**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)**
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal) , EPA I CR Number 1957.0 6 , OMB Control Number 2060

- 0487 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Metal Coil Surface Co ating Plants (40 CFR part 63, subpart SSSS) were proposed on July 18, 2000, promulgated on June 10, 2002, and amended on March 17, 2003. Respondents are owners or operators of each new, reconstructed, or existing affected source. These standards appl y t o each facility that is a major source of hazardous air pollutant (HAP) at which a coil coating line is operated. The coil coating line is a process and the collection of equipment used to apply an organic coating to the surface of a metal coil that is le ss than 0.15 millimeters (0.006 inches) thick, and the coating line is controlled by a common control device that also receives organic HAP emissions from a coil coating line that is subject to the requirements of this subpart. In general, all owners or o perators subject to NESHAP are required to submit one

- time notifications and one

- time reports on compliance status and performance test results. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunc tion in the operation of an affected facility, or any period during which the monitoring sy stem is inoperative. These notifications, reports and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP . Semiannual reports are required for periods of operation during which the emission limitation is exceeded. Any owner or operator subject to the provisions of this subpart will maintain a file of these measurements, and retain the file for at least f ive years following the date of such m easurements, maintenance report , 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

89 respondents are subject to the regulation, and that no additional respondents per ye ar will become subject to the regulation in the next three years. All 89 metal coil surface coating plants in the United States are owned and operated b y the metal coil surface coating industry (the “Affected Public”). All these 89 facilities are privatel yowned, for

- profit businesses; n one of them are owned by state, local, tribal or the Federal go vernment

. The burden to the “Affected Public” is listed below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS )2

(Renewal)

. The total annual industry burden and cost are estimated t o be 19,901 hours and $1, 615,226 , respectivel y
. The Federal government burden associated with the review of reports submitted by

the respondent is shown below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS ) (Renewal)

. The average annual Agency burden is estimated to be 4 89 hours and $ 22 , 056 , respectivel y
. The active (previous) IC R had the following Terms of Clearance (TOC): “When this I CR is renewed, EPA should review the respondent burden, universe, response number, labor rates, and capital costs and ensure these estimates have been updated.” EPA has addressed each item of concern by consulting with i ndustry

representatives regarding the b urden associated with this I CR (including universe of affected entities, the number of responses, the respondent burden , and capital costs) and updating the labor rates using the most recent information available from the Bureau of Labor Statistics.
**2. Need for and Use of the Collection**  **2(a) Need/Authority for the Collection** The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of HAP. These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner or operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impracti cal; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from metal coil surface coating plants cau se or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, subpart SSSS.3

**2(b) Practical Utility/Users of the Data** The re cordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. Inaddition, the collected information is used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility’s i nitial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the A gency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y 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. Nonduplica tion, Consultations,**  **and Other Collection Criteria** The requested recordkeeping and reporting are required under 40 CFR part 63, subpart SSSS. **3(a) Nonduplication** If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their 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 b y the Fede ral standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R was published in the Federal Register ( 76 FR 26 900 ) on May 9 , 20 11 . No co mments 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 con sidered. The primary source of information as reported b y industry , in compliance with the recordkeeping and4

reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by the EPA Office of Compl iance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the indu stry is based on our consultations with the Agency ’s internal industry experts. During the previous renewal, we estimated that a pproximately

89 respondents will be subject to the standard over the three

- ye ar period covered by this ICR. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In dev eloping this ICR, we contacted both the National Coil Coating Association (NCCA) at (937) 498

- 6117, who in turn consulted with several members of the trade association, and Aleris (formerl y Anaconda Aluminum Co mpany) at (3 36) 503

- 1460. It is our polic y t o 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 n otice. **3(d) Effects of Less Frequent Collection** Less frequent infor

mation 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 appli ed and emission limitations are met. If the information required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General G uidelines**  None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention re quirement is consistent with the P art 70 p ermit p rogram and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non

- c ompliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five years. In addition, EPA would be prevented from pursuing the violators due to the destruc tion or nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality i s 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674,5

March 23, 1979). **3(g) Sensitive Questions** None of the reporting or recordkeeping requirements contain sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are metal coil surface coating plants. The United State s Standard Industrial Classification (SI C) codes for the respondents affected b y the standards, which correspond to the North American Industry Classification System (NAI CS) codes, are listed below for the metal coil surface coating source category

