  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR
AREA SOURCES:  POLYVINYL CHLORIDE AND COPOLYMER PRODUCTION, PRIMARY
COPPER SMELTING, SECONDARY COPPER SMELTING, AND PRIMARY NONFERROUS
METALS--ZINC, CADMIUM, AND BERYLLIUM

 

PART A

1.0  Identification of the Information Collection

(a) Title and Number of the Information Collection.

	“NESHAP for Area Sources:  Polyvinyl Chloride and Copolymer
Production, Primary Copper Smelting, Secondary Copper Smelting, and
Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium.”  This is a
new information collection request (ICR) and the EPA tracking number is
2240.01. 

 (b) Short Characterization.

	This ICR covers information collection requirements in the proposed
area source rules for primary copper smelting (40 CFR part 63, Subpart
EEEEEE), secondary copper smelting (40 CFR part 63, subpart FFFFFF), and
primary zinc production facilities (part of the primary nonferrous
metals category) in §§63.11162 through 11164 of 40 CFR part 63,
Subpart  GGGGGG.  The proposed area source rules for polyvinyl chloride
and copolymer production in 40 CFR part 63, Subpart DDDDDD and primary
beryllium production facilities (part of the primary nonferrous metals
category) in §§63.11165 and 11166 of 40 CFR part 63, Subpart GGGGGG do
not impose any new information collection burden.  New and existing
polyvinyl chloride and copolymer plants that are area sources would be
required to comply with the same testing, monitoring, recordkeeping, and
reporting requirements as those in the National Emission Standard for
Vinyl Chloride (40 CFR part 61, Subpart F).  The OMB has previously
approved the information collection requirements in 40 CFR Part 61,
Subpart F (OMB control number 2060-0071, EPA ICR no. 186.10).   New and
existing primary beryllium production facilities that are area sources
would be required to comply with the same testing, monitoring,
recordkeeping, and reporting requirements as those in the National
Emission Standard for Beryllium (40 CFR part 61, Subpart C).  The OMB
has previously approved the information collection requirements in 40
CFR Part 61, Subpart C (OMB control number 2060-0092, EPA ICR number
0193.08).

Potential respondents are owners or operators of a new or existing
primary copper smelter, a new secondary copper smelter, or a new or
existing primary zinc production facility that is an area source of
hazardous air pollutants (HAP) emissions.   For existing facilities, the
proposed NESHAP adopt the same emissions limits, work practice
standards, and compliance provisions that are currently required in the
facility’s Title V permits for the control of particulate matter (PM).
  An existing primary copper smelting area source would be subject to a
facility-wide PM emissions limit; proposed compliance requirements
include a continuous PM sampler, monthly monitoring reports, reports of
deviations, semiannual monitoring reports, and recordkeeping
requirements.  An existing primary zinc production facility would be
subject to equipment/work practice standards for the control of roaster
exhaust gases and PM emissions limits for different types of furnaces. 
Proposed compliance provisions include baghouse monitoring and
maintenance requirements, reports of deviations, semiannual monitoring
reports, and recordkeeping requirements.   The proposed NESHAP also
requires repeat PM performance tests (once every 5 years)  for regulated
emissions sources.  Any sintering machine at a primary zinc production
area source would be subject to the PM and opacity limits in the new
source performance standard (NSPS) for primary zinc smelters (40 CFR
part 60, subpart Q) and associated monitoring requirements.  The NSPS
requires a continuous opacity monitoring system (COMS) for sintering
machines.  

The proposed requirements for new primary copper smelters include a
facility-wide PM emissions limit with a continuous emissions monitoring
system (CEMS) to measure and record the PM concentration and gas flow
rate of the regulated emissions sources and a device to measure and
record the weight of copper concentrate feed.   Monthly monitoring
reports would also be required.  EPA Performance Specification 11 (40
CFR part 60, appendix B) would apply to the CEMS.  The owner or operator
of a new secondary copper smelter would be required to meet a PM
emissions limit, operate bag leak detection systems, and conduct repeat
PM performance tests.  A proposed work practice standard requires a
written plan for the selection, inspection, and pretreatment of copper
scrap to minimize the amount of oil and plastics in the scrap that are
charged to furnaces.  A new primary zinc production facility would be
subject to PM emissions limits for regulated emissions sources and the
equipment/work practice standard for roasters.  Bag leak detection
systems and repeat PM performance tests would also be required.  Any
sintering machine would be subject to the NSPS requirements; EPA
Performance Specification 1 (40 CFR Part 60, Appendix B) would apply to
a COMS.

