SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) 

(Renewal), EPA ICR Number 1678.08, OMB Control Number 2060-0326

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Magnetic 

Tape Manufacturing Operations were proposed on March 11, 1994, promulgated on December 

15, 1994, and amended on April 9, 1999. These regulations apply to new and existing magnetic 

tape manufacturing operations located at major sources of hazardous air pollutants (HAP). 

These magnetic tape manufacturing operations include solvent storage tanks, mix preparation 

equipment, coating operations, waste handling devices, and condenser vents in solvent recovery. 

New facilities include those that commenced construction or reconstruction after the date of 

proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart 

EE.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five 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.

Over the next three years, an average of 6 respondents per year will be subject to these

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

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

without any “Terms of Clearance.”

The “Affected Public” involves private sector businesses or other for-profits that 

manufacture magnetic tape. The burden to the “Affected Public” may be found below in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Magnetic Tape Manufacturing 
2

Operations (40 CFR Part 63, Subpart EE) (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 – NESHAP for 

Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) (Renewal). 

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 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. 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, HAP emissions from magnetic tape manufacturing 

operations cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NESHAP were promulgated for this source category 

at 40 CFR part 63, subpart EE.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with 

the applicable regulations which where 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 standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 
3

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. 

The performance test may also be observed.

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

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

EE.

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 (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

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

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

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

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

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

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

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

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standards as it was being developed and the 

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

compliance purposes. In developing this ICR, we contacted: 1) the Amalgamet Incorporated, at 

(914) 683-5809, and 2) the Ultra Electronics USSI, at (260) 248-3500.
4

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

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

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices 

are applied and emission limitations are met. If the information required by these standards 

was collected less frequently, the proper operation and maintenance of control equipment and 

the possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5.

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 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, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and 

operators of magnetic tape manufacturing operations. The United States Standard Industrial 

Classification (SIC) codes for the respondents affected by the standards and corresponding North 

American Industry Classification System (NAICS) codes are listed in the following table.

Standard (40CFR Part 63, Subpart EE) SIC Codes NAICS Codes

Magnetic and Optical Recording Media 3695 334613

Die-cut Paper and Paperboard and Cardboard 2675 322226

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE).

A source must make the following reports:

Notifications/Reports

Notification of intent to construct or reconstruct 63.5(b), 63.9(b), 63.707(a)

Notification and report of construction date 63.9(b)(4), 63.707(a)

Notification of anticipated startup 63.9(b)(4), 63.707(a)

Actual startup notification 63.9(b)(4), 63.707(a)

Notification of applicability of the standard 63.9(b)(2-3), 63.707(a-c)

Develop startup, shutdown, malfunction plan, submit reports 63.6(e)(3), 63.10(d)(5), 

63.707(a), 63.707(i)

Develop quality control plan for continuous monitoring 

systems (CMS)

63.8(d), 63.707(a)

Notification and report of performance tests and results 63.7(b), 63.8(e), 63.9(e), (g), 

63.10(d)(2), (e)(2), 63.707(a)

Report of when exceeds HAP usage cutoff or when area 

source becomes major

63.9(b), 63.9(h), 63.707(j)

Notification and report of compliance status 63.9(h)(2-3), 63.707(a)
6

Notifications/Reports

Notification and report for waiver application 63.7(h), 63.707(a)

Semiannual reports of no excess emissions 63.10(e)(3), 63.707(a), (i)

Quarterly reports of monitoring exceedances and excess 

emissions

63.10(e)(3), 63.707(a), (i)

A source must keep the following records:

Recordkeeping

Five-year retention of records 63.10(b)(1), 63.706(a), (h)

Records of monitored values, maintenance, startup, shutdown, 

malfunction

63.10(b)(2), 63.10(c), 

63.6(e), 63.706(a)

Records of the freeboard ratio 63.10(b)(2), 63.706(b)

