1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
OMB
Control
No.
2060­
0110
EPA
ICR
No.
1604.06
NSPS
Smelter
Regulations
Including:

Subpart
M,
Secondary
Brass
and
Bronze
Production
Plants
Subpart
P,
Primary
Copper
Smelters
Subpart
Q,
Primary
Zinc
Smelters
Subpart
R,
Primary
Lead
Smelters
Subpart
S,
Primary
Aluminum
Reduction
Plants
Subpart
Z,
Ferroalloy
Production
Facilities
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
The
title
for
OMB
control
number
2060­
0110,
had
been:
NSPS
for
Secondary
Brass
and
Bronze
Production
Plants.
The
following
table
lists
the
old
OMB
Control
Numbers,
EPA
ICR
Numbers
and
titles
that
were
consolidated
into
OMB
Control
number
1604.01:

Table
of
Consolidate
Prior
OMB
Control
Numbers
2060­
0110
1604.01
NSPS
for
Secondary
Brass
&
Bronze
Production
Plants
(
M)
2060­
0030
1068.01
NSPS
for
Primary
Copper,
Lead
&
Zinc
Smelter
Monitoring
2060­
0031
1683.02
NSPS
for
Primary
Aluminum
Reduction
Plants
2060­
0033
1065.02
NSPS
Subpart
Z:
Ferroalloy
Production
Facilities
Its
new
title
is:
NSPS
Smelter
Regulations:
Subpart
M,
Secondary
Brass
and
Bronze
Production
Plants;
Subpart
P,
Primary
Copper
Smelters;
Subpart
Q,
Primary
Zinc
Smelters;
Subpart
R,
Primary
Lead
Smelters;
Subpart
S,
Aluminum
Reduction
Plants;
and
Subpart
Z,
Ferroalloy
Production
Facilities.
.
The
consolidated
ICRs,
with
their
prior
respective
OMB
control
and
EPA
ICR
numbers
are:

NSPS
Subpart
M,
Secondary
Brass
and
Bronze
Production
(
OMB
2060­
0110,
EPA
ICR
1604.5):
NSPS
Subpart
P,
Primary
Copper
Smelters,
Subpart
Q,
Primary
Zinc
Smelters,
and
Subpart
R,
Primary
Lead
(
OMB
2060­
0030,
EPA
ICR
1068.01);
2
NSPS
Subpart
S,
Primary
Aluminum
Smelters
(
OMB
2060­
0031,
EPA
ICR
1683.02);
NSPS
Subpart
Z,
Ferroalloy
Production
Facilities
(
OMB
2060­
0033,
EPA
ICR
1065.02).

SHOWN
AS
TABLE:

Title
Subpart
CFR
OMB
Number
EPA
Number
Smelters
M
60.133
2060­
0110
1604.05
Copper
P
60.166
2060­
0030
1068.01
Zinc
Q
60.176
2060­
0030
1068.01
Lead
R
60.186
2060­
0030
1068.01
Aluminum
S
60.195
2060­
0031
1683.02
Ferroalloy
Z
60.266
2060­
0033
1065.02
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.

Secondary
Brass
and
Bronze
The
New
Source
Performance
Standards
(
NSPS),
for
Subpart
M,
Brass
and
Bronze
were
proposed
on
June
11,
1973,
promulgated
on
March
8,
1974,
and
amended
most
recently
on
February
14,
1989.
Any
facility
that
commences
construction
or
modification
after
June
11,
1973,
is
subject
to
the
requirements
of
this
subpart.
These
standards
apply
to
the
following
facilities
in
secondary
brass
or
bronze
production
plants:
reverberatory
and
electric
furnaces
of
1,000
kg
or
greater
production
capacity
and
blast
(
cupola)
furnaces
of
250
kg/
hr
or
greater
production
capacity.
Furnaces
from
which
molten
brass
or
bronze
are
cast
into
the
shape
of
finished
products,
such
as
foundry
furnaces,
are
not
considered
to
be
affected
facilities.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
subpart
M.
Approximately
5
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
3
Primary
Copper
Smelters
The
New
Source
Performance
Standards
(
NSPS),
for
Subpart
P,
Primary
Copper
Smelters
were
proposed
on
October
16,
1974,
and
promulgated
on
January
15,
1976.
Any
facility
that
commences
construction
or
modification
after
October
16,
1974,
is
subject
to
the
requirements
of
this
subpart.
These
standards
apply
to
the
following
facilities
in
primary
copper
smelters:
dryer,
roaster,
smelting
furnace,
and
copper
converter.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
P.
Approximately
13
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.