	New and existing area sources would be subject to requirements in the
General Provisions  (40 CFR Part 63, Subpart A).  An existing affected
source would be required to submit an initial notification of
applicability and a notification of compliance status.  The owner or
operator of an existing affected source would be allowed to certify
initial compliance with PM limits based on previous performance test
results;  performance tests would be required to demonstrate initial
compliance for a new affected source   The owner or operator of an
existing affected source would also be required to comply with the
requirements for startup, shutdown, and malfunction (SSM) plans and
reports in 40 CFR 63.6(e)(3).  All requirements in the General
Provisions would apply to the owner or operator of a new affected
source. 

The proposed information collection requirements for existing and new
area sources are listed in Attachments 1A and 1B.

2.  Need For and Use of the Collection

(a)	Need/Authority for the Collection.

	Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP
for both major and area sources of HAP that are listed for regulation
under CAA section 112(c).  An area source is a stationary source that is
not a major source (i.e., an area source does not emit and does not have
the potential to emit more than 10 tons per year of any single HAP or
more than 25 tons per year of any combination of HAP).  Requirements for
area sources in CAA sections 112(c)(3) and 112(k) direct EPA to (1) 
identify at least 30 air toxics that present the greatest potential
health threat in the largest number of urban areas and (2) to identify
sufficient area source categories to ensure that sources representing 90
percent or more of the of the emissions of the 30 “listed” HAP are
subject to regulation.  EPA implements these requirements through the
Integrated Urban Air Toxics Strategy (64 FR 38715, July 19, 1999).  Each
of the source categories included in the proposed NESHAP are on the
Integrated Urban Air Toxics Strategy Area Source Category List. 

Under  CAA section 112(d)(5), we may elect to promulgate HAP standards
for area sources based on the use of generally available control
technology (GACT) or management practices used by the sources.  We can
consider costs and economic impacts in determining GACT, which is
particularly important when developing regulations for source categories
that may have few establishments and many small businesses, or when
determining whether additional control is needed for sources that are
already well-controlled as a result of other air emissions standards.

 Facilities in these source categories are current well control as a
result of State and national standards and permitting requirements for
criteria pollutants that obtain co-control of HAP.  Therefore, we have
developed the proposed standards to reflect the application of GACT.
Except for new secondary copper smelters, GACT is equivalent to the
levels of control that are currently required for these sources.  We are
proposing these standards at this time in response to a court-ordered
deadline that requires promulgation of four area source categories by
December 15, 2006 (Sierra Club v. U.S. Environmental Protection Agency,
no. 01-1537, DC Cir.).  

	Certain records and reports are necessary for the Administrator to
confirm the compliance status of area sources, identify any new or
reconstructed sources subject to the standards, and confirm that the
GACT standards are being achieved on a continuous basis.  These
recordkeeping and reporting requirements are specifically authorized by
section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the
part 63 NESHAP General Provisions.  The recordkeeping and reporting
requirements for Title V permits are contained in 40 CFR 70.6 and 40 CFR
71.6.   Under parts 63 and 70 or 71, the owner or operator must keep
each record for 5 years following the date of each occurrence,
measurement, maintenance, corrective action, report, or record.    

 (b)	Use/Users of the Data.

	The information will be used by the delegated authority (State agency
or Regional Administrator if there is no delegated State agency) to
ensure that the emissions limits and other requirements are being
achieved.  Based on review of the recorded information at the site and
the reported information, the delegated permitting authority can
identify facilities that may not be in compliance and decide which
plants, records, or processes may need inspection.      

3.	Nonduplication, Consultations, and Other Collection Criteria

(a)	Nonduplication.

	Primary copper smelters and primary zinc production facilities are
subject to the NSPS in 40 CFR part 60, subparts Q and R, respectively. 
NESHAP for major sources of HAP also apply to primary copper smelters
(40 CFR Part 63, Subpart QQQ).  Existing facilities have title V
operating permits that incorporate the information collection
requirements of the permitting regulations in 40 CFR Parts 70 or 71, the
NSPS, National Ambient Air Quality Standards, and other requirements. 
The proposed NESHAP prevent duplication of similar information requests
by adopting the same information collection requirements established in
the title V permit.  By codifying the current requirements, the proposed
NESHAP do not require existing facilities to change the testing,
monitoring, recordkeeping, and reporting requirements that are already
in place.  New area sources would be required to comply with the
notification, testing, monitoring, operation and maintenance,
recordkeeping, and reporting requirements in the part 63 General
Provisions.   

The last secondary copper smelter closed in 2001.  A computer search of
the Federal Information Locator System indicated that there are no
similar information requests for secondary copper smelters being carried
out by the Federal government; and a similar search of EPA's ongoing
ICR's revealed no duplication of information-gathering efforts. 

