**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for Magnetic Tape Coating Facilities**  **( 40 CFR Part 60, Subpart SSS)**  **(Renewal) 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 I CR Number 1135.11, OMB Control Number 2060

- 0171 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Magnetic Tape Coating Facilities were : proposed on January 22, 1986 ; promulgated on October 3, 1988 ; and last amended on February 12, 1999 . These regulations appl y to each coating operation and to each piece of coating mix preparation equipment for which construction, modification, or reconstruction beg an after January

22, 1986

. This information is being collected to assure compliance with 40 CFR part 60, subpart SSS

. In general, all NSPS standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They 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 an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS. Any owner/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, the event that there is no such delegated authority, the reports are sent directly to the U

. S

. Environmental Protection Agency (EPA) regional office

. Over the next three ye ars, an average of 6 respondents per ye ar will be subject to the se standard s , and no additional respondents per year will become subject to the standard s
. However, we assume that two coating lines per ye ar will be constructed at existing sources over the next three years. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“Terms o f Clearance.” The “Affected Public” are owners and operators of magnetic tape coating facilities. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS) (Renewal). The “burden ” to the Federal Government is attributed entirel y to work performed by either F ederal emplo ye es or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60,2

Subpart SSS) (Renewal).
**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 sy stem 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 adequatel y demonstrated. Section 111(a)(l). The Agency

refers to thi s 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 o wner/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 ac cordance 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 whe n 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 reasonabl y require. In the Administrator's judgment, volatile organ ic c ompound (VOC) emissions from magnetic tape coating operations either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/ 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 recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.3

Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard. Continuous e mission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was ach ieved 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 regu lations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , leaks are being detected and repaired , and the standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Cri**  **teria** 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y of the report submitted to the state or local agency can be sent to the A dministrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (78 FR 33409) on June 4, 2013. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulte d, 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 b y industry , in compliance with the recordkeeping and reporting provisions in the st andard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is bas ed on our consultations with the Agency ’s internal industry experts.4

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard s as they were being developed and the standard s have been reviewed previously to determine the minimum information needed for compliance purposes. Indeveloping this ICR, we contacted : 1) the National Electrical Manufacturers Association (NEMA) , at 703

- 841

- 3245 ; and 2) the Imation Corp oration , online at : http://www.imation.com/en

- US/Contact

- Im ation/

. 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 c omments 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 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, Septemb er 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard s 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 magnetic tape manufacturers . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 3695 which corre sponds to the North American5

Industry Classification Sy stem (NAICS ) 334613 for magnetic and optical recording media manufacturing

. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS). A source must make the following reports:

**Notification s**  **/Reports** 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 sy stem 60.7(a)(5) Phy sical or operational change 60.7(a)(4) A source must keep the following records:
**Recordkeeping** Startups, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 60.7(b)
Records are required to be retained for two ye ars. Records must be kept onsite. 60.717

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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting6

sy stems to transmit data electronicall y. However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test, Reference Method 24 test, 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 sy stems for the purpose of collecting, validating, and verifying inform ation. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency A ctivities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information.7 **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comp ly 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y 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 b y this regul ation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility** There are no small entities (i.e. small businesses) affected b y this regulation, and no small businesses are expected to become subject to the regulation in the next three years. In addition, the impact on small entities was taken into consideration during the development of the regulation. Any new coating operation that utilizes less than 38 m 3 of solvent or an y modified or reconstructed coating operation that utilizes less than 370 m 3 of solvent for the manufacture of magnetic tape per calendar year i s subject only to the monitoring and reporting requirements of 60.714(a), 60.717(b), and 60.717(c). **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1: Annual Responde nt Burden and Cost

– NSPS for Magnetic Tape8

Coating Facilities (40 CFR P art 60, S ubpart 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver 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 disp lays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these record

keeping and reporting requirement s is estimated to be 2,017 hours ( Total Labor Hours from Tabl e 1 below). T hese 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 IC R, and any

comments received. **6(b) Estimating Responde nt Costs**  **(i) Estimating Labor Costs** This I CR uses the following labor rates: Managerial $1 2 2

. 4 9 ($5 8

. 3 3 + 110%) Technical $ 10 1

. 2 8 ($4 8

. 2 3 + 110%) Clerical $ 50

. 80 ($2 4

. 19 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 1 10 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe 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. Th e 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(s) and other costs such as photocop ying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**9

**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 1 (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 2 $29,000 1 $29,000 $ 1,200 4 $4,800 Thermocouple $2,300 2 $4,600 $8,000 6 $48,000 Total $33,600 $52,800
1 We assume there are 6 existing sources, and that two of the existing sources will construct a new coating line per year. 2 We assume that 60 percent of sources will install CEM. The total capital/startup costs for this I CR are $ 33,600 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 52,800

. 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 IC R is estimated to be $ 86,400

. These are the costs of recordkeeping. **6(c) Estimating Agency Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained 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, 33 6

