1 SF 83 SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY STANDARDS OF PERFORMANCE NEW SOURCE PERFORMANCE STANDARD ( NSPS) Subpart SSS, MAGNETIC TAPE MANUFACTURING 1. Identification of the Information Collection 1( a) Title of the Information Collection ICR for NSPS Subpart SSS, Magnetic Tape Manufacturing.

1( b) Short Characterization/ Abstract In general all NSPS standards require initial notifications,

performance tests, and periodic reports. Owners or operators 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, in general, of all sources subject to NSPS.

Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least 2 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 EPA Regional Office.

The New Source Performance Standards ( NSPS) for Subpart SSS, 2 Magnetic Tape Manufacturing were proposed on The New Source Performance Standards ( NSPS) for the magnetic tape manufacturing industry were proposed on January 22, 1986, and promulgated on October 3, 1988. These standards apply to each coating operation and each piece of coating mix preparation equipment for which construction, modification or reconstruction commenced after January 22, 1986. This information is being collected to assure compliance with 40 CFR Part 60 Subpart SSS.

Approximately 10 sources are currently subject to the standard, and it is estimated that an additional 3 sources per year will become subject to the standard in the next three years.

This information was developed from the Agency's IDEA data base and in discussions with the Electronic Industries Association.

Volatile organic compounds ( VOC's) are the pollutants regulated under this Subpart.

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,

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 nonair quality health and environmental impact and 3 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 years.

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

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

In the Administrator's judgment, Volatile Organic Compound emissions from Magnetic Tape Manufacturing cause or contribute to 4 air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, NSPS were promulgated 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 designed equipment, but also the operation and maintenance of that equipment. Emissions of VOCs from Magnetic Tape Manufacturing are the result of operation of coating equipment, and operation of coating mix preparation equipment. These standards rely on the recovery or destruction of VOC emissions by control devices. The required notifications are used to inform the Agency or delegated authority when a source becomes subject to the standard. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and the standard is being met. Performance test reports are needed as these are the Agency's record of a source's initial capability to comply with the emission standard, and serve as a record of the operating conditions under which compliance was achieved. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the 5 Agency to ensure that facilities affected by the NSPS continue to operate the control equipment and achieve compliance with the regulation. Adequate monitoring, recordkeeping, and reporting is necessary to ensure compliance with these standards, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.

3. Nonduplication, Consultations, and Other Collection Criteria The recordkeeping and reporting requested is required under 40 CFR Part 60 Subpart SSS.

3( a) Nonduplication If the standard has not been delegated the information is sent to the appropriate EPA Regional Office. Otherwise, the information is sent directly to the delegated State or Local Agency. If a State or Local Agency has adopted their own similar regulation to implement the Federal Regulation, 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 Standard. Therefore, no duplication exists.

3( b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this ICR was published in the Federal Register on March 31,

2000. 6 3( c) Consultations No comments were received on the burden published in the Federal Register.

3( d) Effects of Less Frequent Collection Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the required 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 likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease.

3( e) General Guidelines None of these reporting or recordkeeping requirements violate any of the regulations established by OMB in 5 CFR 1320.6.

3( f) Confidentiality The required information consists of emissions data and other information that have been determined not to be private.

However, 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 ( see 40 CFR 7 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 None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested 4( a) Respondents/ SIC Codes The respondents of the recordkeeping and reporting requirements are magnetic tape manufacturers ( SIC Code 3695)

which commenced construction, modification, or reconstruction after January 22, 1986.

4( b) INFORMATION REQUESTED ( i) Data Items All data in this ICR that is recorded and/ or reported is required by 40 CFR Part 60 Subpart SSS, Magnetic Tape Manufacturing.

Reports for NSPS SUBPART SSS Construction/ reconstruction 60.7( a)( 1)

Anticipated startup 60.7( a)( 2)

Actual startup 60.7( a)( 3)

Initial performance test results 60.8 ( a)

Initial performance test 60.8( d)

Demonstration of continuous monitoring system 60.7( a)( 5)

Physical or operational change 60.7( a)( 4) 8 Recordkeeping for NSPS SUBPART SSS Startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative 60.7( b)

Records are required to be retained for 2 Years. Records must be kept onsite. 60.717 ii. Respondent Activities Respondent Activities Read instructions.

Install, calibrate, maintain, and operate a device to indicate cumulative VOC recovered ( when monthly liquid balance is to be performed) ( 40 CFR 60.713( b)( 1)).

Monthly liquid material balance ( 40 CFR 60.714( b)).

Maintain records of projected, and actual solvent consumption ( 40 CFR 60.714( a), 40 CFR 60.717( b),( c)).

Install, calibrate, maintain, and operate monitoring devices to track control system parameters ( 40 CFR 60.714( c) through ( g)).

