SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X)

1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection
NESHAP
for
the
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
regulations
published
at
40
CFR
part
63,
subpart
X,
were
proposed
on
June
9,
1994,
(
59
FR
29750),
and
promulgated
on
June
23,
1995,
(
60
FR
32587).
In
response
to
industry
petitions
to
reconsider,
the
final
rule
was
amended
on
June
13,
1997
(
62
FR
32209).
Entities
potentially
affected
by
this
rule
are
owners
or
operators
of
secondary
lead
smelters
that
operate
furnaces
to
reduce
scrap
lead
metal
and
lead
compounds
to
elemental
lead.
The
rule
applies
to
secondary
lead
smelters
that
use
blast,
reverberatory,
rotary,
or
electric
smelting
furnaces
to
recover
lead
metal
from
scrap
lead,
primarily
from
used
lead­
acid
automotive­
type
batteries.
The
rule
provides
protection
to
the
public
by
requiring
all
secondary
lead
smelters
to
meet
emission
standards
reflecting
the
application
of
the
maximum
achievable
control
technology
(
MACT).
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
X.

In
general,
all
NESHAP
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
of
all
sources
subject
to
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
Regional
office.

Approximately
23
sources
are
currently
subject
to
the
regulation,
and
no
additional
sources
are
expected
to
become
subject
to
the
standard
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
one
affected
facility
per
plant
respondent.

In
the
development
of
this
Information
Collection
Request
(
ICR),
we
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
on
the
active
ICR
which
states:
2
This
collection
is
approved
through
October
2003.
OMB
understands
that
the
collection
does
not
currently
provide
for
respondents
to
use
electronic
means
of
reporting.
Under
the
terms
of
the
Government
Paperwork
Elimination
Act,
EPA
should
review
this
collection
and
adopt
such
means
of
reporting,
to
the
extent
practicable,
by
October
2003.
Thus,
before
resubmitting
this
collection
to
OMB
for
approval,
EPA
should
ensure
that,
to
the
extent
practicable,
the
collection
has
been
revised
to
include
electronic
means
of
reporting.

The
reports
required
by
this
rule
are
submitted
directly
to
State
and
local
pollution
control
Agencies,
rather
than
the
Federal
Government.
The
Government
Paperwork
Elimination
Act
applies
only
to
Federal
Agencies.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
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,
metal
(
i.
e.,
containing
lead
compounds)
and
organic
hazardous
air
pollutants
(
HAPs)
emissions
from
secondary
lead
smelting
processes
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
X.
3
2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
metal
and
organic
HAPs
emissions
from
secondary
lead
smelting
processes
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
metal
and
organic
HAPs
emissions
from
secondary
lead
smelting
processes
are
the
result
of
operation
of
the
affected
facilities
(
i.
e.,
smelting
furnaces,
refining
kettles,
agglomerating
furnaces,
dryers
and
fugitive
dust).
The
subject
standards
are
achieved
by
the
capture
of
source
and
fugitive
emissions
containing
total
hydrocarbons
and
lead
compounds
by
adhering
to
the
leak
detection
and
repair
plan
for
baghouses
or
use
of
wet
scrubbers
to
control
particulate
matter
and
metal
hazardous
air
pollutants.

The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and/
or
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.
The
semiannual,
or
as
determined
by
the
Administrator,
emissions
reports,
i.
e.,
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)
requirement
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
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
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
X.

3(
a)
Nonduplication
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
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.
4
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
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
several
sources
were
used
to
obtain
updated
information
on
the
number
of
sources
and
on
the
assumptions
made
to
determine
the
industry
burden
associated
with
NESHAP
subpart
X
over
the
next
three
years.
We
referenced
the
most
recent
ICR,
and
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Nonferrous
Metals
Industry."
We
also
accessed
the
most
recent
data,
dated
June
03,
2003,
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
In
addition,
we
contacted
Mr.
Khonane
Ditthavong
of
King
&
Spading,
LLP,
they
are
the
representatives
of
the
Lead
Trade
Associations,
his
phone
number
is
(
202)
626­
5546,
and
Mr.
Troy
Gueiss
of
East
Penn
Mfg.
Co.
Inc.,
his
phone
number
is
(
610)
682­
6361.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
is
a
useful
technique
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
at
5
CFR
Part
1320,
Section
1320.5.