.
**Stand ard (40 CFR, part 63, subpart SSSS)**  **SIC Codes**  **NAICS**

**Codes** Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers 3479 332812 Gasket, Packing, and Sealing Device Manufacturing 3053 339991 Electrometallurgical Ferroalloy Product Manufacturing 3313 331112 Steel Works, Blast Furnaces (Including Coke Ovens), and Rolling Mills (hot

- rolling purchased steel) 3312 331221
Cold

- Rolled Steel Sheet, Strip, and Bars 3316 331221 Iron and Steel Pipe and Tube Manufacturing from Purchased Steel 3317 331210 Primary Aluminum Production 3334 331312 Secondary

Smelting and Alloying of Aluminum 3341 331314 Aluminum Sheet, Plate, and Foil Manufacturing 3353 331315 Fabricated Structural Metal Manufacturing 3441 332312 Sheet Metal Work Manufacturing 3444 332322 Prefabricated Metal Building and Component Manufacturing 3448 332311 Motor Vehicle Metal Stamping 3465 336370 Electroplating, Plating, Polishing, Anodizing and Coloring 3471 332813 All other Miscellaneous Fabricated Metal Product Manufacturing 3499 332999 Printing Machinery

and Equipment Manufacturing 3555 333293 All other Motor Vehicle Parts Manufacturing 3714 336399 Photographic Film, Paper, Plate, and Chemical Manufacturing 3861 3259926

**4(b) Information Requested**  None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items** In this ICR, all the data recorded or reported is required by the National Emission Standards for Hazardous Air Pollutants for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)

. A source must make the following reports:
**Notifications** Notification and application of construction or reconstruction 63.5180(b)(1), 63.9(b)(1)

- (3) Notification of anticipated date of initial startup 63.5180(b)(2), 63.9(b)(4) Notification to commence construction 63.5180(b)(2), 63.9(b)(4) Notification of actual startup 63.5180(b)(2), 63.9(b)(4) Notification of intent to construct/reconstruct 63.5180(b)(2), 63.9(b)(4)

- (5) Notification of performance tests 63.5180(c), 63.9(e)

- (g) Notification of compliance status 63.5180(d), 63.9(h) **Repo rts**  Report of initial performance test 63.5180(e), 63.10(d)(2) Reports of startup, shutdown, and malfunction plan 63.5180(f), 63.6(e)(3), 63.9(d)(5) Semiannual compliance report of no deviation 63.5180(g), 63.10(e)(5) Semiannual compliance report of deviation 63.5180(h)(i), 63.10(e)(5) A source must keep the following records: **Recordkeeping** Maintain records of all reports 63.5190(a)(1)

- (3), 63.10(b)(2) Maintain records of startup, shutdown, or malfunction plan 63.5180(f), 63.10(b)(2) Maintain documentation of corrective action procedures 63.5180(f), 63.10(b)(2) 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.7

Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electroni cally . However, electronic reporting s ys tems are not widel y used. At this time, it is estimated that 35 percent of the respondents use electronic reporting. **Respondent Activities** Read instructions. Install, calibrate, maintain, and operate a coil coating line at their metal coil surface coating plants. Perform initial performance test, Reference Methods 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 4, 25, 25A tests, and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. 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 equipment that provides parameter data in an automated way (e.g., continuous parameter monitoring s ys tem). Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has 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, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records.8 **Agency Activities** Input, anal yz e, and maintain data in the Online Tracking Information Sy stem ( OTI S )

. **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y installed and operational. P erformance test reports are used b y the Agency to discern a source’s initial capability to comply

with the emission standard, and note the operating conditions under which compliance w as 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 com pliance determination.
In formation contained in the reports is entered into 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 compliance data for approximate ly 125,000 industrial and government

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

a gencies, EPA regional offices, and EPA headquarters. E PA

- delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the 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 busines ses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

f or each information collection activity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, sp ecific tasks and9

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 19,901 (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 NESHAP program, the previously approved ICE, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating L**  **abor Costs** This I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rates are from the United States Department of Lab or, Bureau of Labor Statistics, Sept ember 2011 “Table 2 : Civilian workers, by O ccupational and Industry Group .” The rates are from column 1, “Total C ompensation.” 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 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 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 1 (G)

Total O&M, (E X F)
Continuous mo nitoring system N/A N/A $0 $ 48 76 $3,64810 **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 1 (G)