Records of CMS maintenance, calibration 63.8(c), 63.8(d)(3), 63.10(c), 

63.10(b)(2), 63.706(a)

Records of performance tests 63.10(b)(2), 63.705, 

63. 706(a)

Records of material balance calculation 63.10(b)(2), 63.706(a), (d)

Records of HAP usage 63.10(b)(2), 63.706(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 CEM for volatile organic compound (VOC) inlet/outlet 
7

Respondent Activities

concentration to measure efficiency of control device, and thermocouples to measure 

minimum combustion temperature and temperature across catalyst bed for site-specific 

operating parameters. Maintain records of coating mix HAP concentration and measure 

freeboard ratio.

Perform initial performance test, EPA Method 24 for VOC content in coatings, EPA Method 

18 or EPA Method 25A to determine HAP or VOC concentrations of air exhaust streams, EPA 

Method 22 to determine visible emissions, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

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

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

reduced the burden associated with monitoring and recordkeeping.

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.
8

Agency Activities

Audit facility records.

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

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

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

with the emission standard. 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 five

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, in 

development of the Final Rule (59 FR 64596), EPA estimates that three of the 14 regulated 

facilities (i.e. 21 percent) were small entities (i.e., small businesses). Due to the significant 

impacts expected to be experienced by one of the small facilities, a regulatory flexibility analysis 

was conducted to assess the feasibility of providing additional flexibility to small businesses 

complying with the regulation. 

This ICR estimates that 16 percent of the current estimated number of affected facilities, 

or approximately one facility (from a total of six facilities), may be a small entity. 

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Magnetic Tape 

Manufacturing Operations (40 CFR Part 63, Subpart EE) (Renewal).
9

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

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

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

The Agency may not conduct or sponsor, and a person is not required to respond to, 

a collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 3,905 hours (Total Labor Hours from Table 1 

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP 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 $121.44 ($57.83 + 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

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

the benefit packages available to those employed by private industry.

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

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

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

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

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

ongoing costs to maintain the monitors and other costs such as photocopying and postage.
10

(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

Respondents1

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Total 

enclosure $11,000 1 $11,000 0 0 0

VOC CEM 0 0 0 $8,000 3 $24,000

Thermocouples 0 0 0 $2,000 6 $12,000

Totals $11,000 $36,000

1This ICR assumes six sources are currently subject to the NESHAP, and that no additional source will become 

subject in the next three years. However, we estimate that one of the six existing sources will incur capital costs due 

to modification or reconstruction. 

The total capital/startup costs for this ICR are $11,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $36,000. 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 $47,000. These are the costs

of recordkeeping.

6(c) Estimating Agency Burden and Cost

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

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

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

emissions, and the publication and distribution of collected information. 

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

$2,353. 

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

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

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

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

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,
11

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 Magnetic 

Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) (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

six existing respondents will be subject to the standard. It is estimated that an additional no

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is six per year. 

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

years covered by this ICR. 

Number of Respondents

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 6 0 1 6

2 1 6 0 1 6

3 1 6 0 1 6

Average 1 6 0 1 6

1

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

.

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

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

The total number of annual responses per year is calculated using the following table: 
12

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

Report of Monitoring Exceedances and 

Periods of Noncompliance/ Reports of 

No Excess Emissions

6 2.2 0 13.2

Notification of Intent to 

Construct/Reconstruct 1 1 0 1

Notification of Construction Date 1 1 0 1

Actual Startup Notification 1 1 0 1

Notification of Applicability of the 

Standard New/Reconstructed Sources 1 1 0 1

Total 17.2

The number of Total Annual Responses is 17 (rounded). Note that one of the 

respondents has been double counted in the above table because they have both existing 

and new affected facilities.

The total annual labor costs are $378,110. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Magnetic Tape 

Manufacturing Operations (40 CFR Part 63, Subpart EE) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The total annual labor hours are 3,905 at a cost of $378,110. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for 

Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 230 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $47,000. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.
13

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 52

labor hours at a cost of $2,353. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) 

(Renewal).

