SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
the
Secondary
Lead
Smelter
Industry
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
the
Secondary
Lead
Smelter
Industry
1(
b)
Short
Characterization/
Abstract
In
order
to
reduce
HAP
emissions
from
secondary
lead
smelting,
the
EPA
developed
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Secondary
Lead
Smelting
(
40
CFR
Part
63,
Subpart
X)
which
were
proposed
on
June
9,
1994
(
59
F.
R.
29750)
and
promulgated
on
June
23,
1995
(
60
F.
R.
32587).
In
response
to
industry
petitions
to
reconsider,
the
final
rule
was
amended
on
June
13,
1997
(
62
F.
R.
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).
The
information
required
under
this
standard
is
intended
to
assure
compliance
with
40
CFR
Part
63,
Subpart
X.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
including
notification
of
any
physical
or
operational
change
to
an
existing
facility
which
may
increase
the
regulated
pollutant
emission
rate,
notification
of
the
initial
performance
test,
including
information
necessary
to
determine
the
conditions
of
the
performance
test,
and
performance
test
measurements
and
results.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
start­
up,
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
40
CFR
Part
63,
Subpart
X.

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,
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.

Industry
and
EPA
records
indicate
that
there
are
approximately
23
sources
currently
subject
to
the
standard,
and
no
additional
sources
are
expected
to
become
subject
to
the
standard
2
over
the
next
three
years.
The
burden
hours
for
recordkeeping
and
reporting
requirements
for
this
ICR
will
be
16,033
at
a
cost
of
$
875,991.

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
and
organic
HAP
emissions
from
secondary
lead
smelting
processes
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
a
MACT
standard
for
this
source
category
was
promulgated
at
40
CFR
Part
63,
Subpart
X.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
metal
(
i.
e.,
containing
lead
compounds)
and
organic
HAP
emissions
from
secondary
lead
smelting
processes
require
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
metal
and
organic
HAP
emissions
from
secondary
lead
smelting
processes
are
the
result
of
operation
of
the
affected
facilities.
The
sources
of
HAP
emissions
are
smelting
furnaces,
refining
kettles,
agglomerating
furnaces,
dryers
and
fugitive
dust.
These
standards
rely
on
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
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
3
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
this
MACT
standard
continue
to
achieve
compliance.
Adequate
monitoring,
recordkeeping,
and
reporting
are
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
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
February
1,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
No
comments
were
received
on
the
Federal
Register
notice,
and
no
consultations
were
held.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.
4
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
are
owners
or
operators
of
secondary
lead
smelters
that
operate
furnaces
to
reduce
scrap
lead
metal
and
lead
compounds
to
elemental
lead.
Secondary
lead
smelting
and
refining
is
included
under
SIC
code
3341.
Industries
other
than
secondary
lead
smelters
which
are
included
in
this
SIC
code
are
not
respondents
to
this
ICR.
The
corresponding
North
American
Classification
System
(
NAICS)
code
is
331492
[
i.
e.,
Secondary
Smelting,
Refining,
and
Alloying
of
Nonferrous
Metal
(
except
Copper
and
Aluminum)].

4(
b)
INFORMATION
REQUESTED
(
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:

Reports
for
NESHAP,
Subpart
X
Construction/
reconstruction
63.5
Initial
notifications
63.9(
b)

Initial
performance
test
results
63.10(
d)(
2)

Initial
performance
test
63.7(
b),
63.9(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
63.9(
g)
5
Reports
for
NESHAP,
Subpart
X
Compliance
status
63.9(
h),
63.549(
a)

Physical
or
operational
change
63.9,
63.10
Opacity
or
visible
emissions
63.10(
d)(
3)

Periodic
start­
up,
shutdown,
malfunction
reports
63.10(
d)(
5)(
I)

Semi­
annual
monitoring/
exceedance
summary
63.10(
e)(
3),
63.550(
c)

Standard
operating
procedures
manual
for
control
of
fugitive
dust
emissions
and
baghouses
for
approval
before
startup
63.548(
b),
63.549(
b)

A
source
must
maintain
the
following
records:

Recordkeeping
for
NESHAP,
Subpart
X
Start­
ups,
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)

(
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.
6
Respondent
Activities
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
compounds
(
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
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.
7
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
AFS
[
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem]
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
start­
up,
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
monitoring
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AFS
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
AFS
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
five
years.