Total O&M, (E X F) $0 $3,648 1 There is an average of eighty

- nine sources. Thirteen of these sources are considered synthetic minors and not subject to the emission limits in the standard. The total capital/startup costs for this I CR are zero. This is the total of column D in the above table.
The total operation and maintenance (O&M) costs consists of photocopying, and postage are $3,648. 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 ye ars of the I CR is estimated to be $3,648

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

are those costs associated wi th anal ys is of the reported information. The EPA 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 $ 22,056

. This cost is based on the average hourl y labor rate as follows: Managerial $ 62.27 (GS

- 13, Step 5, $ 38.92 + 60%) Technical $ 46.21 (GS

- 12, Step 1, $ 28.88 + 60%) Clerical $ 25.01 (GS

- 6, Step 3, $ 15.63 + 60%)
These rates are from the Office of Personnel Management (OPM) “ 2011 General Schedule ” which excludes locality

rates of pay . The rates have been increased by 6 0 percent to account for the benefit packages available to government emplo ye es. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this IC R, approximately 89 respondents will be subject to the standard the next three years . It is estimated that no additional sources per year will become subject to the standard. The average number of respondents, as shown in the table below, is 89 per ye ar.11

The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR. **Number of Respondents**

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C)

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

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

Number of Respondents (E=A+B+C

- D)

1 0 89 0 0 89 2 0 89 0 0 89 3 0 89 0 0 89 Average 0 89 0 0 89

1 New respondent include sources with constructed, reconstructed and modified affected facilities. To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 89. The total number of annual responses per ye ar is calculated using the following table:
**Total An nual 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 Initial notification 0 1 0 0 Notification of construction/reconstruction 0 1 0 0 Notification of anticipated startup 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of compliance status 0 1 0 0 Performance test notification 0 0.11 0 0 Performance test report 0 0.11 0 0 Semiannual report of exceedances 7.6 2 0 15.2 Semiannual report of no exceedances 68.4 2 0 136.8 Startup, shutdown, malfunction report 7.6 2 0 15.2 Total 167
The number of Total Annual Responses is 167. The total annual labor costs are $1, 615,226 . Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants ( 40 CFR Part 63, Subpart SSSS) (Renewal )

.12

**6(e) Bottom Line Burden Hours Burden Hours and Cost Tabl es**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor costs are $1, 615,226 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 119 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $3,648. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 489 labor hours at a cost of $ 22 , 056 . See below Table 2 : Average Annual EPA Burden and Cost

- NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart SSSS) (Renewal)

. **6(f) Reasons for Change in Burden**
There is no change in the labor hours in this IC R compared to the previous ICR. This is due to two considerations. F irst, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, the growth rate for the industry is very low, negative or non

- existent, so there is no significant change in the overall burden. However, there is an increase in the total labor and Agency costs as currentl y identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. The change in cost estimates reflects updated labors rates available from the Bureau of Labor Statistics. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 119 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, disclose or provide information to or for a Federal agency . This includes th e 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; adj ust 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; 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 Control13

Numbers for EPA ’ s regulations are listed at 40 CF R 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 s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0232

. 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 content of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W. , Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement an d Compliance Docket and Information Center Docket is (202) 566

- 17 52

. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2011

- 0232 and OMB Control Number 2060

- 0487 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this inform ation.**Table 1: Annu al Respondent Burden and Cost** 
**- NESHAP for Metal Coil Surface Coating Plants**  **(40 CFR Part 63, Subpart**

**SSSS) (Renewal)** 

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

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

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions 4 1 4 0 0 0 0 $0 B. Required activities Initial oxidizer performance test c 280 0.11 30.8 0 0 0 0 $0 Repeat oxidizer performance test c 280 0.11 30.8 0 0 0 0 $0 Initial capture performance test c 215 0.11 23.65 0 0 0 0 $0 Repeat capture performance test c 215 0.11 23.65 0 0 0 0 $0 Emission rate limit compliance determination 16 12 192 0 0 0 0 $0 Startup, shutdown, malfunction plan 32 1 32 0 0 0 0 $0 C. Create information See 4B D. Gather existing information See 4B E. Write Report Initial notification 2 1 2 0 0 0 0 $0 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 Notification of anticipated startup 2 1 2 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 $0 Notification of compliance status 4 1 4 0 0 0 0 $0 Performance test notification c 2 0.11 0.22 0 0 0 0 $0 Performance test report c 40 0.11 4.4 0 0 0 0 $0 Semiannual report of exceedances d, e 16 2 32 7.6 243.2 12.16 24.32 $ 26,799.01 Semiannual report of no exceedances f, g 8 2 16 68.4 1,094.4 54.72 109.44 $ 120,595.55 Startup, shutdown, malfunction report h 8 2 16 7.6 121.6 6.08 12.16 $ 13,399.51 Subtotal for Reporting Requirements 1,67 8.08 4. Recordkeeping requirements A. Read instructions See 4B B. Plan activities N/A15