 (b)  Public Notice Required Prior to ICR Submission to OMB.

	This section is not applicable because this is a rule-related ICR.

(c)	Consultations.

The proposed rules were developed in consultation with individual plants
and a trade association.  The non-EPA persons consulted on the
information collection activities are identified in Table 1.

TABLE 1.  PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact	Organization	Telephone Number

James Mallory	Non-Ferrous Founders’ Society	(847) 299-0950

Jedd Griffin	Zinifex	(931) 552-4200

Mike Altepeter	Big River Zinc	(618) 274-5000

Steve Sands	Kennecott Copper	(901) 238-2400



(d)	Effects of Less Frequent Collection.

	If the relevant information were collected less frequently, the
delegated permitting authority (State or EPA) would not be reasonably
assured that a plant is in compliance with the standards.

(e)	General Guidelines. 

	None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f)	Confidentiality.

	All 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 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR
42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(g)  Sensitive Questions.  

	This section is not applicable because this ICR does not involve
matters of a sensitive nature.

4.	The Respondents and the Information Requested

(a)	Respondents/NAIC Codes.

	Potential respondents under proposed Subpart EEEEEE are owners or
operators of new and existing primary copper smelters that are area
sources of HAP.  The NAICS code for primary copper smelters is 331411. 
We estimate that one primary copper smelter would be subject to the
proposed NESHAP; no new area sources are projected during the 3 year
period of this ICR. 

Potential respondents under proposed subpart FFFFFF are owners or
operators of new secondary copper smelters that are area sources of HAP.
 Secondary copper smelters are part of the broad NAICS code 331423,
which also includes copper, brass, and bronze ingot makers.  The section
112(k) listing for secondary copper smelters was based on a small subset
of this NAICS  code and does not include ingot makers.  There are no
existing secondary copper smelters in the U.S., and no new secondary
copper smelting area sources are expected during the 3-year period of
this ICR.

 Potential respondents under proposed subpart GGGGGG are owners of
operators of new and existing primary zinc smelters that are area
sources of HAP.  The NAICS code for primary zinc smelters is 331419.  We
estimate that two primary zinc smelters would be subject to the proposed
NESHAP; no new area sources are expected during the 3 year period of
this ICR.

(b) Information Requested.

	(i)  Data Items, Including Recordkeeping Requirements.  Attachments 1A
and 1B, Source Data and Information Requirements, summarizes the
proposed data items, including recordkeeping and reporting requirements.

	(ii)  Respondent Activities.  The respondent activities required by the
proposed rules are identified in Tables 2A and 2B and introduced in
section 6(a).

5.	The Information Collected–Agency Activities, Collection
Methodology, and Information Management

(a)	Agency Activities.

	A list of Agency activities is provided in Tables 3A and 3B and
introduced in section 6(c).

(b)	Collection Methodology and Management.

	Data and records maintained by the respondents are tabulated and
published for use in compliance and enforcement programs of the
delegated permitting authority.  The monitoring reports submitted to the
permitting authority are used for problem identification, as a check on
source operation and maintenance, and for compliance determinations. 
EPA is the permitting authority until the State agency is delegated
authority to implement the final rule.  Therefore, information contained
in the reports submitted to the Regional Administrator will be entered
into the Air Facility System (AFS), which is operated and maintained by
EPA's Office of Compliance.  AFS 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 AFS 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.

(c)  Small Entity Flexibility.

	The Small Business Administration defines a small entity as a firm
having no more than 1,000 employees (for the primary copper smelting
industry) or 750 employees (for the secondary copper smelting or primary
zinc smelting industries).   One of the area source facilities that
would be subject to the proposed NESHAP is considered a small entity. 
However, the proposed NESHAP would not impose any significant compliance
costs on that entity or any of the other area source facilities because
each facility is already meeting the proposed emissions limits and
compliance requirements.  The only cost of the proposed NESHAP for
existing area sources is for a startup, shutdown, and malfunction plan
and one-time notifications.  

(d)  Collection Schedule.

	The specific frequency for each information collection activity within
this request is shown in Tables 2A and 2B.

6.   Estimating the Burden and Cost of the Collection

(a)  Estimating Respondent Burden.

	The annual burden estimates for the proposed NESHAP are shown in Tables
2A (for subpart EEEEEE) and 2B (for subpart GGGGGG).    These numbers
were derived from estimates based on EPA’s experience with other
standards.  No burden estimates are provided for new primary copper or
primary zinc area sources because no new facilities are expected during
the 3-year period of this ICR.  No burden estimates are provided for
secondary copper smelters because there are no existing facilities and
no new facilities are expected during the 3-year period of this ICR.

(b)	 Estimating Respondent Costs.

