SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY 1. Identification of the Information Collection 1(a) Title of the Information Collection NSPS for Magnetic Tape Coating Facilities (40 CFR part 60, subpart SSS ) (Renewal) , EPA I CR Number 1135.10, OM B Control Number 2060

- 0171 1(b) Short Characterization/Abstract The New Source Performance Standards (NSPS) for the Magnetic Tape Coating Facilities ( 40 CFR part 60, subpart SSS ) were proposed on January 22, 1986, and promulgated on October 3, 1988. Th ese standards apply to each coating operation and each piece of coating mix preparation equipment commencing construction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with these regulations

. Approximately

six sources are currently

subject to the standard, and it is estimated that no additional sources will become subject to the regulation in the next three years. It is further assumed that two coating lines per year are to be construc ted at existing sources over the next three y ears. There is a reduction in the number of sources due to industry consolidation. The current I CR is based on the most recently approved Information Collection Request (ICR). All reports are sent to the dele gated State, or local authority . In the event that there is no such delegated authority , the reports are sent directly to the EPA Regional Office. OMB approved the currently active I CR without any “ Terms of Clearance ”

. 2. Need for and Use of the Collec tion 2(a) Need/Authority for the Collection The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality

health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated

. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four y ears.2

Inaddition, 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 proced

ures, 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 parameter s, 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

. Inthe Administrator's judgment, Volatile Organic Compound (VOC) emissions from magnetic tape manufacturing either cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS were pr omulgated for this source category

at 40 CFR part 60, subpart SSS

. 2(b) Practical Utility/Users of the Data The control of emissions of Volatile Organic Compounds (VOCs) from magnetic tape manufacturing requires not only the installation of properly de signed equipment, but also the operation and maintenance of that equipment. Emissions of VOCs from magnetic tape manufacturing are the result of the operation of coating equipment, and the operation of coating mix preparation equipment. The subject stand ards are achieved by the recovery , or destruction of VOC emissions by

control devices. The recordkeeping and reporting requirements in the standard ensures compliance with the applicable regulations which where promulgated in accordance with the Clean A ir 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. 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 rev iewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and the standards are being met. The performance test may also be observed. 3. Non
- duplication, Consultations, and Other Collecti on Criteria3

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart SSS. 3(a) Non
- duplication If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Oth erwise, the information is sent directly to the delegated state , or local agency . I f 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, 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 I CR was publi shed in the Federal Register on July 8, 2009 ( 74 FR 3258 1 ). No comments were received on the burden published in the Federal Register

. 3(c) Consultations For this information collection, the previous I CR renewal was used to obtain burden estimates sinc e this I CR renewal was processed under the “Expedited Approach” option provided in May 1, 2008 guidance . Per this guidance, all data and assumptions from the previous I CR renewal were used as the basis for estimating the hourly and cost burdens associated with this renewal.
Itis our policy

to respond after a thorough review of comments received since the last IC R renewal as well as those submitted in response to the first Federal Register notice. Inthis 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 g ood operation and maintenance practices are applied and emission limitations are met. I f 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 s any of the regulations established by

OMB at 5 CFR Part 1320, Section 1320.5. 3(f) Confidentiality4

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; ame nded 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. 4. The Respondents and the Information Requested 4(a) Respondents/SIC and NAICS Codes The respondents to the recordkeeping and reporting requirements are magnetic tape manufacturers. The SI C code for the respondents affected by the standards is SI C (United States Standard Industrial Classification) 3695 which corresponds to the NAI CS (The North American In dustry Classification Sy stem) 334613 for magnetic and optical recording media manufacturing. 4(b) Information Requested (i) Data Items All data in this I CR that is recorded and/or reported is required by 40 CFR part 60, subpart SSS. A source must make the following reports:

Notification s Construction/reconstruction 60.7(a)(1) Actual startup 60.7(a)(3) In itial performance test results 60.8(a) In itial performance test 60.8(d) Demonstration of continuous monitoring sy stem 60.7(a)(5) Phy sical or operational change 60.7(a)(4) A source must keep the following records: Recordkeeping5 Recordkeeping Startups, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 60.7(b)
Records are required to be retained for two years. Records must be kept onsite. 60.717

Electronic Reporting Currently , sources are using monitoring equipment that provides parameter data in an automated way , e.g., in let and outlet concentrations when determining percent efficiency