6(f) Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to an adjustment in 

labor rates and updated assumptions used to estimate technical hours per year. This ICR uses 

updated labor rates from the Bureau of Labor Statistics to calculate burden costs. 

In addition to updated labor rates, there is an update to the assumptions used to estimate 

technical hours per year for the calculated burden costs. In the previous ICR, it was assumed 

that the per respondent burden hour for each activity accounts for technical, managerial, and 

clerical hours. In order to have consistency in the burden calculations in the ICR renewal 

process, this ICR assumes the per respondent burden hour accounts for technical hours only. 

This results in a slight increase in burden hours and costs for both the respondents and the 

Agency. 

6(g) Burden Statement

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

is estimated to average 230 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-2012-0665. 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 
14

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), EPA 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-2012-0665 and OMB Control Number 2060-0326 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Magnetic Tape Manufacturing Operations (40 CFR Part 63,

Subpart EE) (Renewal)

Burden Items (a, b)

(A) 

Hours per 

Occurrence

(B) 

Occurrences 

per Year

(C) 

Hours per 

Year 

(AxB)

(D) 

Respondents 

per Year (a)

(E) 

Technical 

Person 

Hours per 

Year 

(CxD)

(F) 

Managerial 

Hours per 

Year 

(Ex0.05)

(G) 

Clerical 

Hours 

per Year 

(Ex0.10)

(H) 

Total 

Cost per

year $

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions b1 1 1 0 0 0 0 $0

B. Required Activities

 Tests

Initial performance test - APCD c445 1 445 0 0 0 0 $0

Conduct performance test method audits c27 1 27 0 0 0 0 $0

Repeat initial performance test - APCD d445 1 445 0 0 0 0 $0

Repeat performance test method audits d27 1 27 0 0 0 0 $0

Initial performance pest - total enclosure d215 1 215 1 215 10.75 21.5 $23,940.90

Repeat initial performance test - total enclosure d215 1 215 0.2 43 2.15 4.3 $4,788.18

Performance test for VOC CEMs d175 1 175 0 0 0 0 $0

Quarterly VOC CEM audits f10 4 40 3 120 6 12 $13,362.36

C. Create Information

See 3B and

4E

D. Gather Existing Information

See 3B and 

4E

E. Write Reports

Notification of intent to construct/reconstruct e6 1 6 1 6 0.3 0.6 $668.12

Notification of construction date e2 1 2 1 2 0.1 0.2 $222.71
16

Burden Items (a, b)

(A) 

Hours per 

Occurrence

(B) 

Occurrences 

per Year

(C) 

Hours per 

Year 

(AxB)

(D) 

Respondents 

per Year (a)

(E) 

Technical 

Person 

Hours per 

Year 

(CxD)

(F) 

Managerial 

Hours per 

Year 

(Ex0.05)

(G) 

Clerical 

Hours 

per Year 

(Ex0.10)

(H) 