	The information collection activities for the proposed NESHAP are
presented in Tables 2A and 2B.  Because the data are already collected
by respondents as required by the existing permit requirements for PM,
no respondent development costs are associated with the information
collection activities.

(i)  Estimating Labor Costs.  Labor rates and associated costs are based
on Bureau of Labor Statistics (BLS) data.  Technical, management, and
clerical average hourly rates for private industry workers were taken
from the United States Department of Labor, Bureau of Labor Statistics,
December 2005, “Table 2. Civilian Workers, by occupational and
industry group” available at   HYPERLINK
"http://www.bls.gov/news.release/ecec.t02.htm" 
http://www.bls.gov/news.release/ecec.t02.htm .  Wages for occupational
groups are used as the basis for the labor rates with a total
compensation of $41.89/hour for technical, $48.09/hour for managerial,
and $20.86/hour for clerical.  These rates represent salaries plus
fringe benefits and do not include the cost of overhead.  An overhead
rate of 110 percent is used to account for these costs.  The
fully-burdened hourly wage rates used to represent respondent labor
costs are:  technical at $87.98, management at $100.98, and clerical at
$43.80.

	(ii)  Estimating Capital and Operations and Maintenance (O&M) Costs. 
The proposed NESHAP does not require the installation of any new control
devices or monitoring systems at existing facilities.  Capital and O&M
costs are not estimated for new sources because no new sources are
expected during the next 3-year period.  Therefore, no (zero) capital
and O&M costs are associated with the proposed NESHAP during the 3-year
period of this ICR.  

	(iii)  Capital/Startup vs. O&M Costs.  Capital/startup costs are not
estimated for existing area sources because the proposed NESHAP do not
require the installation of any new control devices or monitoring
systems or new performance test to demonstrate initial compliance with
the emission limits (i.e., assumes sources will use the results of
performance tests conducted within the past 5 years to demonstrate
initial compliance).   Capital/startup costs are not estimated for new
sources because no new sources are expected during the next 3-year
period.  Therefore, no (zero) capital/startup are associated with the
proposed NESHAP during the 3-year period of this ICR. 

	(iv)  Annualizing Capital Costs.  No capital costs are associated with
the proposed NESHAP.  Therefore, no (zero) annualized costs are
associated with the proposed NESHAP during the 3-year period of this
ICR. 

(c)  Estimating Agency Burden and Cost.

	Because the information collection requirements were developed as an
incidental part of standards development, no costs can be attributed to
the development of the information collection requirements.  Because
reporting and recordkeeping requirements on the part of the respondents
are required under the operating permits rules in 40 CFR part 70 or part
71 and the part 63 NESHAP General Provisions, no operational costs would
be incurred by the Federal Government.  Publication and distribution of
the information are part of the Compliance Data System, with the result
that no Federal costs can be directly attributed to the ICR. 
Examination of records to be maintained by the respondents will occur
incidentally as part of the periodic inspection of sources that is part
of EPA's overall compliance and enforcement program, and, therefore, is
not attributable to the ICR.  The only costs that the Federal government
would incur are user costs associated with the analysis of the reported
information, as presented in Tables 3A and 3B.

	The Agency labor rates are from the Office of Personnel Management
(OPM) 2006 General Schedule which excludes locality rates of pay.  These
rates can be obtained from Salary Table 2006-GS available on the OPM
website,   HYPERLINK "http://www.opm.gov/oca/06tables/html/gs_h.asp" 
http://www.opm.gov/oca/06tables/html/gs_h.asp . The government employee
labor rates are $14.35/hour for clerical (GS-6, Step 3), $26.53 for
technical (GS-12, Step 1), and $35.75/hr for management (GS-13, Step 5).
 These rates were increased by 60 percent to include fringe benefits and
overhead.  The fully-burdened wage rates used to represent Agency labor
costs are:  clerical at $22.96; technical at $42.45, and management at
$57.20.

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

There is one existing primary copper smelting area source.  No new
sources are expected during the next 3 years.  Consequently, the average
number of respondents during the 3 year period of this ICR is 0.33. 
There are two existing primary zinc smelting area sources.  No new
sources are expected during the next 3 years.  Consequently, the average
number of respondents during the 3 year period of this ICR is 0.67.  
The total average number of respondents for all source categories is 1. 