Maintain records of periods when control device not operating ( 40 CFR 60.714( h)).

Monthly determination of average VOC content of coatings ( 40 CFR 60.714( j)).

Reports of projected and actual solvent consumption ( 40 CFR 60.717( b)).

Semiannual reports when no quarterly reports required ( 40 CFR 60.717( e)).

Quarterly reports of monitoring 40 CFR 60.717( d) exceedances and periods of noncompliance recorded under ( 40 CFR 60.714).

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. Respondent Activities 9 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 Aerometric Information Retrieval System ( AIRS) database.

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

Information contained in the reports is entered into AIRS which is operated and maintained by EPA's Office of Air Quality Planning and Standards. AIRS is EPA's database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government owned facilities. EPA uses AIRS for tracking air pollution compliance and enforcement by Local and State regulatory agencies, and EPA Regional Offices and 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 or operator for two years.

5( c) Small Entity Flexibility There are very few if any small businesses affected by this standard, however, any impact on small businesses was accounted for in the regulation development. The requirements reflect the burden on small businesses. In addition, the recordkeeping and reporting requirements were selected within the context of a small collection of process equipment and reflect the burden on 11 small businesses. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. Even though the recordkeeping and reporting requirements are the same for small and larger businesses, the Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small businesses.

5( d) Collection Schedule The specific frequency for each information collection activity within this request is shown in Table 2: Industry Burden.

6. Estimating the Burden and Cost of the Collection Table 2 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for each of the subparts 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 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 12 estimated at 3,891( total from industry table 2) person hours.

These hours are based on Agency studies and background documents from the development of the standards or test methods, 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 technical labor rates of $ 54.94 per hour.

These rates are from the United States Department of Commerce Bureau of Labor Statistics, March 1999, Table 10: Employment Costs for Private Industry by Occupational and Industry Group.

The rates are from column 1: Total compensation. The wage rates have been loaded by adding 110% overhead.

( ii) Estimating Capital and Operations and Maintenance Costs The type of industry costs associated with the information collection activity in the standards are labor and CEMs. The capital start up costs are one time costs when a facility becomes subject to the standard. The annual operations and maintenance costs are the ongoing costs to maintain the monitor. Total respondent costs have been calculated on the addition of the capital start up costs and the annual operations and maintenance costs.

( iii) Capital/ Start up vs. Operating and Maintenance ( O& M) Costs The total Capital/ Start up costs for this ICR are $ 27,000. 13 This cost is shown on the OMB 83 I form in block 14 letter a:

Total annualized capital/ startup costs. The numbers in block 14 of the OMB 83 I form are truncated to show the cost in thousands of dollars. The one new CEM would cost $ 25,000. A new thermocouple costs $ 2,000 for the new facility, making total annual capital start up cost $ 27,000.

The total annualized Operating and Maintenance ( O& M) Costs for this ICR are $ 66,000. This cost is shown on the OMB 83 I form in block 14 letter b: Total annual costs ( O& M). The numbers in block 14 of the OMB 83 I form are truncated to show the cost in thousands of dollars. Thermocouples have an O& M cost of $ 1,800 per year. The 10 existing facilities X $ 1,800 equals $ 18,00 for annual O& M costs for thermocouples. Operation and maintenance ( O& M) costs for the CEMs is estimated to be $ 7,000 per year. It is estimated that sixty percent of existing sources need CEMs, ( or 6 sources), therefore, 6 X $ 7,000 equals $ 42,000 for CEMs. This makes the total annualized Operating and Maintenance ( O& M) Costs for this ICR to be $ 66,000 ($ 18,000 +

$ 48,000).

The total respondent costs have been calculated on the addition of the capital start up costs and the annual operations and maintenance costs. The average annual cost for capital and operations and maintenance costs to industry over the next three years of the ICR is estimated to be $ 93,000 ($ 66,000 +$ 27,000).

This cost is shown on the OMB 83 I form in block 14 letter c:

Total annualized cost requested. The numbers in block 14 of the 14 OMB 83 I form are truncated to show the cost in thousands of dollars.

6( c) Estimating Agency Burden and Cost The only Federal costs are user costs associated with analysis of the reported information. Publication and distribution of the information are part of the AIRS program.

Examination of records to be maintained by the respondents will occur as part of the periodic inspection of sources, which is part of EPA's overall compliance and enforcement program.

The average annual Federal Government cost during the 3 years of the ICR is estimated to be $ 9,753( from table 1). This cost is based on an average wage of a ( GS 10 step 1 employee rate, ($ 17.09 hr + 110% overhead = $ 35.89 or if previous ICR has specific breakdowns use them) . This rate is from OPM's 2000 General Schedule, excluding locality pay, basic rates and travel associated with compliance activities. Details upon which this estimate is based appear in Table 1: Agency Burden.