Primary
Zinc
Smelters
The
New
Source
Performance
Standards
(
NSPS),
for
Subpart
Q,
Primary
Zinc
Smelters
were
proposed
on
October
16,
1974,
and
promulgated
on
January
15,
1976.
Any
facility
that
commences
construction
or
modification
after
October
16,
1974,
is
subject
to
the
requirements
of
this
subpart.
These
standards
apply
to
the
following
facilities
in
primary
zinc
smelters:
roaster
and
sintering
machine.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
Q.
Approximately
one
source
is
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.

Primary
Lead
Smelters
The
New
Source
Performance
Standards
(
NSPS),
for
Subpart
R,
Primary
Lead
Smelters
were
proposed
on
October
16,
1974,
and
promulgated
on
January
15,
1976.
Any
facility
that
commences
construction
or
modification
after
October
16,
1974,
is
subject
to
the
requirements
of
this
subpart.
These
standards
apply
to
the
following
facilities
in
primary
lead
smelters:
sintering
machine,
sintering
machine
discharge
end,
blast
furnace,
dross
reverberatory
furnace,
electric
smelting
furnace,
and
converter.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
R.
Approximately
one
source
is
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.

Primary
Aluminum
Reduction
Plants
The
New
Source
Performance
Standards
(
NSPS),
for
Subpart
S,
Primary
Aluminum
Reduction
Plants
were
proposed
on
October
23,
1974,
promulgated
on
July
25,
1977,
and
amended
most
recently
on
February
14,
1989.
Any
facility
that
commences
construction
or
modification
after
October
23,
1974,
is
subject
to
the
requirements
of
this
subpart.
These
standards
apply
to
the
following
facilities
in
primary
aluminum
reduction
plants:
potroom
groups
and
anode
bake
plants.
Note
that
an
owner
or
operator
of
an
affected
facility
may
elect
to
comply
with
the
requirements
of
this
subpart
or
the
requirements
of
subpart
LL
of
part
63.
This
4
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
subpart
S.
Approximately
6
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.

Ferroalloy
Production
Facilities
The
New
Source
Performance
Standards
(
NSPS),
for
Subpart
Z,
Ferroalloy
Production
were
proposed
on
October
21,
1974,
promulgated
on
July
25,
1977,
and
amended
most
recently
on
February
14,
1990.
Any
facility
that
commences
construction
or
modification
after
October
21,
1974,
is
subject
to
the
requirements
of
this
subpart.
These
standards
apply
to
the
following
facilities
in
ferroalloy
production
plants:
electric
submerged
arc
furnaces
which
produce
silicon
metal,
ferrosilicon,
calcium
silicon,
silicomanganese
zirconium,
ferrochrome
silicon,
silvery
iron,
high­
carbon
ferrochrome,
charge
chrome,
standard
ferromanganese,
silicomanganese,
ferromanganese
silicon,
or
calcium
carbide;
and
dust­
handling
equipment.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
subpart
Z.
Approximately
one
source
is
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
These
numbers
and
the
number
of
sources
for
the
other
subparts
covered
by
this
ICR
are
based
on
data
in
EPA's
Aerometric
Information
Retrieval
System
(
AIRS)
database,
data
on
primary
nonferrous
metal
smelters
in
the
Sector
Facility
Indexing
Project
(
SFIP),
and
information
provided
by
staff
in
EPA's
Office
of
Air
Quality
Planning
and
Standards.