The only components of the total annual responses attributable to this
ICR are a startup, shutdown, and malfunction plan and two one-time
initial notifications for each existing facility.  The proposed
requirement for repeat PM performance tests would not occur during the
3-year term of this ICR. Therefore, the number of total annual responses
for proposed subpart EEEEEE (primary copper smelting area sources) is
estimated as:  (0.33 annual average respondents × 1 notification) +
(0.33 annual average respondents × 1 notification) + (0.33 annual
average respondents × 1 written plan).   Therefore, the number of total
annual responses for proposed subpart EEEEEE is 0.99 (rounded to 1). 
The number of total annual responses for subpart GGGG (primary zinc
smelters) is estimated as:  (0.67 annual average respondents × 1
notification) + (0.67 annual average respondents × 1 notification) +
(0.67 annual average respondents × 1 written plan).  Therefore, the
number of total annual responses for subpart GGGGGG is 2.01 (rounded to
2).  The total number of responses for the combined sources categories
is 3

 (e)	Bottom Line Burden Hours and Cost Tables.

	(i)  Respondent tally.  The bottom line respondent burden hours and
costs, presented in Tables 2A and 2B, are calculated by adding
person-hours per year down each column for technical, managerial, and
clerical staff, and by adding down the cost column.

The average annual burden for the monitoring, recordkeeping, and
reporting requirements in proposed subpart EEEEEE for the one existing
primary copper smelting area source is 9 person hours with an annual
average cost of $771 with no annual capital and O&M costs. 

The average annual burden for the monitoring, recordkeeping, and
reporting requirements in proposed subpart GGGGGG for the two existing
primary zinc smelting area sources is 18.5 person hours with an annual
average cost of $1,566 with no annual capital and O&M costs.

The total annual burden for all source categories is 27.5 hours at $2337
with no annual capital and O&M costs. 

	(ii)  The Agency tally.  The average annual Federal Government cost is
$286 for 7 total annual hours.  The bottom line Agency burden hours and
costs presented in Tables 3A and 3B are calculated by adding
person-hours per year down each column for technical, managerial, and
clerical staff, and by adding down the cost column. 

	(iii)  Variations in the annual bottom line.   This section does not
apply since no significant variation is anticipated.

(f)	Reasons for Change in Burden.

	This section does not apply because this is a new ICR.

 (g)  Burden Statement

	The average annual respondent burden for the proposed NESHAP for
primary copper smelting area sources is estimated at 9 hours.  The
average annual respondent burden for the proposed NESHAP for primary
zinc smelting area sources is estimated at 18.5 hours. 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 currently
valid OMB control number.  The OMB control numbers for EPA's regulations
in 40 CFR part 63 are listed in 40 CFR part 9.

	To comment on the Agency’s need for this information the accuracy of
the provided burden estimates, and any suggestions for minimizing
respondent burden, including through the use of automated collection
techniques, EPA has established a public docket for this ICR under
Docket ID No. EPA-HQ-OAR-2006-0510, which is available for online
viewing at   HYPERLINK "http://www.regulations.gov"  www.regulations.gov
, or in person viewing at the Air and Radiation Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B-102, 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 Air Docket is (202)
566-1927.  An electronic version of the public docket is available at  
HYPERLINK "http://www.regulations.gov."  http://www.regulations.gov.  
This site can be used to submit or view public comments, access the
index listing of the contents of the public 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 above.  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 No. EPA-HQ-OAR-2006-0510 in any
correspondence.

NOTE:  The EPA Docket Center suffered damage due to flooding during the
last week of June 2006.  The Docket Center is continuing to operate. 
However, during the cleanup, there will be temporary changes to Docket
Center telephone numbers, addresses, and hours of operation for people
who wish to visit the Public Reading Room to view documents.  Consult
EPA's Federal Register notice at 71 FR 38147 (July 5, 2006) or the EPA
website at   HYPERLINK "http://www.epa.gov/epahome/dockets.htm" 
www.epa.gov/epahome/dockets.htm  for current information on docket
status, locations and telephone numbers.

PART B

	This section is not applicable because statistical methods are not used
in data collection associated with the proposed rules.TABLE 2A.  ANNUAL
RESPONDENT BURDEN AND COST:  NESHAP FOR PRIMARY COPPER SMELTING AREA
SOURCES

Burden item	(A) Person-hours per occurrence	(B)  No. of occurrences per
respondent	(C) Person-hours per respondent (C=A*B)	(D) Respondents per
yeara	(E) Technical person-hours per year (E=C*D)	(F) Management
person-hours per year