These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records'
retention
requirement
is
consistent
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.
5
3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
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
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
and
NAICS
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
secondary
lead
smelters
that
operate
furnaces
to
reduce
scrap
lead
metal
and
lead
compounds
to
elemental
lead.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
3341
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
331492
for
Secondary
Smelting,
Refining,
and
Alloying
of
Nonferrous
Metal
(
except
Copper
and
Aluminum).
Industries
other
than
secondary
lead
smelters
which
are
included
in
this
SIC
code
are
not
respondents
to
this
ICR.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
part
63,
subpart
X.

A
source
must
make
the
following
reports:

Notification
Reports
for
40
CFR
part
63,
subpart
X
Construction/
reconstruction
63.5
Initial
notifications
63.9(
b)

Initial
performance
test
63.7(
b),
63.9(
e)
6
Notification
Reports
for
40
CFR
part
63,
subpart
X
Initial
performance
test
results
63.10(
d)(
2)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Approval
of
smelters
fugitive
dust
control
standard
operating
procedures
manual,
and
operating
procedures
manual
for
baghouses
63.549(
b)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Compliance
status
63.9(
h)

Physical
or
operational
change
63.9,
63.10
Periodic
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
i)

Semiannual,
or
as
determined
by
the
Administrator,
monitoring/
exceedance
summary
63.10(
e)(
3),
63.550(
c)

A
source
must
keep
the
following
records:

Recordkeeping
for
40
CFR
part
63,
subpart
X
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
of
bag
leak
detection
system
alarms,
including
corrective
actions
63.550(
a)(
2)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)

Records
of
parametric
monitoring
data,
system
maintenance
and
calibration
63.550(
a)

Initial
and
annual
compliance
test
results
63.550(
a)(
1)

Records
are
required
to
be
retained
for
five
years,
however,
only
the
data
of
the
most
recent
two
years
must
be
kept
on­
site
63.550(
a)

Some
State
Regulatory
Agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
Agencies.
The
estimated
amount
of
electronic
reporting
is
10%.
7
(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
operate
and
maintain
baghouses,
according
to,
a
standard
operating
procedures
manual
and
consistent
with
the
manufacturer's
instructions.

Monitor
and
record
pressure
drop
and
liquid
supply
pressure
at
the
wet
scrubber
at
least
once
every
hour
when
using
this
control
device
for
controlling
particulate
matter
and
metal
HAP
emissions
from
a
process
fugitive
source.

Install,
calibrate,
maintain,
and
operate
a
CMS
for
temperature
monitoring
of
the
afterburner
or
the
combined
blast
furnace
and
reverberatory
furnace
exhaust
streams
when
complying
with
the
total
hydrocarbon
emission
standard.

Install,
calibrate,
maintain,
and
operate
a
total
hydrocarbon
CMS
for
measuring
emissions
when
complying
with
the
total
hydrocarbon
emission
standard.

Equip
pressurized
drying
bleaching
seals
with
an
alarm
to
determine
seal
malfunctions.

Perform
initial
performance
test
and
repeat
performance
tests
if
necessary.

Use
referenced
Methods
in
Appendix
A,
Part
60,
to
determine
compliance
with
the
emission
standards
for
lead
compound
(
i.
e.,
Methods
1,
2,
3,
4,
and
12)
and
to
determine
compliance
with
the
emission
standards
for
total
hydrocarbons
(
i.
e.,
Methods
1,
2,
3B,
4,
and
25A).

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
8
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
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
of
excess
emissions
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
the
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
and
annual
emission
inventory
data
for
more
than
100,000
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.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
small
entities
(
e.
g.,
small
businesses).
However,
the
impact
on
small
entities
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
requirements
the
minimum
needed
to
ensure
9
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
NESHAP
for
the
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X).

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
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
16,034
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
89.94
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
61.66
per
hour
for
Technical
labor,
and
$
38.39
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rate
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
89.94
($
42.83
+
110%)
Technical
$
61.66
($
29.36
+
110%)
Clerical
$
38.39
($
18.28
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
10
1
Assumes
that
temperature
monitors
will
be
installed
at
a
cost
of
$
1,200
each
to
meet
rule
requirements.
The
O&
M
costs
for
temperatures
monitors
are
negligible.