Total 

Cost per

year $

Actual startup notification e2 1 2 1 2 0.1 0.2 $222.71

Notification of applicability of the standard 

existing sources b2 1 2 0 0 0 0 $0

Notification of applicability of the standard 

new/reconstructed sources e2 1 2 1 2 0.1 0.2 $222.71

Notification of initial performance test g2 1 2 0 0 0 0 $0

Report of initial test See 3B 0 0 0 $0

Notification of compliance status h4 1 4 0 0 0 0 $0

Submit startup, shutdown, malfunction plan h20 1 20 0 0 0 0 $0

Develop and implement quality control plan for 

continuous monitoring systems (CMS) h50 1 50 0 0 0 0 $0

Report when exceed HAP usage cutoff (or report 

area source becoming major sources) i2 1 2 0 0 0 0 $0

Waiver application b6 1 6 0 0 0 0 $0

Report of monitoring exceedances and periods of 

noncompliance, including inconsistencies with 

startup, shutdown, and malfunction reports j16 4 64 0.6 38.4 1.92 3.84 $4,275.96

Report of no excess emissions, including startup, 

shutdown, malfunction reports j4 2 8 5.4 43.2 2.16 4.32 $4,810.45

Subtotal for Reporting Requirements 542.34 $52,514.07

4. Recordkeeping Requirements

A. Read Instructions See 4A

B. Plan Activities N/A

C. Implement Activities See 4D

D. Develop Record System h, k 40 1 40 0 0 0 0 $0
17

Burden Items (a, b)

(A) 

Hours per 

Occurrence

(B) 

Occurrences 

per Year

(C) 

Hours per 

Year 

(AxB)

(D) 

Respondents 

per Year (a)

(E) 

Technical 

Person 

Hours per 

Year 

(CxD)

(F) 

Managerial 

Hours per 

Year 

(Ex0.05)

(G) 

Clerical 

Hours 

per Year 

(Ex0.10)

(H) 

Total 

Cost per

year $

E. Time to enter information

Facilities above cutoff, including records 

associated with startup, shutdown, malfunction, 

maintenance of APCD, and measurement of 

freeboard ratio l0.5 350 175 6 1,050 52.5 105 $116,920.65

Maintain, adjust, and calibrate CMS and maintain 

records of this and any CMS malfunction that 

occurs m6 52 312 6 1,872 93.6 187.2 $208,452.82

Facilities below cutoff n2 1 2 1 2 0.1 0.2 $222.71

F. Time to Train Personnel N/A

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 3,362.6 $325,596.17

Total Labor Burden and Cost (rounded) 3,905 $378,110

Assumptions:

a This ICR uses the following labor rates: $121.44 for Managerial, $100.23 for Technical, and $50.51 for Clerical.

b This cost was incurred during the first year.

c

 Hours associated with the initial performance test include preparation of site-specific test plan. Hours for performance test method audits are 

estimated as 6 percent of the performance test hours. No facility is expected to conduct testing for the air pollution control device (APCD) and 

CEMS.

d

 We have assumed 20 percent of sources will have to be retested (equals zero).

e

 It is projected that, on average, new coating lines will be added at the rate of one per year. These coating lines will be located at existing facilities 

which will already be meeting the reporting and recordkeeping requirements of the standard. Also, additional emission points are likely to be tied 

into the existing APCD. Therefore, new compliance tests for the APCD and continuous monitors will not be necessary. However, as new total 

enclosure would be built and must be tested.

f All facilities using VOC continuous emission monitors (CEMs) will have to perform quarterly audits of monitors, estimated at three facilities.
18

g

 No facilities are expected to conduct an initial performance test.

h

 No facilities are expected to be required to report on status, or develop a startup, shutdown, malfunction plan, quality control plan for continuous 

monitoring system (CMS), or record system.

i

 No existing area sources are expected to exceed the HAP usage cutoff or become a major source.

j These reports will include data based on CMS performance and/or material balance results. It is assumed to 90 percent of the facilities in this 

source category will have no excess emission: reporting will therefore be semiannual. We assume that 10 percent of the facilities in this source 

category will be submitting reports.

k

 Activities that must be implemented at all facilities include maintaining a 75 percent freeboard ration in wash sinks, the use of a closed system for 

flushing fixed lines, and the use of a closed system for particulate transfer. A record system will need to be developed to maintain records 

associated with the freeboard ratio, performance test, notification, and CMS QA/QC program.

l

 All facilities subject to the control requirements of the standard will be keeping records.

m

 All but one of the 6 facilities subject to the rule will operate a CMS, as defined in Section 63.2 of the proposed General Provisions. The one 

facility that will not operate a CMS has only one control device and will be keeping records.

