0660ss13

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal), EPA ICR Number 0660.13, OMB Control Number 2060-0107.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) were proposed on January 5, 1981, promulgated on November 1, 1982, and amended on both June 24, 1986, and October 17, 2000. These regulations apply to the following surface coating lines in the metal coil surface coating industry: each prime coat operation; each finish coat operation; and each prime and finish coat operation cured simultaneously, where the finish coat is applied wet-on-wet over the prime coat. These regulations apply to facilities commencing construction, modification, or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 60, Subpart TT.

In general, all NSPS standards require initial notification reports, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least two years following the generation date of such maintenance reports, and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The “burden” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal). There are approximately 158 metal coil surface coating facilities which are owned and operated by the metal coil industry. None of the 158 facilities in the United States are owned by either state, local, tribal or the Federal government. They are all privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries.

Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 158 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every eight years.

In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator’s judgment, volatile organic compound (VOC) emissions from metal coil surface coating lines either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart TT.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standards. Continuous emission monitors are used to ensure compliance with these standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of these regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and leaks are being detected and repaired and that these standards are being met. The performance test may also be observed.

The required semiannual and quarterly 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 60, Subpart TT.

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 (82 FR 29552) on June 29, 2017. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 158 respondents will be subject to these standards over the three-year period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the National Coil Coating Association, at 216-241-7333, and Aleris International, at 216-910-3400.

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 these standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

3(f) Confidentiality

Any information submitted to the Agency, for which a claim of confidentiality is made, will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities engaged in metal coil surface coating. The United States Standard Industrial Classification (SIC) code for the respondents affected by these standards and the corresponding North American Industry Classification System (NAICS) codes are listed below for the metal coil surface coating source category.

Standard (40 CFR Part 60, Subpart TT)	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
Iron and Steel Mills and Ferroalloy Manufacturing	3313	331110
Rolled Steel Shape Manufacturing	3312	331221
Alumina Refining and Primary Aluminum Production	3334	331313
Aluminum Sheet, Plate, and Foil Manufacturing	3353	331315
Other Aluminum Rolling, Drawing, and Extruding	3355	331318
Copper Rolling, Drawing, Extruding, and Alloying	3341	331420
Fabricated Structural Metal Manufacturing	3441	332312
Sheet Metal Work Manufacturing	3444	332322
Prefabricated Metal Building and Component Manufacturing	3448	332311
All Other Miscellaneous Fabricated Metal Product Manufacturing	3499	332999
Blind and Shade Manufacturing	2591	337920
Photographic Film, Paper, Plate, and Chemical Manufacturing	3861	325992

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT).

A source must make the following reports:

Notifications
Notification of construction/reconstruction	60.7(a)(1)
Notification of actual startup	60.7(a)(3)
Notification of physical or operational change	60.7(a)(4)
Notification of CMS demonstration date	60.7(a)(5)

Reports
Performance test results	60.8(a), 60.465(a-b)
VOC emissions report	60.7(c), 60.465(c)
Excess emissions report	60.465(c)
Temperature variance report	60.7(c), 60.465(d)

A source must keep the following records:

Recordkeeping
Maintain records of startup, shutdown, or malfunction period where the continuous monitoring system is inoperative	60.7(b)
Monthly performance test of volume-weighted average emissions of VOCs, in kg/l of coating solids applied	60.463(b), 60.463(c), 60.465(a)
Record average VOC content of coatings applied monthly	60.464(a, b)
For thermal incineration, install, calibrate, maintain, and operate temperature monitoring device	60.464(c)
For catalytic incineration: maintain daily records of upstream and downstream gas temperature	60.465(e)
Maintain daily records of incinerator combustion temperature or amounts of solvent recovered	60.464(c), 60.465(e)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate a device that continuously records the combustion temperature of any effluent gases incinerated to achieve compliance

Perform initial performance test, Reference Methods 24 or 25, or data provided by the coating formulator, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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.

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, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.

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 standards, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA’s Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two years.

5(c) Small Entity Flexibility

The majority of 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 – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor 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 16,200 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 NSPS program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $149.35 ($71.12 + 110%)

Technical $112.98 ($53.80 + 110%)

Clerical $54.81 ($26.10 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 standards 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 these regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

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

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondent	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Temperature Monitoring System	N/A	N/A	N/A	$1,200a	142	$170,400
Method 25 or 25A Performance Test	$18,750b	0	$0	N/A	N/A	$0
Total			$0			$170,000

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

^a According to industry consultation comment received on an ICR for a related rulemaking (40 CFR Part 63, Subpart SSSS), the O&M cost to maintain continuous temperature measuring monitor is $1,200 per respondent. The cost covers replacement of temperature sensor each calendar year. This cost is applied to the 80 percent of respondents assumed to use an incinerator to comply with the requirements.

^b Costs included to contract out for a one-time initial performance test using Method 25 for facilities with control devices. It is assumed that all existing facilities have conducted an initial performance test.

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

The total operation and maintenance (O&M) costs for this ICR are $170,000. 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 $170,000. These are the recordkeeping costs.

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 $44,300.

