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 ICR Number 1957.06, OMB Control Number 2060-0487

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Metal Coil 

Surface Coating 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 apply to 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 less 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 operators 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 

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 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 five years following the date of such measurements, 

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 directly to the U. S.

Environmental Protection Agency (EPA) regional office.

Approximately 89 respondents are subject to the regulation, and that no additional 

respondents per year 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 by the 

metal coil surface coating industry (the “Affected Public”). All these 89 facilities are privatelyowned, for-profit businesses; none of them are owned by state, local, tribal or the Federal 

government. 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 to be 19,901 hours and 

$1,615,226, respectively. 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 489 hours and $22,056, respectively.

The active (previous) ICR had the following Terms of Clearance (TOC):

“When this ICR 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 industry representatives 

regarding the burden associated with this ICR (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 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, HAP emissions from metal coil surface coating plants 

cause 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 recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, 

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 initial capability 

to comply with the emission standard. Continuous emission monitors are used to ensure 

compliance with the standard at all times. During the performance 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 Agency 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 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. Nonduplication, 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 directly to the delegated state 

or local agency. If a state or local agency has adopted their 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, 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 ICR was published in 

the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the burden 

published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 
4

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. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. During the previous 

renewal, we estimated that approximately 89 respondents will be subject to the standard over the 

three-year 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 developing 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 (formerly Anaconda 

Aluminum Company) at (336) 503-1460. 

It is our policy to respond after a thorough review of comments received since the last ICR 

renewal as well as those submitted in response to the first Federal Register notice.

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

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. EPA believes that the five-year records retention requirement is consistent with the Part 

70 permit program and the five-year 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-compliance, 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 destruction or 

nonexistence of essential records.

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, 
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 States Standard Industrial Classification (SIC) codes for the 

respondents affected by the standards, which correspond to the North American Industry 

Classification System (NAICS) codes, are listed below for the metal coil surface coating source 

category.

Standard (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 325992
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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)

Reports

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

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

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 

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 equipment that provides parameter data in an 

automated way (e.g., continuous parameter monitoring system). Although personnel at the source 

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

burden associated with monitoring and recordkeeping.

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

Management

5(a) Agency Activities

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

and distribution of the required information.

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, analyze, and maintain data in the Online Tracking Information System (OTIS).

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 properly installed and operational. 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 determination. 

Information contained in the reports is entered into OTIS 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 approximately 125,000 industrial and government-owned 

facilities. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state 

regulatory agencies, EPA regional offices, and EPA headquarters. EPA-delegated Authorities can 

edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or operator for five 

years.

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 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 - 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 ICR. The 

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

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 
9

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 Labor Costs

This ICR 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 Labor, Bureau of Labor Statistics, 

September 2011 “Table 2: Civilian workers, by Occupational and Industry Group.” The rates are 

from column 1, “Total Compensation.” The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs, which are addressed elsewhere in this ICR, and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor 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 

monitoring system N/A N/A $0 $48 76 $3,648
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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 ICR 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 years of the ICR is estimated to be $3,648.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis 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 hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011 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 - 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 ICR, 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 

year.
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The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.

Number of Respondents

Year

(A)

Number of 

New

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(D)

Number of Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 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-year period of this ICR is 89.

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

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).
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6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor 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 ICR compared to the previous ICR. This is due 

to two considerations. First, 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 currently 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 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 
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Numbers for EPA’s 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-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 

system, 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 

Information 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 holidays. The 

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

Enforcement and Compliance Docket and Information Center Docket 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, 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 

information.
Table 1: Annual 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 

personhours per 

year

(E=CxD)

(F)

Management 

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 c280 0.11 30.8 0 0 0 0 $0

 Repeat oxidizer performance test c280 0.11 30.8 0 0 0 0 $0

 Initial capture performance test c215 0.11 23.65 0 0 0 0 $0

 Repeat capture performance test c215 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 c2 0.11 0.22 0 0 0 0 $0

 Performance test report c40 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 h8 2 16 7.6 121.6 6.08 12.16 $13,399.51

Subtotal for Reporting Requirements 1,678.08

4. Recordkeeping requirements

 A. Read instructions See 4B

 B. Plan activities N/A
15

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 

personhours per 

year

(E=CxD)

(F)

Management 

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 $1,450,945.10

 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 j0.25 2 0.5 76 38 1.9 3.8 $3,486.85

 I. Time for audits N/A

Subtotal for Recordkeeping Requirements 18,222.9

TOTAL LABOR BURDEN AND COST 

(rounded)

19,900.98

19,901 

(rounded)

$1,615,226

Assumptions:

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 

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.

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 minutes to transmit or disclose information twice a year.
17

Table 2: Average Annual EPA Burden and Cost - NESHAP for Metal Coil Surface Coating Plants (40 CFR Part 63, Subpart 

SSSS) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrence

s per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

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

Review 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 7.6 121.60 6.08 12.16 $6,301.60

 Semiannual report of no excess emissions e, f 2 2 4 68.4 273.60 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 30.40 1.52 3.04 $1,575.40

Subtotals Labor Burden and cost 425.60 21.28 42.56 $22,055.61

TOTAL ANNUAL BURDEN AND COST 

(rounded)

489 $22,056

Assumptions:

 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). These rates are from 
18

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.