n

 Facilities that fall below the HAP usage cutoff will have to submit an annual report certifying this usage. One facility is expected to be subject to 

this requirement.
19

Table 2: Average Annual EPA Burden and Cost – NESHAP for Magnetic Tape Manufacturing Operations (40 CFR Part 63, 

Subpart EE) (Renewal)

Activity

(A) 

EPA Hours 

per 

Occurrence

(B) 

Occurrences 

per Year

(C) 

EPA 

Hours 

per Year 

(AxB)

(D) 

Plants 

per Year 

(a)

(E) 

Technical 

Hours 

per Year 

(CxD)

(F) 

Managerial 

Hours per

Year 

(Ex0.05)

(G) 

Clerical 

Hours 

per Year 

(Ex0.10)

(H) 

Cost, $

Initial performance test b60 0 0 0 0 0 0 $0

Repeat initial performance test c 2 0 0 0 $0

1. Retesting preparation 16 0 0 0 0 0 0 $0

2. Retesting 60 0 0 0 0 0 0 $0

Report Review

Notification of construction/reconstruction e2 1 2 1 2 0.1 0.2 $103.65

Notification of construction data d2 1 2 1 2 0.1 0.2 $103.65

Notification of actual startup d2 1 2 1 2 0.1 0.2 $103.65

Notification of applicability -existing sources e2 0 0 0 0 0 0 $0

Notification of applicability - new/ reconstruction 

sources d2 1 2 1 2 0.1 0.2 $103.65

Notification of initial performance test f2 1 2 1 2 0.1 0.2 $103.65

Report of initial performance test f8 1 8 1 8 0.4 0.8 $414.60

Notification of compliance status e4 0 0 0 0 0 0 $0

Startup, shutdown, malfunction plan h4 0 0 0 0 0 0 $0

Quality control plan for CMS h4 0 0 0 0 0 0 $0

Report of monitoring exceedances and periods of 

noncompliance i8 1 8 0.6 4.8 0.24 0.48 $248.76

Report of no excess emissions i2 2 4 5.4 21.6 1.08 2.16 $1,119.41

Report for facilities blow cutoff j1 1 1 1 1 0.05 0.1 $51.82

Report of area source becoming a major source or 

exceeding HAP usage cutoff k8 0 0 0 0 0 0 $0
20

Activity

(A) 

EPA Hours 

per 

Occurrence

(B) 

Occurrences 

per Year

(C) 

EPA 

Hours 

per Year 

(AxB)

(D) 

Plants 

per Year 

(a)

(E) 

Technical 

Hours 

per Year 

(CxD)

(F) 

Managerial 

Hours per

Year 

(Ex0.05)

(G) 

Clerical 

Hours 

per Year 

(Ex0.10)

(H) 

Cost, $

Waiver application l8 0 0 0 0 0 0 $0

Total Labor Burden and Cost (rounded) 52 $2,353

Assumptions:

a

 This ICR uses the following labor rated: $62.27 for Managerial, $46.21 for Technical, and $25.01 for Clerical.

b

 We assume that 10 percent of the number of tests conducted is attended by EPA.

c

 We assume that 20 percent will fail the initial performance tests and will have to be retested.

d

 We assume that one new coating line will be added per year. This line will be at an existing facility.

e

 We assume that the notification of the applicability of the standard for existing sources has already occurred.

f

 This is based on one facility conducting test, including retesting.

g We assume that no facility will require notification.

h

 We assume that EPA will not review startup, shutdown, malfunction plans and CMS quality control plans.

i

 The number of noncompliance reports and reports of no excess emissions correspond to the respondents per year reported in Table 1 (column D) multiplied by 

the number of occurrences per year reports in Table 1 (column B).

j

 There will be one existing facility expected to be below the solvent usage cutoff.

k

 We assume that no existing area sources are expected to exceed the HAP usage cutoff or become area sources.

l

 We assume that all waiver applications have been submitted.