 (E*0.05)	(G) Clerical person-hours per year (E*0.1)	(H) Costb, $ 

1.  Applications	N/A







	2.  Surveys and Studies	N/A







	3.  Acquisition, Installation, and Utilization of Technology 

     and Systemsc	0	0	0	0	0	0	0	0

4.  Reporting Requirements









A.  Read instructions	8	1	8	0.33	2.64	0.13	0.26	$256.79

B.  Required activities









      Monitor per Title V permitc	0	0	0	0	0	0	0	0

      Initial/repeat performance testsd	0	0	0	0	0	0	0	0

     Prepare startup, shutdown, malfunction plan	4	1	4	0.33	1.32	0.07
0.13	$128.89

     Initial notification of applicability	4	1	4	0.33	1.32	0.07	0.13
$128.89

     Initial notification of compliance status	8	1	8	0.33	2.64	0.13	0.26
$256.79

     Reports per  Title V permitc	0	0	0	0	0	0	0	0

C.  Create information	See 4B







	D.  Gather existing information	See 4B







	E.  Write report	See 4B







	5.  Recordkeeping Requirements 









A.  Read instructions	See 4A







	B.  Plan activities	See 4A







	C.  Implement activities	See 4A







	D.  Record all data required by title V permitc	0	0	0	0	0	0	0	0

E. Time to transmit or disclose informationc	0	0	0	0	0	0	0	0

F.  Time to train personnelc	0	0	0	0	0	0	0	0

G.  Time for audits	N/A







	TOTAL LABOR BURDEN AND COST

9 hrs/yr	$771.36

a  There is one existing primary copper smelter that is an area source. 
No new sources are projected during the 3-year term of this ICR. 
Therefore, the average number of respondents per year is 0.33
(1÷3=0.33).

b  This ICR uses the following labor rates: $100.98 for managerial
labor, $87.98 for technical labor, and $43.80 for clerical labor.  These
rates are from the U.S. s Department of Labor, Bureau of Labor
Statistics, December 2005, (Table 2. Civilian Workers, by occupational
and industry group.(  The rates are from 

column 1, (Total compensation.(  The rates have been increased by 110%
to account for the benefit packages available to those employed by
private industry.

c   No hours or costs are associated with this burden item because
existing plants are already complying with the requirement in their
Title V permit. 

d  An existing facility may certify initial compliance based on previous
PM tests; no new test is required.  Repeat tests would not occur during
the 3-year period of this ICR.

TABLE 2B.  ANNUAL RESPONDENT BURDEN AND COST:  NESHAP FOR PRIMARY ZINC
PRODUCTION AREA SOURCES

Burden item	(A) Person-hours per occurrence	(B)  No. of occurrences per
respondent	(C) Person-hours per respondent (C=A*B)	(D) Respondents per
yeara	(E) Technical person-hours per year (E=C*D)	(F) Management
person-hours per year

 (E*0.05)	(G) Clerical person-hours per year (E*0.1)	(H) Costb, $ 

1.  Applications	N/A







	2.  Surveys and Studies	N/A







	3.  Acquisition, Installation, and Utilization of Technology 

     and Systemsc	0	0	0	0	0	0	0	0

4.  Reporting Requirements









A.  Read instructions	8	1	8	0.67	5.36	0.27	0.54	$522.28

B.  Required activities









     Monitor per Title V permitc	0	0	0	0	0	0	0	0

     Initial./Repeat performance testsd	0	0	0	0	0	0	0	0

     Prepare startup, shutdown, malfunction plan	4	1	4	0.67	2.68	0.13
0.27	$260.75

     Initial notification of applicability	4	1	4	0.67	2.68	0.13	0.27
$260.75

     Initial notification of compliance status	8	1	8	0.67	5.36	0.27	0.54
$522.28

     Reports per Title V permitc	0	0	0	0	0	0	0	0

C.  Create information	See 4B







	D.  Gather existing information	See 4B







	E.  Write report	See 4B







	5.  Recordkeeping Requirements 









A.  Read instructions	See 4A







	B.  Plan activities	See 4A







	C.  Implement activities	See 4A







	D.  Record all data required by title V permitc	0	0	0	0	0	0	0	0

E. Time to transmit or disclose informationc	0	0	0	0	0	0	0	0

F.  Time to train personnelc	0	0	0	0	0	0	0	0

G.  Time for audits	N/A







	TOTAL LABOR BURDEN AND COST

18.5 hrs/yr	$1,566.06

a  There is one existing primary zinc smelter area source.  No new
sources are projected during the 3-year term of this ICR.  Therefore,
the average number of respondents per year is 0.33 (1÷3=0.33).

b  This ICR uses the following labor rates: $100.98 for managerial
labor, $87.98 for technical labor, and $43.80 for clerical labor.  These
rates are from the U.S. s Department of Labor, Bureau of Labor
Statistics, December 2005, (Table 2.  The rates are from column 1,
(Total compensation.(  The rates have been increased by 110% to account
for the benefit packages available to those employed by private
industry.

c   No hours or costs are associated with this burden item because
existing plants are already complying with the requirement in their
Title V operating permit. 

d  An existing facility may certify initial compliance based on previous
PM tests; no new test is required.  Repeat tests would not occur during
the 3-year period of this ICR.