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
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,
5
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,
particulate
matter
emissions
from
secondary
brass
and
bronze
plants,
primary
copper,
lead
and
zinc
smelters,
primary
aluminum
reduction
plants,
and
ferroalloy
production
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
regulations
were
promulgated
for
these
source
categories
at
40
CFR
Part
60,
Subparts
M,
P,
Q,
R,
S
and
Z.

2(
b)
Practical
Utility/
Users
Of
The
Data
The
control
of
emissions
of
particulate
matter
and
other
specified
pollutants
from
secondary
brass
and
bronze,
primary
copper,
lead
and
zinc
smelters,
primary
aluminum
reduction
and
ferroalloy
production
plants
require
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
metallic
particulate
matter
from
Secondary
Brass
and
Bronze
Production
Plants
are
the
result
of
operation
of
any
reverberatory
and
electric
furnaces
of
1,000
kg
or
greater
production
capacity
and
blast
(
cupola)
furnaces
of
250
kg/
h
or
greater
production
capacity.
Emissions
of
metallic
particulate
matter
and
sulfur
dioxide
from
Primary
Copper
Smelters
are
the
result
of
the
operation
of
each
dryer,
roaster,
smelting
furnace
or
copper
converter.
The
same
emissions
from
Primary
Lead
Smelters
are
the
result
of
each
sintering
machine,
sintering
machine
discharge
end,
blast
furnace,
dross
reverberatory
furnace,
electric
smelting
furnace
and
converter.
Emissions
from
Primary
Zinc
Smelters
are
the
result
of
each
roaster
and
sintering
machine.
Emissions
of
gaseous
hydrogen
fluoride
and
particulate
fluorides,
alumina,
carbon
monoxide,
volatile
organic
compounds
and
sulfur
dioxide
from
Primary
Aluminum
Reduction
Plants
are
the
result
of
the
operation
of
potroom
groups
and
anode
bake
plants.
Emissions
of
particulate
matter
and
carbon
monoxide
from
Ferroalloy
Production
Facilities
are
the
result
of
the
operation
of
electric
submerged
arc
furnaces
that
produce:
silicon
metal,
ferrosilicon,
calcium
silicon,
silicomanganese
zirconium,
ferrochrome
silicon,
silvery
iron,
high­
carbon
ferrochrome,
charge
chrome,
standard
ferromanganese,
silicomanganese,
ferromanganese
silicon,
or
calcium
carbide;
and
dust­
handling
equipment.
These
standards
rely
on
the
capture
of
particulate
matter
emissions
by
control
devices
such
as
filters,
scrubbers,
or
electrostatic
precipitators.
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
particulate
control
devices,
e.
g.,
filters,
scrubbers,
and
percipitators,
are
properly
installed
and
operated
and
the
standards
are
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.
An
example
of
an
operating
condition
common
to
all
subparts
addressed
in
this
ICR
is
the
opacity
of
gases
during
operation
of
an
affected
facility.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
6
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulations.
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,
Subparts
M,
P,
Q,
R,
S
and
Z.

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.

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
the
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.
7
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
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:

Regulation
SIC
Codes
NAICS
Codes
NSPS
Subpart
M,
Secondary
Brass
and
Bronze
Production
Plants
3341
331492
NSPS
Subpart
P,
Primary
Copper
Smelters
3331
331411
NSPS
Subpart
Q,
Primary
Zinc
Smelters
3339
331419
NSPS
Subpart
R,
Primary
Lead
Smelters
3339
331419
NSPS
Subpart
S,
Primary
Aluminum
Reduction
Plants
3334
331312
NSPS
Subpart
Z,
Ferroalloy
Production
Facilities
3313
331112
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
M,
Secondary
Brass
and
Bronze
Production
Plants;
Subpart
P,
Primary
Copper
8
Smelters;
Subpart
Q,
Primary
Zinc
Smelters;
Subpart
R,
Primary
Lead
Smelters;
Subpart
S,
Primary
Aluminum
Reduction
Plants;
or
Subpart
Z,
Ferroalloy
Production
Facilities.

