SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

EPA ICR Number 0660.12, 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 apply to facilities commencing construction, modification, or reconstruction after the 

date of proposal. This information is being collected to assure compliance with 40 CFR Part 60, 

Subpart TT.

In general, all NSPS standards require initial notification reports, 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, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the 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 year will become subject in the next three years.

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

without any “Terms of Clearance.”

The term “Affected Public” applies to owners and operators of metal coil surface coating 

facilities. These facilities are privately owned, for-profit businesses, and are not owned by 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 Metal 
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Coil Surface Coating (40 CFR Part 60, Subpart TT) (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 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 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 metal 

coil surface coating lines cause or contribute to air pollution that may reasonably be anticipated 

to endanger public health or welfare. Therefore, the NSPS were promulgated for this source 

category at 40 CFR Part 60, Subpart 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 were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

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

capability to comply with the emission standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 these standards 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, that leaks are being detected and repaired, and that the standards are being 

met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

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 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 (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 by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS), which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. 

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 developing this ICR, we 

contacted both the 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 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 standard do not include sensitive 

questions.
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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 (SIC) code for these respondents is SIC 3479 (Coating, Engraving, and Allied 

Services, Not Elsewhere Classified). The corresponding North American Industry Classification 

System (NAICS) 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 by the NSPS for Metal 

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

A source must make the following notifications:

Notifications

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

Notification of actual startup 60.7(a)(3)

Notification of physical 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-weighted 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 years. The first two years of 

records must be retained at the facility

60.7(f), 60.465(e)

For catalytic incineration: maintain daily records of upstream and 

downstream gas temperature

60.465(e)

Maintain daily records of incinerator combustion temperature or 

amounts of solvent recovered

60.464(c), 

60.465(e)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are 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 a device that continuously records the combustion 

temperature of any effluent gases incinerated to achieve compliance.

Perform initial performance test, Reference Methods 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.
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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 ways to comply with any previously applicable instructions and 

requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring systems). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests, if necessary.

Review notifications and reports, including performance test 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). 
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 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

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 types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown 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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.
9

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 15,643 hours (Total Labor Hours from Table 1). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NSPS program, the previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $128.02 ($60.98 + 110%)

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2014, “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 (O&M) 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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

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

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 
10

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

total of column G. 

The average annual cost for both capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $331,800.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$39,674. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 Metal Coil 

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

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

Based on our research for this ICR, on average over the next three years, approximately

158 existing respondents will be subject to these standards. It is estimated that no additional

respondents per year will become subject. The overall average number of respondents is 158 per 

year, as shown in the table below:

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 158 0 0 158

2 0 158 0 0 158

3 0 158 0 0 158

Average 0 158 0 0 158

1

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

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 158. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of 

construction/reconstruction

0 1 0 0

Notification of 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 is 379.
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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 average 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 be 872 

labor hours at a cost of $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 currently identified in the 

OMB Inventory of Approved Burdens. The change from the most-recently approved ICR is due 

to the use of updated labor rates. It is not due to any program changes. This ICR 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 years 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.
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6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information

is estimated to average 41 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, 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-2014-0026. 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-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.
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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

Personhours

per 

occurrence

Annual 

occurrences

per 

respondent

Person-hours

per respondent

per year (AxB)

Respondents

per year a

Technical 

hours 

per year

(CxD)

Management 

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 c60 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

Temperature variance report d4 0.5 2 126 252 12.6 25.2 28,372.68

Subtotal for Reporting Requirements 2,106.8 206,265

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 3B
15

Burden item

A B C D E F G H

Personhours

per 

occurrence

Annual 

occurrences

per 

respondent

Person-hours

per respondent

per year (AxB)

Respondents

per year a

Technical 

hours 

per year

(CxD)

Management 

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 13,536.7 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 standard 

over the three-year period of this ICR.

b

This ICR 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, by occupational and industry

group.” The rates are from column 1, “Total compensation.” They have been increased by 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 will file a temperature variance report every other year.
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)

Management

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 c24 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

Review 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

Temperature variance report d2 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 standard 

over the three-year period of this ICR.

b

This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are from the 

Office of Personnel Management (OPM), 2014 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.
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 temperature variance report every other year.