. 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. Ina ddition, some regulatory agencies are setting up electronic reporting sy stems to allow sources to report electronically

which is reducing the reporting burden. However, electronic reporting sy stems are still not widely used by the regulatory

agencies. It is estimated that approximately 10 percent of the respondents use electronic reporting.

ii. Respondent Activities

Respondent Activities Read instructions. In stall, calibrate, maintain, and operate a device to indicate cumulative VOC recovered (whe n monthly liquid balance is to be performed) [40 CFR, Section 60.713(b)(1)]. Monthly liquid material balance [40 CFR, Section 60.714(b)]. Maintain records of projected, and actual solvent consumption [40 CFR, Section 60.714(a), 40 CFR, Section 60.717( b), (c)]. In stall, calibrate, maintain, and operate monitoring devices to track control sy stem parameters [40 CFR, Section 60.714(c) through (g)]. Maintain records of periods when control device not operating [40 CFR, Section 60.714(h)]. Monthly dete rmination of average VOC content of coatings [40 CFR, Section 60.714(j)]. Reports of projected and actual solvent consumption [40 CFR, Section 60.717(b)]. Semiannual reports when no quarterly reports required [40 CFR, Section 60.717(e)]. Quarterly re ports of monitoring 40 CFR, Section 60.717(d) exceedances and periods of noncompliance recorded under (40 CFR, Section 60.714).6 Respondent Activities Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required rep orts 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. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information

. 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 requir ed information. Agency Activities Observe initial performance tests and repeat performance tests if necessary

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

. Audit facility

records. Input, analy

ze, and maintain data in the Air Facility Sy stem (AFS). 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 operated. Performance test reports are used by the Agency

to discern a source ’ s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved . Data and records maintained by the respondents are tabulated and published for use in7

compliance and enforcement programs.
In formation contained in the reports is entered into the AFS which is operated and maintained by

EPA ’ s Office of Compliance. A FS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 1 25 ,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by

local and state regulato ry agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analy ze the data. The records required by

this regulation must be retained by the owner or operator for two y ears. 5(c) Small Enti ty Flexibility There are no small businesses affected by this regulation at present, and no small businesses are expected to become subject to the regulation in the next three years. 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 for NSPS for Magnetic Tape Coating Facilities (40 CFR part 60, subpart SSS) (Renewal)

. 6. Estimating the Burden and Cost of the Collection Table 1 docum ents 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 th e concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct , or sponsor, and a person is not requ ired to respond to, a collection of information unless it display s a currently valid OMB Control Number. 6(a) Estimating Respondent Burden The av erage annual burden to industry o ver the next three years from these recordkeeping and reporting requirement s is estimated to be 2,017 (Total L abor Hours from Table 1 below ). The recordkeeping hours shown in Table 1 are 1, 051 .8

. The reporting requirement hours shown in Table 1 are 965 .6

. These hours are based on Agency studies and background documents from th e development of the regulation, Agency knowledge and experience with the NSPS program, the previously

approved I CR, and any

comments received.
6(b) Estimating Respondent Costs8
(i) Estimating Labor Costs This I CR uses the following labor rates:
Man agerial $114.49 ($54.52 + 110%) Technical $98.20 ($46.76 + 110%) Clerical $48.53 ($23.11 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2009, “ Table 2. Civilian Workers, by occupational and ind

ustry 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 and Operations and Maintenance Co sts The ty pe of industry

costs associated with the information collection activity in the standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital / startup costs are one tim e costs when a new line becomes subject to the standard. The annual operations and maintenance costs are the ongoing costs to maintain the monitor (s) and other costs such as photocopying and postage

(iii) Capital/Startup vs. Operating 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 Res pondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