A
source
must
make
the
following
reports
Reports
for
All
NSPS
Regulations
Included
in
this
ICR
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Physical
or
operational
change
60.7(
a)(
4)

Demonstration
of
continuous
monitoring
system
(
except
for
Subpart
M)
60.7(
a)(
5)

Initial
performance
test
results
60.8(
a)

Initial
performance
test
notification
60.8(
d)

There
are
no
Additional
Reports
for
NSPS
Subpart
M
Additional
Reports
for
NSPS
Subpart
P
excess
emissions
of
opacity
and
sulfur
dioxide
60.7(
c)
and
60.165(
d)

Additional
Reports
for
NSPS
Subpart
Q
Excess
emissions
of
opacity
and
sulfur
dioxide
60.7(
c)
and
60.175(
c)

Additional
Reports
For
NSPS
Subpart
R
excess
emissions
of
opacity
and
sulfur
dioxide
60.7(
c)
and
60.185(
c)
9
Additional
Reports
For
NSPS
Subpart
S
Excess
emissions
of
fluoride
(
between
1.0
kg/
Mg
and
1.3
kg/
Mg)
in
any
performance
test
60.192(
b)

Advance
notification
of
each
performance
test
after
initial
performance
test
60.194(
c)

Additional
Reports
For
NSPS
Subpart
Z
Excess
emissions
of
opacity
60.7(
c)
and
60.264(
b)

product
change
60.264(
c)

Recordkeeping
for
all
NSPS
Regulations
included
in
this
ICR
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
(
if
required)
is
inoperative
60.7(
b)

Performance
test
records
60.7(
d)

Records
are
required
to
be
retained
for
2
Years
60.7(
f)

No
Additional
Recordkeeping
for
NSPS
Subpart
M
Additional
Recordkeeping
for
NSPS
Subpart
P
Monthly
records
of
the
total
smelter
charge
and
the
weight
percent
(
dry
basis)
of
arsenic,
antimony,
lead
and
zinc
contained
in
the
charge.
60.165(
a)
10
Additional
Recordkeeping
for
NSPS
Subpart
Q
Calculations
of
two­
hour
average
sulfur
dioxide
concentrations
that
have
been
recorded
daily
for
the
12
consecutive
2­
hour
periods
of
each
operating
day.
60.175(
b)

Additional
Recordkeeping
for
NSPS
Subpart
R
Calculations
of
two­
hour
average
sulfur
dioxide
concentrations
that
have
been
recorded
daily
for
the
12
consecutive
2­
hour
periods
of
each
operating
day.
60.185(
b)

Additional
Recordkeeping
for
NSPS
Subpart
S
Daily
records
of
the
weight
of
aluminum
and
anode
produced
60.194(
a)

Daily
records
of
production
rates
of
aluminum
and
anodes,
raw
material
feed
rates,
and
cell
or
potline
voltages
60.194(
b)

Additional
Recordkeeping
for
NSPS
Subpart
Z
Daily
records
of
product
produced;
description
of
constituents
of
furnace
charge,
including
the
quantity,
by
weight;
time
and
duration
of
each
tapping
period
and
identification
of
material
tapped;
all
furnace
power
input
data
obtained;
all
flow
rate
data
or
all
fan
motor
power
consumption
and
pressure
drop
data.
60.265(
a)
11
ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

With
the
exception
of
Subpart
M
respondents,
install,
calibrate,
maintain,
and
operate
a
CMS.
Subparts
P,
Q,
R,
and
Z
respondents
shall
use
a
CMS
to
monitor
for
opacity.
In
addition,
Subparts
P,
Q,
and
R
respondents
shall
use
a
CMS
to
monitor
sulfur
dioxide
emissions.
Subpart
S
respondents
shall
use
a
CMS
to
daily
weigh
aluminum
and
anode
produced.
Subpart
Z
respondents
also
shall
use
a
CMS
to
measure
and
record
the
furnace
power
input,
the
flow
rate
through
each
separately
ducted
hood
of
the
capture
system
or,
alternatively,
measure
and
record
all
fan
motor
power
consumption
and
pressure
drop
across
the
fan.

