**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 I CR Number 0660.12, OMB Control Number 2060

- 0107. **1(b) Short Characterization/Abstract**  The New Source Performance Standards (NSPS) for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT ) were : proposed on January 5, 1981; promulgated on November 1 , 1982; and 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 appl y to facilities commencing construction, modificatio n, or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 60, Subpart TT

. In general, al l NSPS s tandards require initial notification report s, 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 th ese measurements, and retain the file for at leas t 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Approximately

158 sources are currently subject to the regulation. It is estimated that no additional sources per ye ar will become subject in the next three years. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any

“Terms of Clearance.” The term “Affec ted Public” applies to owners and operators of metal coil surface coating facilities. These facilities are private ly owned , for

-profit businesses, and are not owned b y either state, or local, or tribal entities , or by the Federal government. The “burden ” to the “Affected Public” may

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

– NSPS for Metal2

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

. The “burden ” to the Federal Government is attributed entirely to work performed by either F ederal employees or government contractor s , and may

be found below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (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 adequatel y 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 Admini strator may reasonabl y require. In the Administrator' s judgment , volatile organic compound (VOC) emissions from metal coil surface coating lines cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, th e NSPS w ere promulgated for this source category at 40 CFR Part 6 0, Subpart TT

.3

**2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected f acility ’ s initial capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the standard s at all times . D uring 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 se standard s 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 properl y installed and operate d, that leaks are being detected and repaired , and that the standard s are being met. The performance test may al so be observed. The required semiannual repo rts 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 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 agenc y. 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 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 I CR was published in the Federal Register (79 FR 30117) on May 27, 2014

. No comments were received on the burden published in the Federal Register

.4

**3(c) Consultations** 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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S), 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. Consultations with industry representatives (i.e., respondents) also were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply . In develop ing this I CR, we contacted both th e National Coil Coating Association at (216) 241

- 7333 and PPG Industries, Inc

. at (724) 274

- 7900

. **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** These 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, C hapter 1, P art 2, S ubpart 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** The reporting or recordkeeping requirements in the standard do not include sensitive questions.5

**4. The Respondents and the Information Requested 4(a)**  **Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are owners and operators of metal coil surface coating facilities . The United States Standard Industrial Classification (SI C) code for th ese respondents is SI C 3479 ( C oating, Engraving, and Allied Services, Not Elsewhere Classified). The corresponding North American Industry Classification System (NAI CS) code is 332812 ( Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers )

. **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 Metal Coil Surface Coating (40 CFR Part 60, Subpart TT)

. A source must make the following notifications :
**Notification s**  Notification of construction/reconstruction 60.7(a)(1) Notification of actual startup 60.7(a)(3) Notification of phys ical or operational change 60.7(a)(4) Notification of CMS demonstration date 60.7(a)(5) A source must make the following reports: **Reports** Performance test results 60.8(a), 60.465(a, b) VOC emissions report 60.7(c) , 60.465( c ) Temperature variance report 60.7(c) , 60.465( d) 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)6 **Recordkeeping** Monthly performance test of volume

- wei ghted average emissions of VOCs, in kg/l of coating solids applied 60.463(b), 60.463(c) Record average VOC content of coatings applied monthly 60.464(a , b ) For thermal incineration , install, calibrate, maintain, and operate temperature monitoring device 60.464(c) Records are required to be retained for two ye ars. The first two years of records must be retained at the facility 60.7(f), 60.465(e)
For catal ytic 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 th e respondents continue to create reporting systems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**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 Metho ds 24 or 25, or data provided by the coating formulator , and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above.7 **Respondent Activities** 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 way s 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 and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem s) . 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 Activities, Collection**  **Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following a ctivities 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 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).8

**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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to compl y 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 agenci es, 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 regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibil** **ity** The majority

of 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 ty pes 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 sp ecific frequency

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

– 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 I CR. The individual burdens are expressed under standardized headings beli eved to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

.9

**6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to b e 15,643 h ours (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 th e NSPS program, the previously approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 8

. 0 2 ($ 60.98 + 110%) Technical $ 10 1

. 05 ($4 8

. 12 + 110%) Clerical $ 5 1

. 37 ($2 4

. 46 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014 , “ Table 2. Civilian w orkers, b y occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 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 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 co ntinuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance (O&M) costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying an d 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)

Tem perature $8,000 0 $0 $2,100 158 $331,800 The total capital/startup costs for this I CR are $0 . This is the total o f column D in the above table.10

The total operation and maintenance ( O&M) costs for this I CR are $331,800

. This is the total of column G. The average annual cost for both capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $331,800

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

are those costs associated with anal ys is of the report ed 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 informati on. The average annual Agency cost during the three years of the ICR is estimated to b e $ 39,674

