1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
Subpart
L
Secondary
Lead
Smelters
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS,
Subpart
L
­
Information
Requirements
for
Secondary
Lead
Smelters.

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Secondary
Lead
Smelters
were
proposed
on
June
11,
1973
and
promulgated
on
March
8,
1974.
These
standards
apply
to
the
following
facilities
in
NSPS
Subpart
L,
Secondary
Lead
Smelters:
any
pot
furnace
of
more
than
250
kg
charging
capacity,
blast
(
cupola)
furnaces,
and
reverberatory
furnaces,
commencing
construction,
modification,
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
L.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
any
affected
facility.
There
are
no
monitoring
requirements
specific
to
NSPS,
Subpart
L.
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
two
years
following
the
date
of
such
measurements,
2
maintenance
reports,
and
records.

Approximately
23
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.
These
numbers
are
consistent
with
the
numbers
in
the
previously
approved
ICR
and
are
based
on
data
in
EPA's
Aerometric
Information
Retrieval
System
(
AIRS)
database.
The
cost
of
this
ICR
will
be
$
1,895.43
dollars.
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.

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
or
methods
(
in
accordance
with
3
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
Keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)

provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
lead
and
non­
lead
particulate
matter
emissions
from
secondary
lead
smelters
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
L.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
particulate
matter
from
secondary
lead
smelters
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
lead
and
non­
lead
particulate
matter
from
secondary
lead
smelters
are
the
result
of
operation
of
pot
furnaces,
blast
furnaces,
and
reverberatory
furnaces.
These
standards
rely
on
the
capture
and
collection
of
particulate
matter
by
particulate
emission
control
devices
such
as
an
electrostatic
precipitator
or
scrubber.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
Operating
conditions
include
the
particulate
matter
concentration
in
the
gas
stream
4
during
operation
of
a
blast
(
cupola)
or
reverberatory
furnace
and
opacity
of
gases
from
a
pot
furnace.
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
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60,

Subpart
L.
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
Volume
64,
No.
157
on
August
16,
1999.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register
Notice
on
August
16,
1999.
5
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
contained
in
40
CFR
Part
60,

Subpart
L
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
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
contained
in
40
CFR
Part
60,

Subpart
L
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.
6
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
secondary
lead
smelters
that
commenced
construction,
modification,
or
reconstruction
after
June
11,
1973.
They
are
listed
under
SIC
Code
3341.
The
government
is
in
the
process
of
transitioning
to
the
new
North
American
Industrial
Classification
System
(
NAICS).
The
NAIC
code
for
this
industry
is
331492.

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
L,
Secondary
Lead
Smelters.

A
source
must
make
the
following
reports
Notification
Reports
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
60.8(
d)

Physical
or
operational
change
60.7(
a)(
4)
and
60.145(
a)

Reports
Initial
performance
test
results
60.8
(
a),
7
A
source
must
keep
the
following
records.

Recordkeeping
Startups,
shutdowns,
malfunctions.
(
60.7(
b)

Performance
test
records
(
60.7(
d)

Records
are
required
to
be
retained
for
two
years.

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
control
equipment
Perform
initial
performance
test,
Reference
Method
5
for
determination
of
particulate
matter
concentration,
Method
9
for
determination
of
opacity,
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.

We
believe
that
many
regulatory
agencies
are
allowing
sources
to
submit
reports
by
means
8
of
a
disk
or
electronically.

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,
Subpart
L:

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.

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
9
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
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant(
s).
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
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
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
L).
The
10
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
34.5
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,

Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
I)
Estimating
Labor
Costs
This
ICR
uses
technical
labor
rates
of
$
26.16
plus
110%
overhead
which
equals
$
54.94.

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
this
standard's
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
.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
There
are
no
capital
start
up
costs
for
this
regulation
since
there
are
no
11
new
sources
anticipated
during
the
next
three
years.
There
are
no
annual
operations
and
maintenance
costs.
This
is
based
on
the
fact
that
no
continuous
monitoring
is
required
under
this
standard.
The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
0.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
This
section
is
not
applicable
since
there
is
no
continuous
monitoring
required
in
NSPS
Subpart
L.

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
$
0
(
from
table
1).
This
cost
is
based
on
an
average
wage
of
a
(
GS
10
step
1
employee
rate,
($

16.52
hr
+
110%
overhead
=
$
34.69)
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
NSPS
Subpart
L
is
23.
The
number
of
new
sources
subject
to
NSPS
Subpart
L
is
zero.
The
number
of
total
respondents
is
23.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.
The
total
annual
responses
is
34.5.
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
recordkeeping
12
requirements.
The
total
annual
labor
costs
are
$
1,895.43
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
0
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:

Industry
Burden.

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

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
labor
rate
increase
not
a
burden
hour
change.
There
has
been
no
change
in
the
number
of
sources.