Perform
initial
performance
test,
Reference:
Method
5
for
particulate
matter
concentrations
for
Subpart
M
(
during
charging
and
refining,
but
not
during
pouring
of
the
heat)
and
Subparts
P,
Q,
R,
and
Z,
and
volumetric
flow
rate
of
the
effluent
gas
(
with
certain
exceptions)
for
Subpart
Z;
Reference
Method
9
for
determination
of
opacity
for
all
subparts;
Reference
Methods
13A
or
B
for
ducts
or
stacks
and
Method
14
for
roof
monitors
to
determine
total
fluoride
concentration
and
volumetric
flow
rate
of
effluent
gas
for
Subpart
S;
Reference
the
emission
rate
correction
factor,
integrated
sampling
procedure
of
Method
3B
for
carbon
monoxide
concentration
for
Subpart
Z,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

It
is
our
understanding
that
many
regulatory
agencies
are
allowing
sources
to
submit
reports
by
disk
or
electronically.
12
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
information
required
under
40
CFR,
Part
60,
Subparts
M,
P,
Q,
R,
S,
and
Z:

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
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
of
any
excess
emissions
required
by
subparts
P,
Q,
R
and
Z
and
monthly
or
annual
performance
test
reports
and
excess
emissions
reports
of
Subpart
S
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
The
majority
of
sources
affected
by
this
ICR
are
not
small
businesses.
Most
of
the
primary
nonferrous
facilities
are
operated
by
large
corporations.
Even
the
smallest
primary
13
aluminum
plant
in
the
country
produces
approximately
73,000
metric
tons/
year
which
would
not
typically
be
considered
a
small
business.
Some
of
the
secondary
brass
and
bronze
production
sources
subject
to
NSPS
Subpart
M
may
qualify
as
small
businesses,
but
these
facilities
need
to
comply
only
with
the
basic
requirements
for
all
NSPS
sources.

The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
these
specific
NSPS
subparts
and
the
specific
process
equipment
and
pollutants.
The
requirements
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
Although
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
2a
through
Table
2d.

Table
Index
Table
2a
NSPS
subpart
M
Table
2b
NSPS
subparts
P,
Q,
R
Table
2c
NSPS
subpart
S
Table
2d
NSPS
subpart
Z
6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
2a
through
2d
document
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
(
40
CFR
Part
60,
Subpart
M,
P,
Q,
R,
S
and
Z).
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
at
5,350.5
person­
hours.
This
number
represents
the
14
addition
of
the
total
burden
hours
from
each
of
the
subparts
included
in
this
ICR.
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,
previous
ICRs,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
technical
labor
rate
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.
Only
technical
labor
rates
are
used
because
most
of
these
standards'
requirements
involve
initial
reporting
of
performance
tests
for
new
sources
which
is
not
anticipated
to
occur
in
the
next
three
years
or
recordkeeping
at
existing
sources
of
startups,
shutdowns
and
malfunctions.
In
addition,
most
of
the
measurements
and
calculations
required
for
monthly
performance
tests
under
Subpart
S
are
consistent
with
the
respondents'
normal
recordkeeping
practices.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs
and
continuous
monitoring
device
costs.
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
monitors.
The
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
Capital/
Start­
up
and
Operating
and
Maintenance
(
O&
M)
Costs
(
A)
Regulation
(
B)

Continuous
Monitoring
device
(
C)

Start
up
cost
($)
for
1
affected
facility
(
D)

#
of
new
affected
facilities
to
start
up
(
E)

Total
start
up
(
C
X
D)
(
F)
Annual
O&
M
costs
($)
for
1
affected
facility
(
G)
#
of
affected
facilities
with
O&
M
(
H)

Total
O&
M
(
F
X
G)

