&M	(G)

Total O&M,

(E X F)

Temperature	$8,000	0	$0	$2,100	158	$331,800



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

The total operation and maintenance (O&M) costs for this ICR are
$331,800.  This is the total of column G.

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $331,800.

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 $39,283.

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) “2011
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 in Table 2: Average Annual EPA Burden, NSPS for Metal Coil
Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

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

	Based on our research for this ICR, on average over the next three
years, approximately 158 existing respondents will be subject to the
standard.  It is estimated that no additional respondent per year will
become subject to the standard.  The overall average number of
respondents, as shown in the table below, is 158 per year. 

	The number of respondents is calculated using the following table that
addresses the three years covered by this ICR.

Number of Respondents

Year	(A)

Number of New Respondents 1	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	0	158	0	0	158

2	0	158	0	0	158

3	0	158	0	0	158

Average	0	158	0	0	158

1 New respondents include sources with constructed, reconstructed, and
modified affected facilities.

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 158.

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Notification of construction/reconstruction	0	1	0	0

Notification of performance test	0	1.2	0	0

Notification of actual startup	0	1	0	0

Report of performance test	0	1.2	0	0

Emissions report	158	2	0	316

Temperature variance report	126	0.5	0	63



	Total	379



The number of Total Annual Responses is 379.

The total annual labor costs are $1,497,459.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost –
NSPS Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below. 

(i)  Respondent Tally

The total annual labor hours are 15,643.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost:
NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT)
(Renewal).

Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 41 hours per
response.

The total annual capital/startup and operation and maintenance (O&M)
costs to the regulated entity are $331,800.

(ii)  The Agency Tally

The average annual Agency burden and cost over the next three years is
estimated to be 872 labor hours at a cost of $39,283.  See Table 2:
Annual Agency Burden and Cost Metal Coil Surface Coating (40 CFR Part
60, Subpart TT) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the
previous ICR.  Consultations with the Office of Air Quality Planning and
Standards (OAQPS) and trade associations revealed that there are
approximately 158 sources subject to the rule, with no new facilities
expected to be constructed over the next three years of this ICR.

However, there is an increase in the estimated burden cost as currently
identified in the OMB Inventory of Approved Burdens.  The increase is
not due to any program changes.  The change in burden is due to the use
of the most updated labor rates.  

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 41 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, 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-2011-0226.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
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 content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than 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 Avenue, N.W., Washington, D.C.  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) 566-1927. 
Also, you can send comments 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.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2011-0226 and OMB Control Number
2060-0107in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

Table 1:  Annual Respondent Burden and Cost – NSPS for Metal Coil
Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)

Burden item	(A)

Person 

hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person hours per year

(Ex0.05)	(G)

Clerical person hours per year

(Ex0.1)	(H)

Total Cost 

Per year b



1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting requirements









     A.  Read instructions 	1	1	1	0	0	0	0	$0

     B.  Required activities









        Initial performance tests c	60	1	60	0	0	0	0	$0

        Repeat of performance tests d	60	0.2	12	0	0	0	0	$0

     C.  Gather existing information	See 3B  







	     D.  Write Report









        Notification of construction/reconstruction e	2	1	2	0	0	0	0	$0

        Notification of  initial performance test e	2	1	2	0	0	0	0	$0

        Notification of actual startup e	2	1	2	0	0	0	0	$0

        Report of performance test	See 3B







	        Emissions report f	5	2	10	158	1,580	79	158	$173,931.14

        Temperature variance report g	4	0.5	2	126	252	12.6	25.2
$27,740.92

Subtotal  for Reporting  Requirements





2,106.8



4.  Recordkeeping requirements









     A.  Read instructions 	See 3A







	     B.  Plan activities	See 3B







	     C.  Implement activities (monthly performance

           test) h	1	12	12	158	1,896	94.8	189.6	$208,717.36

     D.  Develop record system









          Records of operating parameter i	0.25	250	62.5	158	9,875
493.75	987.5	$1,087,069.62

Subtotal  for Recordkeeping Requirements  





13,536.65



Subtotals: Labor Burden and costs



	13,603	680.15	1,360.3	$1,497,459.04

TOTAL LABOR BURDEN AND COST (rounded)





15,643.45

15,643

    (rounded)                                                           
                                                            

$1,497,459



Assumptions:

  a 	 We have assumed that there are approximately 158 respondents, with
no additional new or reconstructed sources becoming subject to the rule
over the next three years.

  b  This ICR uses the following labor rates:  $119.36 per hour for
Executive, Administrative, and Managerial labor; $99.18 per hour for
Technical labor, and $49.35 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 2011, Table 2. Civilian Workers, by Occupational and
Industry groups.  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.

c  We have assumed that it will take 60 hours for each respondent to
perform initial performance tests.  All sources are in compliance with
the initial rule requirements including the initial performance test.

d  We have assumed that 20 percent of sources would have to repeat the
performance test due to failure.

e  We have assumed that it will take each respondent two hours once per
year to write the report.

f  We have assumed that each respondent will take 5 hours twice per year
to complete the performance test report.

g  We have assumed that 80 percent of facilities will use incineration,
and will file a temperature variance report every other year.

h  We have assumed that each respondent will take 1 hour once per month
to implement the performance test.

i   We have assumed that each respondent will take 0.25 hours 250 times
per year to develop the operating parameter record system.

Table 2:  Average Annual EPA Burden - NSPS for Metal Coil Surface
Coating (40 CFR Part 60, Subpart TT) (Renewal)

Activity	(A)

EPA person- hours per occurrence	(B)

No. of occurrences per plant per year	(C)

EPA person- hours per plant per year

(C=AxB)	(D)

Plants per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person-hours per year

(Ex0.05)

	(G)

Clerical person-hours per year

(Ex0.1)	(H)

Cost, $ b

   Initial performance test









      New plant 	24	1	24	0	0	0	0	$0

   Repeat performance test









      New plant c	24	0.2	4.8	0	0	0	0	$0

   Report review









      New plant









        Notification of construction	2	1	2	0	0	0	0	$0

        Notification of initial startup d	0.5	1	0.5	0	0	0	0	$0

        Notification of actual startup d	0.5	1	0.5	0	0	0	0	$0

        Notification of initial test d	0.5	1.2	0.6	0	0	0	0	$0

        Review test results e	8	1.2	9.6	0	0	0	0	$0

      Existing plant









        VOC emissions report f	2	2	4	158	632	31.6	63.2	$32,753.08

        Temperature reports g	2	0.5	1	126	126	6.3	12.6	$6,529.89

Subtotals Labor Burden and cost



	758	37.9	75.8	$39,282.97

TOTAL ANNUAL BURDEN AND COST (rounded)





871.7

872 (rounded)

$39,283



 	Assumptions:

    a  We have assumed that there are approximately 158 respondents,
with no additional new or reconstructed sources becoming subject to the
rule over the next

    three years. 

b  This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21
for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6,
Step 3, $15.63 1.6).  These rates are from the Office of Personnel
Management (OPM) (2011 General Schedule( which excludes locality rates
of pay.

c  We have assumed that 20 percent of respondents will repeat the
performance tests due to failure.

d  We have assumed that each respondent will take 0.5 hours to review
the startup and initial test notifications.

e  We have assumed that each respondent will take 8 hours to review the
test results.

f  We have assumed that each respondent will take 2 hours twice per year
to review the VOC emissions report.

    g  We have assumed that 80 percent of facilities will use
incineration, and will file a temperature variance report every other
year.

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