CEM $29,000 1 $29,000 $2,100 4 (60% of sources) $4,800
Thermocouple $2,300 2 $4,600 $8,000 6 $48,000 The total capital/startup costs for this I CR are $33,600. This is the total of column D in the above table. The total operation and maintenance costs for this I CR are $52,800. This is the total of column G. The total respondent costs have been calculated as the addition of the capital/startup costs, and the annual op eration and maintenance costs. The average annual cost for9

capital/startup and operation and maintenance costs to industry over the next three y ears of the IC R is estimated to be $86,400. The continuous monitoring costs that are included in this section consist only

of those capital/startup and O&M costs that a source incurs as a result of the standard. Some continuous monitoring costs may not be included in this section. For instance, if a particular industry

ty pically utilizes a control device that must have a continuous monitor (e.g., temperature, pressure drop, etc.) to function properly , and the recordation of additional measurements beyond the minimum are required by the standard, then there is no capital/startup or O&M cost, but there is a labor cost to record the additional readings. Such a cost would not appear in this section, but in the industry burden Section 6(d) below. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the rep orted 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 inform ation. The average annual Agency cost during the three y ears of the I CR is estimated to be $ 6, 892

. This cost is based on the average hourly labor rate as follows: Managerial $6 2.27 (GS

- 13, Step 5, $38. 92 + 60%) Technical $4 6

. 21 (GS

- 12, Step 1, $2 8. 88 + 60%) Clerical $2 5.01 (GS

- 6, Step 3, $15. 63 + 60%) These rates are from the Office of Personnel Management (OPM), 2010 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: Annual Agency Burden and Cost for NSPS for Magnetic Tape Coating Facilities ( 40 CFR part 60, subpart SSS ) (Renewal). 6(d) Estimating the Respo ndent Universe and Total Burden and Costs Based on our research for this I CR, approximately six (6) existing sources currently are subject to the standard. It is estimated that an additional zero sources per year will become subject to the regulation in the next three y ears. It is further assumed that two coating lines per ye ar are to be constructed at existing sources over the next three years. Number of respondents is calculated using the following table which addresses the three ye ars covered by

this IC R.10 Number of Respondents Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records but Do Not Sub mit Reports (D)

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

Number of Respondents (E=A+B+C

- D)

1 2 6 0 2 6 2 2 6 0 2 6 3 2 6 0 2 6 Average 2 6 0 2 6
To avoid double

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

- ye ar period of this I CR is six (6). The total number of annual responses per year is calculated using the following table: Total Annual Responses (A) Number of New Respondents (B)

Number of Reports for New Respondents (C)

Number of Existing Respondents (D)

Number of Reports for Existing Respondents (F)

Number of Existing Respondents That Keep Records but Do Not Submit Reports (E) Total Annual Responses E=(AxB)+(CxD)+F

2 4 6 2 .5 0 23 The number of Total Annual Responses is 2 3

. The total annual labor costs are $ 190,824 . Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost for NSPS for Magnetic Tape Coating Facilities ( 40 CFR part 60, subpart SSS ) (Renewal). Note that the total annual capital and O&M costs to the regulated entity are $86,400. These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. 6(e) Bottom Line B urden Hours and Cost Tables The bottom line burden hours and cost tables for both the Agency and the respondents are attached. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 88 hours per re sponse.11

6(f) Reasons for Change in Burden There is no change in the labor hours to the respondents in this I CR compared to the previous I CR because the regulations have not changed over the past three years and are not anticipated to change over the next three y ears. Since this I CR renewal was approved to be processed under the “Expedited Approach” option , EPA has maintained the same estimate for the number of sources currently subject to this standard as indicated in the most recently approved IC R. Ther efore, the labor hours figures in the previous I CR reflect the current burden to the respondents and are reiterated in this I CR

. However, there is a decrease number of respondents currently identified in the OMB Inventory of Approved I CR Burdens. This de crease was due to the number of respondents being incorrectly assigned in the Information Collection Request, Review, and Approval Sy stem (I CRAS). 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of infor mat ion is estimated to average 88 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 neede d to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the exis ting 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 disclo se the information. An agency

may not conduct , or sponsor, and a person is not required to respond to, a collection of information unless it display s a valid OMB control number. The OMB control numbers for EPA ’ s regulations are listed at 40 CFR part 9 an d 48 CFR chapter 15. To comment on the Agency ’ s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket I D Number EPA

- HQ

- OECA

- 200 9

- 0 419 . 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 pub lic comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem , select “search,” then key in the docket I D number identif ied 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 C enter 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 telephone12

number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 1752 . Also, comments can be sent to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office r for EPA. Please include the EPA Docket I D Number EPA

- HQ

- OECA

- 2009

- 0419 and OMB Control Number 2060

- 0171 in any correspondence.
Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.