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 ICR 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 apply to each coating operation and to each piece of 

coating mix preparation equipment for which construction, modification, or reconstruction began

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 any period during which the monitoring system 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 years, an average of 6 respondents per year will be subject to 

these standards, and no additional respondents per year will become subject to the standards. 

However, we assume that two coating lines per year will be constructed at existing sources over 

the next three years. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of 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 entirely to work performed by either 

Federal employees 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 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/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 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 emission 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 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 check if the pollution control devices are properly 

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 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, 

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 ICR 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 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 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 

based 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 standards as they were being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the National Electrical 

Manufacturers Association (NEMA), at 703-841-3245; and 2) the Imation Corporation, online 

at: http://www.imation.com/en-US/Contact-Imation/.

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

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by 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, 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 standards 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 (SIC) code for the 

respondents affected by the standards is SIC 3695 which corresponds to the North American 
5

Industry Classification System (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 by the NSPS for Magnetic 

Tape Coating Facilities (40 CFR Part 60, Subpart SSS). 

A source must make the following reports:

Notifications/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 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

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 
6

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, 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 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 

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.

Currently sources are using monitoring and reporting equipment that provide 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.
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, 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 operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply

with the emission standard, and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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/operator for two 

years.

5(c) Small Entity Flexibility

There are no small entities (i.e. small businesses) affected by 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 m3of 

solvent or any modified or reconstructed coating operation that utilizes less than 370 m3of 

solvent for the manufacture of magnetic tape per calendar year is 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 Respondent Burden and Cost – NSPS for Magnetic Tape 
8

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. 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 2,017 hours (Total Labor Hours from 

Table 1 below). 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 $122.49 ($58.33+ 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 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 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 type 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 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 photocopying 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

Respondents1

(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 ICR are $33,600. This is the total of column D 

in the above table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR 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 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 

$6,336. 

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), 2012 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: Average Annual EPA Burden and Cost – NSPS for Magnetic 
10

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, on average over the next three years, approximately

6 existing respondents will be subject to the standards. It is estimated that no additional 

respondents per year will become subject. However, we assume that two existing respondents 

will each construct a new coating line each year; however, 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 

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 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. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 6.

The total number of annual responses per year 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 Part 60, Subpart 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, respectively, 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 Part 60, Subpart 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 $6,336. See below Table 2: Average Annual EPA Burden and Cost –

NSPS for Magnetic Tape Coating Facilities (40 CFR Part 60, Subpart SSS) (Renewal).
12

6(f) Reasons for Change in Burden

There is no change in labor hours in this ICR compared to the previous ICR. This is due 

to two considerations: 1) the regulations have not changed over the past three years 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 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 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-2013-0318. 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, 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments 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-2013-0318 and OMB Control Number 2060-0171 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 Part 60, Subpart SSS)

 (Renewal)

Burden Items

(A)

Person

hours per 

occurrence

 

(B)

Number of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=A x B)

(D)

Number of 

Respondents 

per year b

(E)

Technical 

person

hours 

per

year

(E=C x D)

(F)

Management 

person 

hours

per

year

(Ex0.05)

(G)

Clerical 

person

hours

per

year

(E x 0.1)

(H) 

Total Labor 

Costs per 

Year a

1. Applications N/A

2. Surveys and Studies 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 c243.48 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 d1.74 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 e13.91 4 55.65 1.2 66.78 3.34 6.68 $7,512.01

Report of No Excess Emissions f6.96 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 $94,447.85

4. Recordkeeping Requirements
15

Burden Items

(A)

Person

hours per 

occurrence

 

(B)

Number of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=A x B)

(D)

Number of 

Respondents 

per year b

(E)

Technical 

person

hours 

per

year

(E=C x D)

(F)

Management 

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 $102,879.27

TOTAL LOBOR BURDEN AND COST (rounded) 2,017 $197,327

Assumptions:

a This ICR uses the following labor rates: $122.49 per hour for Executive, Administrative, and Managerial labor; $101.28 per hour for 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 increased by 110 percent to account 

for the benefit packages available to those employed 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 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 that it will take each respondent 243.48 hours to perform initial performance test.

d

 We have assumed that there will be one modification/reconstruction line over 5 years.

e

 We have assumed that 20 percent of sources will report excess emissions.

f We have assumed that 80 percent of sources will 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 projected/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 Part 60, Subpart SSS)

(Renewal)

Activity

(A)

EPA Hours 

per 

Occurrence

 

(B)

Number of 

Occurrences 

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)

Management 

Hours per 

Year 

(E x 0.05)

(G)

Clerical 

Hours per 

Year

(E x 0.1)

(H)

Total

Costs per 

Year a

Initial Performance Tests c

New Plant 20.87 1 20.87 2 41.74 2.09 4.17 $2,163.11

Repeat Performance Test

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 d0.43 1.2 0.52 2 1.04 0.05 0.10 $54.08

Review test results e6.96 1.2 8.35 2 16.70 0.83 1.67 $865.24

Excess emission report f6.96 4 27.83 1.2 33.39 1.67 3.34 $1,730.49

Report of no excess emissions g1.74 2 3.48 4.8 16.70 0.83 1.67 $865.24

TOTAL LABOR BURDEN AND COST (rounded) 141 $6,336

Assumptions:

a

 This cost is based on the following labor rates which 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 that 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 20 percent of sources will report excess emissions.

g

 We have assumed that 80 percent of sources will report no excess emissions