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
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
13
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
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
1128.06
and
OMB
control
number
2060­
0080
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
TABLE
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENTS
AS
A
RESULT
OF
NSPS
Subpart
L
(
A)
(
B)
(
C)
a
(
D)
(
E)
b
EPA
hours/
Occurrences/
EPA
hours/
Plants/
Cost/

Activity
Occurrence
plant/
year
plant
year
year
year
New
Plants:
c
_____________________________
Not
Applicable
_________________________________________

!
Report
Review:

­
Notifications:

(
Modification/
construction,

anticipated
and
actual
startup)

­
Review
initial
performance
test
results
!
Attend
initial
performance
test
Existing
Plants:
d
!
Report
Review:

­
Performance
Test
Results
24
1
24
2.4
57.60
­

!
Attend
performance
test
TOTAL
ANNUAL
HOURS
177.60
177.60
Travel
Expenses
(
1
person
*
2.4
plants/
year
*
3
days/
plant
*
75
per
diem)
+
($
300
round
trip/
plant
*
2.4
plants/
year)
=
$
1,260
Salary
(
1
person
*
177.60
hours/
year
*
$
37.40/
hour)
=
$
6,642.24/
year
TOTAL
ANNUAL
COST
=
$
7,902.24
a.
A
*
B
=
C
b.
C
*
D
=
E
c.
Assume
that
no
sources
will
be
subject
to
the
Subparts
N
and
Na.

d.
Assume
all
sources
use
venturi
scrubbers
emission
control
systems.

e.
Assume
50
percent
of
sources
submit
semiannual
reports
of
low
pressure.
TABLE
2.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDSa
Occurrences/
Hours/
Cost
Hours
per
respondent/
respondent/
Respondents
Hours
per
Occurrence
year
year
per
yearb
per
yearc
year
$

(
A)
(
B)
(
C
=
A
*
B)
(
D)
(
E
=
C
*
D)
(
F)

1.
APPLICATIONS
____________________________
Not
Applicable
___________________________________________

2.
SURVEY
AND
STUDIES
____________________
Not
Applicable
__________________________________________

3.
REPORTING
REQUIREMENTS
FOR
EXISTING
AND
NEW
SOURCES
A..
Read
Instructions
1
1
1
2.4
2.4
57.12
B..
Required
Activities
Performance
testd
194
1
194
2.4
465.60
11,081.28
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
Requirementsa
______________________________________
Not
Applicable
___________________________________________

Report
of
performance
test
32
1
32
2.4
76.80
1,827.84
Monitoring
results
which
average
more
than
10%
below
performance
test
results
10
2
20
12
240.00
5,712.00
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
___________________________
Not
Applicable
___________________________________

E.
Time
to
Enter
Information
0.25
365f
91.25
24
2190.00
52,122.00
Records
of
operating
parameters
of
the
continuous
monitoring
system
Synchronization
and
calibration
of
monitoring
device
F.
Train
Personnel
____________________________________
Not
Applicable
_____________________________________________

G.
Audits
____________________________________
Not
Applicable
______________________________________________
continuation...

TABLE
2.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDSa
Occurrences/
Hours/

Cost
Hours
per
respondent/
respondent/
Respondents
Hours
per
Occurrence
year
year
per
yearb
per
yearc
year
$

(
A)
(
B)
(
C=
A
*
B)
(
D)
(
E
=
C
*
D)

(
F)

5.
TOTAL
ANNUAL
BURDEN
2,974.8
70,800.24
a.
Assume
that
no
new
sources,
on
average,
will
be
subject
to
NSPS,
Subparts
N
and
Na.
Therefore,
this
estimate
is
for
existing
sources
only.

b.
Assume
that
all
sources
use
venturi
scrubbers
for
pollution
control
and
that
half
of
the
sources
have
either
a
reportable
pressure
loss
through
the
venturi
constriction
or
water
supply
pressure
to
the
control
equipment.

c.
Assume
an
hourly
wage
of
$
23.80
based
on
Table
2
of
the
March
1998
report
of
the
U.
S.
Department
of
Commerce
Bureau
of
Labor
Statistics
.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

d.
Assume
the
10%
of
the
existing
sources
conduct
a
performance
test
due
to
operational
or
physical
changes.
e.
Assume
50
percent
of
sources
submit
semiannual
report
of
measurements
over
any
3­
hour
period
that
average
more
than
10
percent
below
the
average
levels
maintained
during
the
most
recent
performance
test.

f.
Assume
operation
365
days
per
year
as
specified
in
the
NSPS
review
document.
6(
f)
Reasons
for
Change
in
Burden
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
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,
OPPE
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
St.,
S.
W.,
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
and
OMB
control
number
in
any
correspondence.

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