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 General Schedule , which excludes locality

rates of pay

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

– 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 I CR, on average over the next three ye ars, approximately 158 e xisting respondents will be subject to the se standard s . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents is 158 per ye ar , as shown in the table below : The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.11 **Number of Respondents** Respondents That Submit Reports Respondents That Do Not Submit Any Reports

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 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. 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 158

. The total number of annual responses per ye ar 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 actual startup 0 1 0 0 Notification of CMS demonstration date 0 1 0 0
VOC emissions report 158 2 0 316 Temperature variance report 126 1 0 63 Total 379 The number of Total Annual Responses i s 379

.12

The total annual labor costs are $ 1,531,562

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

– NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (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 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 15,643 hours

. Details regarding these estimates may be found below 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 averag e 41 hours per response

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

. 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 b e 872 labor hours at a cost o f $39,674 . See below Table 2 : Average Annual EPA Burden and Cost

– NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal). **6(f) Reasons for Change in Burden** There is an increase in the respondent and Agency cost burdens currentl y identified in the OMB Inventory

of Approved Burdens. The change from the most

- recently approved ICR is due to the use of up dated labor rates. It is not due to any program changes. This I CR references labor rates from the Bureau of Labor Statistics and OPM to calculate the respondent and Agency cost burdens, respectively

. There is no change to the respondent and Agency labor burden in this ICR compared to the previous ICR 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 respondents is very

low, negative, or non

- existent. Therefore, the labor hours in the previous ICR reflect the current burden to respondents and are reiterated in this ICR.13

**6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to averag e 41 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train perso nnel 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 re spond 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

- 2014

- 0026 . An electronic vers ion 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 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 EPA

- HQ

- OECA

- 2014

- 0026 and OMB Control Number 2060

- 0107 in any correspondence. **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 Metal Coil Surface Coating (40 CFR Part 60, Subpart TT)**  **(Renewal)**

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per y**  **ear (CxD)**  **Managem ent** 

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** 1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements A. Read instructions 1 1 1 0 0 0 0 0 B. Required activities Initial performance test 60 1 60 0 0 0 0 0 Repeat performance test c 60 1 60 0 0 0 0 0 C. Gather existing information See 3B D. Write report Notification of construction/reconstruction 2 1 2 0 0 0 0 0 Notification of actual startup 2 1 2 0 0 0 0 0 Notification of CMS demonstration date 2 1 2 0 0 0 0 0 Report of performance test See 3B VOC emissions report 5 2 10 158 1,580 79 158 177,892.2 Tem perature variance report d 4 0.5 2 126 252 12.6 25.2 28,372.68 **Subtotal for Reporting Requirements 2,10**  **6.8 206,265**  4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 3B15

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondents**

**per year a**  **Technical**

**hours per y**  **ear (CxD)**  **Managem ent** 

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** C. Implement activities Monthly performance test 1 12 12 158 1,896 94.8 189.6 213,470.64 D. Develop record system Records of operating parameters 0.25 250 62.5 158 9,875 493.75 987.5 1,111,826.25
**Subtotal for Recordkeeping Requirements**  **13,53 6.7**  **1,325,297 TOTAL ANNUAL BURDEN AND COST (ROUNDED)**  **15,643 1,531,562**  **Assumptions:** a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standa rd over the three

- ye ar period of this I CR. b This I CR uses the following labor rates: $101.05 (technical), $128.06 (managerial), and $51.37 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2. Civilian workers, b y occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. c EPA assumes 20% of new respondents must repeat performance testing due to failure. d EPA assumes 80% of facilities will use incineration, and wi ll file a temperature variance report every other ye ar.16

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

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

**Burden item A**  **B C**  **D E**  **F G**  **H EPA**  **person -**  **hours per**  **occurrence Annual** 

**occurrences per**  **respondent EPA** 

**person -**  **hours per respondent**  **per year (AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** Initial performance test New plant 24 1 24 0 0 0 0 0 Repeat performance test New plant c 24 1 24 0 0 0 0 0 Report review New plant Notification of construction/ reconstruction 2 1 2 0 0 0 0 0 Notification of actual startup 0.5 1 0.5 0 0 0 0 0 Notification of CMS demonstration date 0.5 1 0.5 0 0 0 0 0 Revie w test results 8 1 8 0 0 0 0 0 Existing plant VOC emissions report 2 2 4 158 632 31.6 63.2 33,078.88 Tem perature variance report d 2 0.5 1 126 126 6.3 12.6 6,594.84 **TOTAL ANNUAL BURDEN AND COST (ROUNDED) 872**  **39,674 Assumptions:**  a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standa rd over the three

- ye ar period of this I CR. b This I CR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are fro m the Office of Personnel Management (OPM), 2014 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 emplo yees.17

c EPA assumes 20% of new respondents must repeat performance testing due to failure. d EPA assumes 80% of facilities will use incineration, and will file a temperatu re variance report every

other ye ar.