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Magnetic10

Tape Coating Facilities (40 CFR P art 60, S ubpart SSS) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 6 existing respondents will be subject to the standard s . It is estimated that no additional respondents per ye ar will become subject. However, we assume that two existing respondents will each construct a new coating line each ye ar ; howeve r, the overall average number of respondents, as shown in the table below, is 6 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Year (A) Number of Ne w 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 2 6 0 2 6
2 2 6 0 2 6
3 2 6 0 2 6 Average 2 6 0 2 6 1 New respondent include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 6

. The total number of annual responses per ye ar is calculated using the following table:11 **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 1 1 0 1 Notification of physical /operational change 2 1 0 2 Notification of actual startup 2 1 0 2 Notification of initial performance test 2 1 0 2 Notification of CMS 2 1 0 2 Quarterly report of excess emission 1.2 4 0 4.8 Semiannual report of no excess emission 4.8 2 0 9.6 **Total 23**  **.4** The number of Total Annual Responses is 23 (rounded)

. The total annual labor costs are $197, 327

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Magnetic Tape Coating Facilities ( 40 CFR P art 60, S ubpart SSS ) (Renewal). **6(e) Bottom Line 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, respectivel y, and summarized below. **(i) Respondent Tally**  The total annual labor hours are 2,017 hours at a cost of $197,327

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NSPS for Magnetic Tape Coating Facilities ( 40 CFR P art 60, S ubpart SSS ) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 88 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 86,400

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 141 labor hours at a cost of $6, 33 6 . See below Table 2: Average Annual EPA Burden and Cost

– NSPS for Magnetic Tape Coating Facilities ( 40 CFR P art 60, S ubpart SSS ) (Renewal).12

**6(f) Reasons for Change in Burden**
T here is no change in labor hours in this I CR compared to the previous I CR. This is due to two considerations : 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years ; and 2) the growth rate for the industry is either very low, or negative or non

- existent, so there is no significant change in the overall burden. However, there is an adjustment increase in both the respondent and Agency burden costs due to an increase in labor rates. **6(g) Burden Statement** The annual public repor

ting 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 b y persons to generate, maintain, retain, or disclose or provide informati on to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining informatio n, and disclosing and providing information; adjust the existing way s to compl y 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 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2013

- 0318. An electronic version of the public docket is available at http://www.regulations.gov/ , which may be used to obtain a co py

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 sy stem , 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), WJC 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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 E PA

- HQ

- OECA

- 20 13

- 0318 and OMB Control Number 2060

- 017 1 in any correspondence.13

**Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1: Annual Respondent Burden and Cost**

**– NSPS for Magnetic Tape Coating Facilities (40 CFR**  **P art**  **60, S**  **ubpart SSS)**  **(Renewal)**

**Burden Items (A)**  **Person h**  **ours per o**  **ccur r**  **ence (B)** 

**Number of o**  **ccur r**  **ences per**  **r espondent**  **per y**  **ear (C)** 

**Person h**  **ours per r**  **espondent per**  **y ear**  **(C=A x B) (D)** 

**Number of Respondents**  **per y**  **ear b**  **(E)**

**Technical person**  **h ours**  **per year**  **(E=C x D) (F)** 

**Managem ent**  **person hours**  **per year**  **(Ex0.05) (**  **G)**

**Clerical person**  **hours per**  **year (**  **E x 0.1) (H)** 

**Total Labor Costs per**  **Year a** 

1. A pplications N/A 2. Surveys and S tudies N/A 3. Reporting Requirements A. Read Instructions 0.87 1 0.87 2 1.74 0.09 0.17 $195.63 B. Required Activities **New Sources** Initial performance test c 243.48 1 243.48 2 486.96 24.35 48.70 $54,775.05 Repeat of performance test 243.48 0.2 48.70 2 97.39 4.87 9.74 $10,955.01 Method 24 Testing 78.26 12 939.13 0.1 93.91 4.70 9.39 $10,563.76 C. Create Information See 3B D. Gather Existing Information See 3E E. Write Report **New Sources** Notification of construction/reconstruction/modification d 1.74 1 1.74 1 1.74 0.09 0.17 $195.63 Notification of phys/operational change 6.96 1 6.96 2 13.91 0.70 1.39 $1,565.00 Notification of actual startup 1.74 1 1.74 2 3.48 0.17 0.35 $391.25 Notification of initial performance test 1.74 1 1.74 2 3.48 0.17 0.35 $391.25 Notification of CMS 1.74 1 1.74 2 3.48 0.17 0.35 $391.25 Report of performance test See 3B Excess Emission Report e 13.91 4 55.65 1.2 66.78 3.34 6.68 $7,512.01 Report of No Excess Emissions f 6.96 2 13.91 4.8 66.78 3.34 6.68 $7,512.01 Report when Exceed Size Cutoff 1.74 1 1.74 0 0 0 0 $ 0 **Subtotal for Reporting Requirements 965.6**  **$94,447.8 5**  4. Recordkeeping Requirements15