TABLE 3A.  ANNUAL BURDEN AND COST TO THE AGENCY: NESHAP FOR PRIMARY
COPPER SMELTING AREA SOURCES

Burden Item	(A) Person hours per occurrence	(B) Occurrences per plant
per year	(C) Plants per year a	(D) Technical hours/year (D=A*B*C)	(E)
Management   hours/year (E=0.05*D)	(F) Clerical-hours/year (F=0.1*D)	
(G) Costb, $

Report Review:







	  Initial notification of applicability 	2	1	0.33	0.66	0.03	0.07	$31.35

  Initial notification of compliance status	4	1	0.33	1.32	0.07	0.13
$63.01

TOTAL BURDEN AND COST



2.28  hours 	$94.36

Footnotes:

a  There is one existing primary copper smelter that is area source.  No
new sources are projected during the next 3-year period..  Therefore,
the average number of plants per year is 0.33 (1÷3=0.33).No travel is
expected.

b  This ICR uses the following average hourly labor rates: 57.20 for
managerial (GS-13, Step 5, $35.75 x 1.6), $42.45 (GS-12, Step 1, $26.53
x 1.6) for technical and $22.96 (GS-6, Step 3, $14.35 x 1.6) for
clerical.  These rates are from the Office of Personnel Management (OPM)
(2006 General Schedule( which excludes locality rates of pay.

TABLE 3B.  ANNUAL BURDEN AND COST TO THE AGENCY:  NESHAP FOR PRIMARY
ZINC SMELTING AREA SOURCES

Burden Item	(A) Person hours per occurrence	(B) Occurrences per plant
per year	(C) Plants per year a	(D) Technical hours/year (D=A*B*C)	(E)
Management   hours/year (E=0.05*D)	(F) Clerical-hours/year (F=0.1*D)	
(G) Costb, $

Report Review:







	  Initial notification of applicability 	2	1	0.67	1.34	0.07	0.13	$63.86

  Initial notification of compliance status	4	1	0.67	2.68	0.13	0.27
$127.41

TOTAL BURDEN AND COST



4.62  hours 	$191.27

Footnotes:

a  There are 2 existing primary zinc smelters that are area sources.  No
new sources are projected during the next 3-year period.. Therefore, the
average number of plants per year is 0.67 (2÷3=0.67).  No travel is
expected.

b  This ICR uses the following average hourly labor rates: 57.20 for
managerial (GS-13, Step 5, $35.75 x 1.6), $42.45 (GS-12, Step 1, $26.53
x 1.6) for technical and $22.96 (GS-6, Step 3, $14.35 x 1.6) for
clerical.  These rates are from the Office of Personnel Management (OPM)
(2006 General Schedule( which excludes locality rates of pay.

ATTACHMENT 1A.  INFORMATION REQUIREMENTS-- NESHAP FOR PRIMARY COPPER
SMELTING AREA SOURCES

Requirement	Citation for existing sources	Citation for new sources
General Provisions citation

Monitoring



	Continuous PM sampler or PM CEMS and calculations of daily average
emissions	§63.11148(d)	§63.11149(d), (e)	NA

Notifications



	Notification of applicability	Table 1 to subpart EEEEEE	Table 1 to
subpart EEEEEE	40 CFR 63.9(a)(2)

Notification of construction/ reconstruction 	NA	Table 1 to subpart
EEEEEE	40 CFR 63.9(b)(5)

Notification of special compliance requirements 	NA	Table 1 to subpart
EEEEEE	40 CFR 63.9(d)

Notification of performance test	NA	Table 1 to subpart EEEEEE	40 CFR
63.9(c)

Notification of opacity/VE observations	NA	Table 1 to subpart EEEEEE	40
CFR 63.9(f)

Additional CMS notifications	NA	Table 1 to subpart EEEEEE	40 CFR 63.9(g)

Notification of compliance status	Table 1 to subpart EEEEE/
§63.11150(a)	Table 1 to subpart EEEEEE/ §63.11150(b) 	40 CFR 63.9(h)

Notification of changes in information	Table 1 to subpart EEEEE	Table 1
to subpart EEEEEE	40 CFR 63.9(j)

Plans



	SSM plan	Table 1 to subpart EEEEE	Table 1 to subpart EEEEEE	40 CFR
63.6(e)(3)

Performance test plan	NA	Table 1 to subpart EEEEEE	40 CFR 63.7(c)(2)

CMS quality control plan	NA	Table 1 to subpart EEEEEE	40 CFR 63.8(d)

CMS performance evaluation test plan	NA	Table 1 to subpart EEEEEE	40 CFR
63.8(e)(3)