6( d) Estimating the Respondent Universe and Total Burden and Costs Respondant Universe Regulation Title ( A) # new sources per year ( B) # of initial reports for new sources ( C) # existing sources ( D) # of reports for existing sources ( E) total annual responses ( AXB)+( CXD)

3 2 10 5 56 The number of total respondents is 13. It is shown on the 15 OMB 83 I form in block 13 a. This is the number of existing sources plus the number of sources anticipated in one year.

Approximately 10 sources are currently subject to the standard,

and it is estimated that an additional 3 new sources per year will become subject to the standard in the next three years.

The total annual responses is 56. This number is in column E of the Respondant Universe table. It is shown on the OMB 83 I form in block 13 b. The total annual labor costs are $ 213,785.

This number is shown on the OMB 83 I form in block 13 c. Details upon which this estimate is based appear in Table 2: Industry Burden.

The total annual capital and O& M costs to the regulated entity are $ 93,000. This number is shown on the OMB 83 I form in block 14 c. These costs are detailed in section 6 b ( iii)

Capital/ Start up vs. Operating and Maintenance ( O& M) Costs.

6( e) Bottom Line Burden Hours And Cost Tables See Tables 1 and 2.

6( f) Reasons for Change in Burden The decrease] in burden from the most recently approved ICR is due to an adjustment. This decrease in burden is due to more accurate estimates of existing and anticipated new sources.

6( g) Burden Statement Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or 16 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 currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director,

Collection Strategies Division, Office of Environmental Information ( OEI), U. S. Environmental Protection Agency, Mail code 2822, 1200 Pennsylvania Avenue, NW, Washington, D. C. 20460;

and to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 17 20503, Attention: Desk Officer for EPA. Include the EPA ICR number 1135.07 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.


Record for the Proposed Section 316( b) Rule for Phase III Facilities 1 2 3 4 5 6 7 8 9 10 11 12 13 A B C D E Date Modified: 5/ 25/ 2006 By: Abt Associates Inc.

Data Sources:

Description: Compiles Average Yield to Maturity on Selected Long Term Bonds Purpose: For use in the capital expenditures estimate The original version of this file contains, or is linked to a file that contains, confidential business information ( CBI), or information that could be used to reveal CBI. As a result, the values for any variables determined by EPA to be CBI, or that could be used to reveal CBI, have been replaced with dummy values. Such variables have been marked with light orange highlight. It should be noted that the dummy values have been added to illustrate how the spreadsheets work; they may not always be consistent with other data provided for the same model facility. Any observed patterns of the dummy values is for illustration purposes only and has no significance with respect to the original values. It should also be noted that any information that uses the dummy values will not show the true results of EPA's analysis.

November 1, 2004 1 of 3 DCTM_ ARP. xls  File Info Record for the Proposed Section 316( b) Rule for Phase III Facilities 1 2 3 4 5 6 7 8 9 10 11 12 A B Date Yield 1992 8.98 1993 7.93 1994 8.63 1995 8.2 1996 8.05 1997 7.87 1998 7.22 1999 7.88 2000 8.37 2001 7.95 2002 7.8 November 1, 2004 2 of 3 DCTM_ ARP. xls  SAS Record for the Proposed Section 316( b) Rule for Phase III Facilities 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 A B C D E F G H I J K L M N O AVERAGE YIELD TO MATURITY ON SELECTED LONG TERM BONDS.

http:// www. federalreserve. gov/ Releases/ H15/ data. htm Year Aaa Baa Diff 1976 8.43 9.75 1.32 1977 8.02 8.97 0.95 1978 8.73 9.49 0.76 1979 9.63 10.69 1.06 1980 11.94 13.67 1.73 1981 14.17 16.04 1.87 1982 13.79 16.11 2.32 1983 12.04 13.55 1.51 1984 12.71 14.19 1.48 1985 11.37 12.72 1.35 1986 9.02 10.39 1.37 1987 9.38 10.58 1.2 1988 9.71 10.83 1.12 1989 9.26 10.18 0.92 1990 9.32 10.36 1.04 1991 8.77 9.8 1.03 1992 8.14 8.98 0.84 1993 7.22 7.93 0.71 1994 7.97 8.63 0.66 1995 7.59 8.2 0.61 1996 7.37 8.05 0.68 1997 7.27 7.87 0.6 1998 6.53 7.22 0.69 1999 7.05 7.88 0.83 2000 7.62 8.37 0.75 2001 7.08 7.95 0.87 2002 6.49 7.8 1.31 0 2 4 6 8 10 12 14 16 18 Year 1977 1979 1981 1983 1985 1987 1989 1991 1993 1995 1997 1999 2001 Year Average Yield to Maturity Aaa Baa Diff November 1, 2004 3 of 3 DCTM_ ARP. xls  Data