5(
c)
Small
Entity
Flexibility
The
Small
Business
Administration
(
SBA)
defines
a
small
business
for
SIC
3341
as
any
company
with
500
or
fewer
employees.
Eleven
of
the
16
companies
in
this
industry
meet
the
small
business
criterion.
In
the
previous
ICR,
the
recordkeeping
and
reporting
requirements
were
estimated
not
to
present
an
unreasonable
burden
for
any
of
these
businesses.
Even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
large
business
entities,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
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
2:
Industry
Burden.
8
6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
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
at
16,033
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
NESHAP
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
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:
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial,
$
55.34
per
hour
for
Technical,
and
$
35.64
per
hour
for
Clerical
are
used
in
this
ICR.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
labor
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
the
private
industry.

Managerial
$
78.54
($
37.40
+
110%)
Technical
$
55.34
($
26.35
+
110%)
Clerical
$
35.64
($
16.97
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
continuous
monitoring
systems.
There
are
no
capital
start
up
costs
since
no
new
facilities
will
become
subject
to
the
standard
over
the
next
three
years.
The
annual
operations
and
maintenance
costs
are
$
150,000.
This
is
based
on
an
estimated
20
facilities
that
have
installed
continuous
particulate
monitors
in
order
to
comply
with
this
MACT
standard,
multiplied
by
$
7,500
for
annual
upkeep
of
each
monitoring
device.
We
are
assuming
that
the
cost
for
operation
and
maintenance
of
a
temperature
monitor
is
negligent.
The
total
respondent
cost
is
calculated
by
adding
the
capital
start­
up
costs
and
the
annual
operations
and
maintenance
costs.
Since
there
are
no
capital
costs,
the
average
annual
burden
to
respondents
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
150,000.
9
(
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)

continuous
particulate
monitor
0
0
0
7,500
20
$
150,000
The
capital/
startup
costs
for
this
ICR
are
zero.
This
is
the
total
of
column
D.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
(
a):
Total
annualized
capital/
startup
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

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

The
total
respondent
non­
labor
costs
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
costs
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
The
only
costs
to
the
Agency
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
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
44,301
(
see
attached
Table
1).
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
36.98.
This
rate
is
from
OPM's
"
2001
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
1.
Annual
Agency
Burden
and
Cost.
10
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Citation
(
A)
No.
of
New
Sources/
Year
(
B)
No.
of
Initial
Reports
for
New
Sources
(
C)
No.
of
Existing
Sources
(
D)
No.
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)

Section
63.549
(
Notification
of
reconstruction)
1
*
1*
1
Sections
63.550(
b),
and
63.10
(
Semiannual
reports)
23
2
46
Sections
63.
(
Notification
of
operational
change_)
23
1
**
23
TOTAL
70
*
We
assume
that
although
no
new
plants
will
be
constructed,
one
new
furnace
or
affected
facility
will
be
rebuilt.
**
All
facilities
will
make
a
major
adjustment
once
a
year.

The
number
of
total
respondents
is
23
since
we
assume
that
no
new
plants
will
be
constructed
over
the
three
year
period.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.

The
"
Total
Annual
Responses"
is
70.
This
number
is
the
sum
of
the
Total
Annual
Responses
for
each
regulation
citation
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
(
b).
The
total
annual
labor
costs
for
respondents
are
$
876,004.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13
(
c),
only
the
burden
hours
are
reflected
in
block
13
(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Respondent
Burden
and
Cost.

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).
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Respondent
Burden
And
Cost
Table
Refer
to
Table
2,
attached.

6(
f)
Reasons
for
Change
in
Burden
There
is
no
increase
in
burden
hours
to
sources
subject
to
this
rule
when
compared
to
the
most
recently
approved
ICR,
however,
the
cost
for
recordkeeping
and
reporting
requirements
has
increase
due
to
an
increase
in
labor
rates
as
indicated
by
the
Bureau
of
Labor
Statistics.
11
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
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­
0001;
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.