Records



	Information to demonstrate compliance 	§63.11148(i)	Table 1 to subpart
EEEEE/§63.11149(e)	40 CFR 63.10

Reports



	Monthly summary of monitoring data	§63.11148(f) 	§63.11149(g)	NA

Report of deviation	§63.11148(g) 	NA	NA

Semiannual monitoring report	§63.11148(h) 	NA	NA

Initial performance test	§63.1148(e)	§63.11149(f)	40 CFR 63.7(e)(1)

Quality assurance test plan	NA	Table 1 to subpart EEEEEE	40 CFR 63.7(c)

CMS performance evaluations/report	NA	Table 1 to subpart EEEEEE	40 CFR
63.8(e)(5)

SSM reports	Table 1 to subpart EEEEEE	Table 1 to subpart EEEEEE	40 CFR
63.6(e)(3)

Excess emissions reports	NA	Table 1 to subpart EEEEEE	40 CFR 63.10(e)(3)



ATTACHMENT 1B.  INFORMATION REQUIREMENTS--NESHAP FOR PRIMARY ZINC
PRODUCTION AREA SOURCES

Requirement	Citation for existing sources	Citation for new sources
General Provisions citation

Monitoring



	Baghouse	§63.11162(c)	§63.11163(c)	NA

COMS for sintering machine	§63.11162(e)	§63.1163(e)	NA

Notifications



	Notification of applicability	Table 1 to subpart GGGGGG	Table 1 to
subpart GGGGGG	40 CFR 63.9(a)(2)

Notification of construction/ reconstruction 	NA	Table 1 to subpart
GGGGGG	40 CFR 63.9(b)(5)

Notification of special compliance requirements 	NA	Table 1 to subpart
GGGGGG	40 CFR 63.9(d)

Notification of performance test	NA	Table 1 to subpart GGGGGG	40 CFR
63.9(c)

Notification of opacity/VE observations	NA	Table 1 to subpart GGGGGG	40
CFR 63.9(f)

Additional CMS notifications	NA	Table 1 to subpart GGGGGG	40 CFR 63.9(g)

Notification of compliance status	Table 1 to subpart GGGGGG/
§63.11164(a)	Table 1 to subpart GGGGGG/ §63.11164(b) 	40 CFR 63.9(h)

Notification of changes in information	Table 1 to subpart GGGGGG	Table 1
to subpart GGGGGG	40 CFR 63.9(j)

Plans



	SSM plan	Table 1 to subpart GGGGGG	Table 1 to subpart GGGGGG	40 CFR
63.6(e)(3)

Performance test plan	NA	Table 1 to subpart GGGGGG	40 CFR 63.7(c)(2)

CMS quality control plan	NA	Table 1 to subpart GGGGGG	40 CFR 63.8(d)

CMS performance evaluation test plan	NA	Table 1 to subpart GGGGGG	40 CFR
63.8(e)(3)

Records



	Baghouse and monitoring information	§63.11162(c), (j)	Table 1 to
subpart GGGGGG/§63.11163(d)	40 CFR 63.10

Reports



	Reports of deviation	§63.11162(h)	NA	NA

Semiannual monitoring reports	§63.11162(i)	NA	NA

Initial /repeat performance tests 	§63.11162(f), (g)	§63.11163(g), (h)
40 CFR 63.7(e)(1)

40 CFR 63.6(h)(7)

Quality assurance test plan	NA	Table 1 to subpart GGGGGG	40 CFR 63.7(c)

CMS performance evaluation/report	NA	Table 1 to subpart GGGGGG	40 CFR
63.8(e)(5)

 SSM reports	Table 1 to subpart GGGGGG	Table 1 to subpart GGGGGG	40 CFR
63.6(e)(3)

Excess emissions reports	NA	Table 1 to subpart GGGGGG	40 CFR 63.10(e)(3)



   The Secondary Copper Smelting and Cadmium Refining and Cadmium Oxide
Production source categories were added to the area source category list
on June 26, 2002 (67 FR 43112).  The listing of secondary copper
smelting was based on HAP emissions of cadmium, lead, and dioxin.  On
November 22, 2002 (67 FR 70427), we added Primary  Copper Smelters to
the area source category list based on HAP metal emissions (arsenic,
cadmium, chromium, lead, and nickel),  changed the name of the Cadmium
Refining and Cadmium Oxide Production source category to Primary
Nonferrous Metals-Zinc, Cadmium and Beryllium, and expanded the scope of
the Primary Nonferrous Metals source category.  The listing of primary
nonferrous metals was based on HAP metal emissions of arsenic, cadmium,
lead, manganese, and nickel.

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