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

Managerial $64.80 (GS-13, Step 5, $40.50 + 60%)

Technical $48.08 (GS-12, Step 1, $30.05 + 60%)

Clerical $26.02 (GS-6, Step 3, $16.26 + 60%)

These rates are from the Office of Personnel Management (OPM), 2017 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 158 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 158 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR:

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	158	0	0	158
2	0	158	0	0	158
3	0	158	0	0	158
Average	0	158	0	0	158

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 158.

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

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of CMS demonstration date	0	1	0	0
VOC emissions report	158	2	0	316
Excess emissions report	16	4	0	64
Temperature variance report	126	1	0	63
			Total	411

The number of Total Annual Responses is 411.

The total annual labor costs are $1,780,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 16,200 hours (rounded). Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 39 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $170,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 945 labor hours at a cost of $44,300; see below in Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in both the respondent and Agency burdens and in the number of responses currently identified in the OMB Inventory of Approved Burdens. The increase is attributed to several adjustments as follows: 1) this renewal allows time for each source to re-familiarize themselves with the rule requirements each year; 2) this renewal adjusted the frequency of recordkeeping requirements to match the requirements in the rule. (Daily records are required for temperature for units using incinerator while monthly records of data used to support VOC calculations are required for sources that do not use an incinerator); and 3) this renewal assumed 10 percent of the sources would have excess emissions and would have to report quarterly instead of semi-annually.

There is a decrease in the capital and O&M costs currently identified in the OMB Inventory of Approved Burdens. This decrease is not due to any program changes. The decrease is attributed to an adjustment: the previous renewal had estimated O&M costs related to temperature monitoring for all sources; however, only 80 percent of the sources are anticipated to comply with the rule using incineration.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 39 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 neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2014-0026. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1728. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2014-0026 and OMB Control Number 2060-0107 in any correspondence.

Part B of the Supporting Statement

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

Table 1: Annual Respondent Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)

Burden item	(A) Person-hours per occurrence	(B) Annual occurrences per respondent	(C) Person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirements a	1	1	1	158	158	8	16	19,896.70
B. Required activities
Initial performance test c	30	0.07	2	0	0	0	0	0
Repeat performance test c	30	0.07	2	0	0	0	0	0
C. Gather existing information	See 3B
D. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	0
Notification of actual startup c	2	1	2	0	0	0	0	0
Notification of CMS demonstration date	2	1	2	0	0	0	0	0
Report of performance test c	See 3B
VOC emissions report d	5	2	10	142	1,420	71	142	178,818.47
Excess emissions report d	5	4	20	16	320	16	32	40,297.12
Temperature variance report e	4	0.5	2	126	252	12.6	25.2	31,733.98
Subtotal for Reporting Requirements					2,473			270,746
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities
Monthly VOC weighted average calculations f	1	12	12	32	384	19.2	38.4	48,356.54
D. Develop record system
Records of temperature e	0.25	365	91.25	126	11,498	575	1,150	1,447,862.93
Records of data used to support monthly VOC calculations f	0.25	12	3.0	32	96	4.8	9.6	12,089.14
Subtotal for Recordkeeping Requirements					13,774			1,508,309
TOTAL ANNUAL BURDEN AND COST (ROUNDED)g					16,200			1,780,000
Total CAPITAL and O&M COST (rounded)g								170,000
GRAND TOTAL (rounded)g					16,200			1,950,000

^a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR. This ICR assumes each respondent will incur a burden to re-familiarize themselves with the regulatory requirements each year.

^b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c This is a one-time requirement and does not apply since no new sources are estimated. EPA assumes 20% of new sources must repeat performance testing due to failure.

^d EPA assumes 10% of respondents have excess VOC emissions and must report quarterly instead of semi-annually. The remaining 90% of sources report semi-annually.

^e EPA assumes 80% of facilities will use incineration, and will file a temperature variance report every other year. These facilities will also have to maintain daily temperature records of incinerator combustion temperature (for thermal incineration) or gas temperature (for catalytic incineration).

^f EPA assumes the remaining 20% of sources do not have control devices will comply using the monthly weighted average VOC calculation approach.

^g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NSPS for Metal Coil Surface Coating (40 CFR Part 60, Subpart TT) (Renewal)

Burden item	(A) EPA person-hours per occurrence	(B) Annual occurrences per respondent	(C) EPA person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b
Initial performance test
New plant c	24	0.07	2	0	0	0	0	0
Repeat performance test
New plant c	24	1	24	0	0	0	0	0
Report review
New plant c
Notification of construction/reconstruction	2	1	2	0	0	0	0	0
Notification of actual startup	0.5	1	0.5	0	0	0	0	0
Notification of CMS demonstration date	0.5	1	0.5	0	0	0	0	0
Review test results	8	1	8	0	0	0	0	0
Existing plant
VOC emissions report d	2	2	4	142	568	28.4	56.8	30,627.70
Excess emissions report d	2	4	8	16	128	6.4	12.8	6,902.02
Temperature variance report e	2	0.5	1	126	126	6.3	12.6	6,794.17
TOTAL ANNUAL BURDEN AND COST (ROUNDED)f					945			44,300

^a On average, EPA estimates 158 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR.

^b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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.

^c This is a one-time requirement and does not apply since no new sources are estimated.

^d EPA assumes 10% of sources will have excess emissions and will file a quarterly report instead of the semi-annual frequency submitted from the other 90% of sources.

^e EPA assumes 80% of facilities will use incineration, and will file a temperature variance report every other year.

^f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.