Subparts
P,
Q,
R,
Z
Opacity
Monitor
$
36,
000
0
0
$
7,500
16
$
120,000
Capital/
Start­
up
and
Operating
and
Maintenance
(
O&
M)
Costs
15
P,
Q,
R
CMS
that
measures
sulfur
dioxide
emissions
$
25,100
0
0
5,400
15
81,000
Subpart
S
CMS
that
daily
weighs
aluminum
and
anode
produced
Unknow
n
0
0
5,000
6
30,000
Subpart
Z
CMS
that
measures
and
records
furnace
power
input
and
flow
rate
or
fan
motor
power
consumptio
n
and
pressure
drop
across
the
fan
gas
flow­
$
13,500
pressure
drop­
$
1300
0
0
900
1
900
There
are
no
Capital/
Start­
up
costs
for
this
ICR
as
indicated
in
the
total
of
column
E.
Total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
231,900.
This
is
the
total
of
column
H.
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
$
9,184.74.
This
cost
is
based
on
an
average
wage
of
a
GS
10,
step
1
employee
rate
($
17.09
hour
+
110%
overhead
=
$
35.89).
This
rate
is
from
OPM's
2000
General
Schedule,
excluding
16
locality
pay,
basic
rates.
Details
upon
which
this
estimate
is
based
appear
in
Tables
1a­
d:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Summary
Table
Regulation
Title
#
new
sources
per
year
#
existing
sources
total
burden
hours
total
labor
costs
total
annual
responses
Subpart
M,
Brass
and
Bronze
0
5
7.5
$
412.05
0
Subpart
P,
Primary
Copper,
Subpart
Q,
Primary
Zinc,
Subpart
R,
Primary
Lead
0
15
783.5
$
43,045.49
30
Subpart
S,
Primary
Aluminum
0
6
4,365
$
239,813.10
51
Subpart
Z,
Ferroalloy
Production
0
1
194.5
$
10,685.83
1
TOTAL
0
27
5350.5
$
293,956.47
82
The
number
of
existing
sources
subject
to
NSPS
Part
60,
Subparts
M,
P,
Q,
R,
S
and
Z
is
27.
The
number
of
new
sources
subject
to
Subparts
M,
P,
Q,
R,
S
and
Z
is
zero.
The
number
of
total
respondents
is
27.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.
The
total
annual
response
is
82.
This
number
is
calculated
from
the
number
of
new
sources
multiplied
by
the
number
of
initial
reports,
plus
the
number
of
existing
sources
multiplied
by
the
reporting
requirements
for
each
subpart
included
in
this
ICR.
The
total
annual
labor
costs
are
$
293,956.47,
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
231,900.
Details
upon
which
these
estimates
are
based
appear
in
Tables
2a
­
2d:
Industry
Burden.
17
6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
attached
Tables
1a­
d
and
2
a­
d.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
total
burden
hours
from
the
most
recently
approved
ICRs
is
due
to
a
reinstatement
of
burden
hours
for
Subparts
P,
Q,
R
and
Z
.
The
previous
ICR
for
Subparts
P,
Q,
R,
and
the
ICR
for
Subpart
Z
were
inadvertently
allowed
to
lapse
several
years
ago
There
has
been
no
change
in
the
number
of
sources.
Total
annual
respondent
costs
for
complying
with
NSPS
subparts
M
and
S
have
increased
slightly
due
to
an
increase
in
the
labor
rate
since
the
last
ICR
renewal.
Also
that
the
burden
represented
in
this
ICR
is
the
result
of
several
previously
separate
ICRs
being
combined
into
one.

SUMMARY
OF
BURDEN
CHANGES
Regulation
Title
Prior
OMB
Control
No.
Previously
Approved
Burden
Hrs.
Current
Burden
Hrs.
Previous
Costs
$
Current
Costs
$

Subpart
M
2060­
0110
7.5
7.5
263.00
412.05
Subpart
P,
Q,
R
2060­
0030
0*
783.5
0*
43,045.49
Subpart
S
2060­
0031
4365
4365
152,775.00
239,813.10
Subpart
Z
2060­
0033
0*
194.5
0*
10,685.83
TOTALS
4372.5
5350.5
$
153,038.00
$
293,956.47
*
The
previously
approved
hours
and
costs
are
no
longer
relevant
given
the
time
that
has
passed
since
the
last
ICR
renewal.
Therefore,
the
increase
in
burden
is
being
calculated
from
a
base
of
0.

6(
g)
Burden
Statement
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
18
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
Ave.,
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
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1604.06
and
OMB
control
number
2060­
0110
in
any
correspondence.

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