2
Twenty
of
the
23
existing
sources
have
continuous
particulate
monitors.
subject
standard(
s)
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
cost
when
a
facility
becomes
subject
to
the
regulation.
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)
Startup
Cost
($)
for
One
Affected
Facility
(
C)
No.
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
(
F)
No.
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Temperature1
monitor
for
afterburners
1,200
0
0
negligible
0
0
Continuous2
particulate
monitor
0
0
0
7,500
20
$
150,000
The
total
capital/
startup
costs
for
this
ICR
is
zero.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
150,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
150,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
11
1
One
furnace
may
be
rebuilt
over
the
three
year
period
of
this
ICR.
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
$
47,309.
[
see
Table
2
in
Section
6(
H)].
This
cost
is
based
on
the
following
average
hourly
labor
rates,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
NESHAP
for
the
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Approximately
23
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
source
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
40
CFR
part
63,
subpart
X
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
Section
63.549
Notification
of
reconstruction
11
11
0
0
0
1
Sections
63.550(
b),
and
63.10
(
Semiannual
reports)
N/
A
N/
A
23
2
0
46
Sections
63.9,
and
63.10
(
notification
of
operational
changes)
N/
A
N/
A
23
1
0
23
TOTAL
70
The
number
of
total
respondents
is
23.
This
represents
the
number
of
existing
sources
12
which
is
23,
plus
the
number
of
new
sources
which
is
(
zero)
averaged
over
the
three­
year
period
(
i.
e.,
the
total
of
the
number
of
new
respondents
over
the
three­
year
period
divided
by
three
years).
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
Total
Annual
Responses
is
70.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table
above.
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
975,913.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
the
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
150,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
229
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
Even
though
there
is
an
increase
of
one
hour
in
the
total
estimated
burden
from
the
most
recently
approved
ICR,
there
is
no
increase
in
the
number
of
new
or
modified
sources.
The
increase
in
the
annual
cost,
was
due
to
a
revised
hourly
rate
from
the
United
States
Department
of
Labor.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
229
hours
per
response.
Burdens
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
13
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.

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
OECA­
2003­
0036,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
N.
W.,
Washington,
D.
C.
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1514.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
Once
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0036
and
OMB
Control
Number
2060­
0296
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
14
Table
1.
Annual
Respondent
Burden
and
Cost:

NESHAP
for
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X)

Burden
item
(
A)
Technical
person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
$
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
b
4
1
4
0
0
0
0
0
B.
Required
activities
0
0
0
0
Annual
performance
test
330
1
330
23
7,590
380
759
$
531,314.61
Monitoring
requirements:
0
0
0
0
­
CPM
c
1
52
52
20
1,040
52
104
$
72,795.84
­
Baghouse
inspection:
d
0
0
0
0
0
0
0
0
Initial/
Annual
inspection
of
capture
hoods
e
8
1
8
23
184
9.2
18.4
$
12,879.27
Revise
SOP
Manual
f
20
1
20
1
20
1
2
$
1,399.92
C.
Create
information
See
3B
0
0
0
0
D.
Gather
existing
information
See
3B
0
0
0
0
E.
Write
report
0
0
0
0
15
Burden
item
(
A)
Technical
person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
$
a
Initial
notification
report
b
3
1
3
0
0
0
0
0
Notification
of
construction
d
/
reconstruction
2
1
2
1
2
0
0
$
123.32
Notification
of
actual
startup
2
1
2
0
0
0
0
0
Notification,
review
and
approval
of
SOP
manuals
h
8
1
8
0
0
0
0
0
Notification
of
performance
b
test
2
1
1
0
0
0
0
0
Notification
of
compliance
b
status
4
1
4
0
0
0
0
0
Report
of
performance
test
8
1
8
0
0
0
0
0
Notification
of
CMS
b
demonstration
2
1
2
0
0
0
0
0
Semi­
annual
summary
g
reports
16
2
32
23
736
36.8
73.6
$
51,517.05
Notification
of
physical/
f
operational
changes
8
1
8
23
184
9.2
18.4
$
12,879.27
4.
Recordkeeping
Requirements
0
0
0
0
A.
Read
instructions
See
3A
0
0
0
0
16
Burden
item
(
A)
Technical
person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
$
a
B.
Plan
activities
See
3B
0
0
0
0
C.
Implement
activities
See
3B
0
0
0
0
D.
Develop
record
system
N/
A
E.
Develop
Record
System
b
3.5
52
182
23
4,186
209.3
418.6
$
293,003.25
F.
Time
to
enter
and
transmit
information
Record
monitoring
parameters
See
4E
0
0
0
0
Record
of
performance
tests
See
4E
0
0
0
0
Record
of
periodic
inspections
See
4E
0
0
0
0
G.
Time
to
train
personnel
N/
A
0
0
0
0
H.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
0
0
0
0
I.
Time
for
audits
N/
A
0
0
0
0
TOTAL
LABOR
BURDEN
AND
COST
(
Rounded)
13,942
698
1,394
$
975,913
17
Assumptions:

a
Costs
are
based
on
the
following
hourly
rates:
$
89.94
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
61.66
per
hour
for
Technical
labor,
and
$
38.39
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,