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

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

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**

C. Implement Activities N/A D. Develop record system N/A E. Time to enter information Records of all information required by standards i 4 52 208 76 15,808 790.4 1,580.8 $1,45 0 ,945.10 F. Time to train personnel N/A G. Time to adjust existing ways to comply with previously applicable requirements N/A
H. Time to transmit or disclose information j 0.25 2 0.5 76 38 1.9 3.8 $3,486.85 I. Time for audits N/A Subtotal for Recordkeeping Requirements 18,22 2.9 **TOTAL LABOR BURDEN AND COST**  **(rounded)** 19,900.98 19,901 (rounded) $1, 615,226

**Assu mptions:**  a We have assumed that there are approximately eighty

- nine respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Within those eighty

- nine existing sources, only seventy

- six are subject to the emission limits in the standard. The remaining thirteen respondents are permitted as synthetic minors and, therefore, are not subject to the emission limits in the standard

. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “ Table 2 : Civilian Workers , by O ccupatio nal and I ndustry Group. ” The rates are from column 1, “ Total C om pensation. ” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. c This is a one

- time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting. The one

- time startup costs are amortized over the 15

- year life of control equipment at 7 percent interest. For computational purposes, the number of occurrences per respondent per year is amortized over 15 years. d We have assumed that exceedances are reported semiannually. e We have assumed that 10 percent of respondents will report exceedances. f Reports indicating no exceedances are required semiannually. g We have assumed that 90 percent of respondents will report no exceedances. h We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction report semiannually.16

i We have assumed that all information is entered on a weekly basis. j We have assumed that each of the 76 respondents will take 15 mi nutes to transmit or disclose information twice a year.17

**Table 2: A verage Annual EPA**  **Burden and Cost** 
**- NESHAP for Metal Coil Surface Coating Plants**  **(40 CFR Part 63, Subpart SSSS)**  **(Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrence**  **s per plant per year**  **(C)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E) Technical**  **person**   ** hours per** **year (E=CxD)**  **(F)**

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

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Initial performance test 495 1 495 0 0 0 0 $0 Repeat performance test

- retesting preparation 4 1 4 0 0 0 0 $0 Repeat performance

- retesting 495 1 495 0 0 0 0 $0 Excess emissions enforcement activities 120 1 120 0 0 0 0 $0 Revie w reports Notification of applicability 2 1 2 0 0 0 0 $0 Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 Notification of anticipated startup 2 1 2 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 $0 Notification of special compliance requirements N/A Notification of compliance status 2 1 2 0 0 0 0 $0 Review of initial performance test report 8 1 8 0 0 0 0 $0 Review of repeat performance test report 8 1 8 0 0 0 0 $0 Semiannual report of excess emissions c, d 8 2 16 7.6 121.6 0 6.08 12.16 $6,301.60 Semiannual report of no excess emissions e, f 2 2 4 68.4 273.6 0 13.68 27.36 $14,178.61 Review of NESHAP waiver application N/A Review startup, shutdown, malfunction report g 2 2 4 7.6 30.4 0 1.52 3.04 $1,575.40 Subtotals Labor Burden and cost 425.6 0 21.28 42.56 $22,055.61 **TOTAL ANNUAL BURDEN AND COST (rounded)**  489 $22,056

**Assu mptions:**  a We have assumed that there are approximately eighty

- nine respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Within those eighty

- nine existing sources, only seventy

- six are subject to the emission limits in the standard. The remaining thirteen respondents are permitted as synthetic minors and, therefore, are not subject to the emission limits in the standard. b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $ 62.27 for Managerial (GS

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

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

- 6, Step 3, $ 15.63 x 1.6). T hese rates are from18

the Office of Personnel Management (OPM) “ 2011 General Schedule ” which excludes locality rates of pay.
c It is assumed that 10 percent of respondents will report excess emissions. d It is assumed that reports of excess emissions are required semiannually

. e We have assumed that 90 percent of respondents will report excess emissions. f It is assumed that reports of no excess emissions are required semiannually. g We have assumed that 10 percent of startup, shutdown, malfunction reports will be reviewed.