**Burden Items (A)**  **Person h**  **ours per o**  **ccur r**  **ence (B)** 

**Number of o**  **ccur r**  **ences per**  **r espondent**  **per y**  **ear (C)** 

**Person h**  **ours per r**  **espondent per**  **y ear**  **(C=A x B) (D)** 

**Number of Respondents**  **per y**  **ear b**  **(E)**

**Technical person**  **h ours**  **per year**  **(E=C x D) (F)** 

**Managem ent**  **person hours**  **per year**  **(Ex0.05) (**  **G)**

**Clerical person**  **hours per**  **year (**  **E x 0.1) (H)** 

**Total Labor Costs per**  **Year a** 

A. Read Instructions See 3A B. Plan Activities See 4C C. Implement Activities See 3B D. Develop Record System N/A E. Time to Enter Information Records of startups, shutdowns, malfunctions, etc. g 1.30 50 65.22 6 391.30 19.57 39.13 $44,015.66 Records of control device operating parameters h 0.22 350 76.09 6 456.52 22.83 45.65 $51,351.61 Records of Projected/Actual Solvent Use i 6.96 2 13.91 1.2 16.70 0.83 1.67 $1,878.00 Records for Monthly Liquid Material Balance j 1.74 12 20.87 1.2 25.04 1.25 2.50 $2,817.00 Monthly Determination of Avg VOC Content k 1.74 12 20.87 1.2 25.04 1.25 2.50 $2,817.00 F. Train Personnel N/A G. Audits N/A **Subtotal for Recordkeeping Requirements 1,051.8**  **$102,879.2 7**  **TOTAL LOBOR BURDEN AND COST (rounded) 2,017**  **$197,327**

**Assu mptions:** 
a This ICR uses the following labor rates: $122.49 per hour for Executive, Administrative, and Managerial labor; $101.28 per hour f or Technical labor, and $50.80 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “Table 2. Civilian Workers, by Occupational and Industry group”. The rates are from column 1, “Total Compensation”. The rates have been increa sed by 110 percent to account for the benefit packages available to those empl oyed by private industry. b We have assumed that the average number of respondents that will be subject to the rule will be 6 existing sources, and no ad ditional sources will become subject to the standard. However, we assume that two coating lines per year will be constructed at existing sources over the three

- year period of this ICR.
c We have assumed that it will take each respondent 243.48 hours to perform initial performance test. d We have assumed that there will be one mo dification/reconstruction line over 5 years.
e We have assumed that 20 percent of sources will report excess emissions. f We have assumed that 8 0 percent of sources wil l report no excess emissions. g We have assumed that each respondent will take 1.3 hours 50 times per year to record SSM reports.16

h We have assumed that each respondent will take 0.22 hours 350 time per year to record the control device operating parameters information. i We have assumed that 20 percent of respondents will enter information on records of project ed/actual solvent use two times per year. j We have assumed that 20 percent of respondents will record liquid material balance 12 times per year. k We have assumed that 20 percent of respondents will perform monthly VOC determination.17

**Table 2: Average Annual EPA Burden and Cost** 

**– NSPS for Magnetic Tape Coating Facilities (40 CFR**  **P art**  **60, S**  **ubpart SSS)**  **(Renewal)**

**Activity (A)**  **EPA Hours per**  **Occur r**  **ence (B)** 

**Number of Occur**  **r ences**  **per Plant per Year**  **(C)**

**EPA Hours per Year**  **(C=A x B)**  **(D)**

**Plants per Year**  **b (E)** 

**Technical Hours**  **per Year (E=C x D)**  **(F)**

**Managem ent**  **Hours per Year**  **(E x 0.05) (G)** 

**Clerical Hours per**  **Year (**  **E x 0.1) (H)** 

**Total Costs per**  **Year a** 

I nitial P erformance T ests c New Plant 20.87 1 20.87 2 41.74 2.09 4.17 $2,163.11 Repeat P erformance T est New Plant 20.87 0.2 4.17 2 8.35 0.42 0.83 $432.62 Report Review **New Plant** Notification of construction 1.74 1 1.74 2 3.48 0.17 0.35 $180.26 Notification of actual startup 0.43 1 0.43 2 0.87 0.04 0.09 $45.06 Notification of initial test d 0.43 1.2 0.52 2 1.04 0.05 0.10 $54.08 Revie w test results e 6.96 1.2 8.35 2 16.70 0.83 1.67 $865.24 Excess emission report f 6.96 4 27.83 1.2 33.39 1.67 3.34 $1,730.49 Report of no excess emissions g 1.74 2 3.48 4.8 16.70 0.83 1.67 $865.24 **TOTAL LABOR BURDEN AND COST (rounded) 141**  **$6, 336** 
**Assu mptions:**  a This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial rate (GS

- 13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS

- 6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2012 General Schedule”, which excludes locality rates of pay. b We have assumed that the average number of respondents that will be subject to the rule will be 6 existing sources, and no additional sources will become subject to the standard. However, we assume that two coating lines per year will be constructed at existing sources over the three

- year period of this ICR.
c We have assumed th at it will take each respondent 20.87 hours to perform initial performance test. d We have assumed that it will take each respondent 0.43 hours 1.2 time per year to perform initial test notification.
e We have assumed that it will take 6.96 hours 1.2 times per year to review test results. f We have assumed that 2 0 percent of sources will report excess emissions. g We have assumed that 80 percent of sources will report no excess emissions