"
Total
compensation."
The
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Management
person­
hours
and
clerical
person­
hours
are
assumed
to
be
5
percent
and
10
percent
of
technical
personhours
respectively.

b
One­
time
only
activity.
Assumes
no
new
sources
over
the
next
three
years.

c
Three
facilities
already
have
continuous
particulate
monitors
(
CPM).
Assumes
1
hour
per
week
to
monitor
and
respond
to
alarms.

d
Since
baghouses
requirements
are
part
of
the
normal
plant
operation,
inspections
are
not
attributed
to
this
rule.

We
have
determined
that
there
are
approximately
23
existing
sources
currently
subject
to
this
rule
and
that
no
new
plants
will
be
constructed
over
the
next
three
years
of
this
ICR.
However,
we
have
assumed
that
one
furnace
will
be
rebuilt
per
year
over
the
period
of
this
ICR.

e
Sources
must
perform
this
inspection
when
starting­
up
and
once
per
year
thereafter.

f
Assume
that
each
facility
will
make
a
major
adjustment
once
per
year.
In
each
instance,
SOP
must
be
revised.

g
Sources
are
required
to
submit
semi­
annual
status
reports
of
excess
emissions
or
no
excess
emissions.

h
The
owner
or
operator
shall
submit
fugitive
dust
control
and
baghouse
SOP,
along
with
a
notification
requesting
review
and
approval.
18
Table
2.
Annual
Burden
and
Cost
for
The
Federal
Government:

NESHAP
for
Secondary
Lead
Smelter
Industry
(
40
CFR
part
63,
subpart
X)

Activity
(
A)

EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
person­

hours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
E)
Technical
person­

hours
per
year
(
E=
CxD)
(
F)

Cost,
$
a
Review
initial
notification
reports
b
2
1
2
0
0
0
Review
notifications
of
compliance
status
10
1
10
0
0
0
Review
quarterly
summary
reports
10
1
10
92
920
$
36,330.80
Review
notifications
of
actual
startups
2
1
2
0
0
0
Review
notices
of
physical/
operational
changes
c
4
1
4
23
92
$
3,633.08
Review
notification
of
performance
tests
4
1
4
0
0
0
Review
notifications
of
demonstration
of
CMS
2
1
2
0
0
0
Review
notifications
of
construct/
reconstruction
2
1
2
1
2
$
78.98
19
Activity
(
A)

EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
person­

hours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
E)
Technical
person­

hours
per
year
(
E=
CxD)
(
F)

Cost,
$
a
Review
and
approve
SOP
manuals
(
see
footnote
h
­

Table
1)
8
1
8
0
0
0
Attend
initial
performance
tests
120
1
120
0
0
0
Attend
repeat
performance
tests
120
1
120
0
0
0
Review
annual
compliance
test
results
d
8
1
8
23
184
$
7,266.16
Subtotal
1,198
$
47,309.02
Travel
Expenses
e
(
1
person
x
0
plant/
yr
x
2
days/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
1
round
trips/
yr)
=
$
0.00
TOTAL
ANNUAL
COST
(
rounded)
TOTAL
ANNUAL
COST
=
$
47,309.

Assumptions:

a
Costs
are
based
on
the
hourly
rate
for
Technical
personnel
of
$
39.49,
which
has
been
increased
by
a
1.6
multiplication
factor
to
account
for
government
overhead
expenses.
This
rate
is
obtained
from
the
Office
of
Planning
and
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b
We
have
determined
that
there
are
approximately
23
existing
sources
currently
subject
to
this
rule
and
that
no
new
plants
will
be
constructed
over
the
next
three
years
of
this
ICR.
However,
we
have
assumed
that
one
furnace
may
be
rebuilt
per
year
over
the
period
of
this
ICR.
20
c
Assumes
that
each
plant
will
make
at
least
one
major
adjustment
per
year.

d
Assume
that
it
will
take
8
hrs
to
review
annual
compliance
test.

e
Since
there
are
no
new
sources
expected
over
the
period
of
this
ICR,
there
will
be
no
costs
associated
with
attending
performance
tests.
