1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
National
Emission
Standards
for
Hazardous
Air
Pollutants
For
Beryllium
Rocket
Motor
Firing
(
Subpart
D)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP,
Subpart
D
­
Beryllium
Rocket
Motor
Firing
1(
b)
Short
Characterization/
Abstract
Beryllium
rocket
motor
firing
operations
result
in
emissions
of
beryllium.
In
the
Administrator's
judgment,
emissions
from
these
sources
are
in
sufficient
quantity
to
cause
or
contribute
to
air
pollution
that
may
endanger
public
heath
or
welfare.
Consequently,
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
40
CFR
61
subpart
D
was
promulgated
on
April
6,
1973
and
amended
on
November
7,
1985
for
this
source
category.
These
standards
establish
limits
for
beryllium.

In
order
to
ensure
compliance
with
the
standards,
adequate
record
keeping
and
reporting
is
necessary.
This
information
enables
the
Agency
to:
(
1)
identify
the
sources
subject
to
the
standard;
(
2)
ensure
initial
compliance
with
emission
limits;
and
(
3)
verify
continuous
compliance
with
the
standard.
Specifically,
the
rule
requires
subject
test
sites
to
test
ambient
air
for
beryllium
during
and
after
firing
of
a
rocket
motor.
Samples
are
analyzed
within
30
days
and
results
are
reported
to
the
EPA
Region
by
registered
letter
by
the
business
day
following
the
determination.
The
rule
also
requires
stack
sampling
of
beryllium
combustion
products
during
and
after
firing
of
rocket
motor,
and
analysis
and
reporting
within
30
days.
The
results
are
reported
to
EPA
by
the
day
following
the
determination
and
calculation.
There
is
one
test
facility
and
three
to
four
stored
beryllium
fueled
rockets
subject
to
NESHAP
40
CFR
61
subpart
D.

Under
OMB's
terms
of
clearance
for
ICR
1125.02,
it
stated
that
prior
to
submitting
the
collection
to
OMB
for
renewal,
EPA
should
carefully
examine
whether
the
monitoring
required
by
the
collection
imposes
any
financial
burden
on
the
respondent(
s)
that
should
be
included
in
the
estimate
of
operations
and
maintenance
costs.
In
this
particular
case,
the
respondent
does
not
incur
any
Capital
expense
burden
and
minimal
O&
M
costs
since
they
are
not
required
to
purchase
equipment
for
the
purpose
of
complying
with
the
PRA.
The
monitoring
is
done
by
the
respondent
with
his
existing
monitoring
equipment
and
only
during
a
test
firing
(
not
on
a
daily
basis)
which
is
already
estimated
in
Table
2.

The
cost
of
this
ICR
is
$
452.65
on
an
average
annual
basis.

2.
Need
for
and
Use
of
the
Collection
2
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
or
methods
(
in
accordance
with
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,
beryllium
emissions
from
beryllium
rocket
motor
firing
can
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
61
Subpart
D
.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
beryllium
from
National
Emission
Standard
for
Beryllium
Rocket
Motor
Firing
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
control
of
that
equipment.
Emissions
of
beryllium
from
the
National
Emission
Standard
for
Rocket
Motor
Firing
are
the
result
of
controlled
firing
of
rocket
motors
and
disposal
of
propellant.
Since
beryllium
is
a
hazardous
air
pollutant,
these
standards
rely
on
the
capture
and
reduction
of
beryllium
emissions.
The
required
notifications
are
used
to
inform
the
Agency
when
a
rocket
firing
is
planned.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
rocket
motor
and
equipment
are
properly
operated,
and
the
standard
is
being
met.
Test
reports
are
needed
as
these
are
the
Agency's
record
of
the
source
is
in
compliance
with
the
emission
standard.
The
information
generated
by
the
monitoring,
record
keeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
in
accordance
with
the
standards.

The
information
collected
from
record
keeping
and
reporting
requirements
is
also
used
for
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Non
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non
duplication
The
record
keeping
and
reporting
requested
is
required
under
40
CFR
Part
61
Subpart
D.
If
the
standard
has
not
been
delegated
the
information
is
sent
to
the
appropriate
EPA
Regional
3
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
standard,
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
planned
submission
of
this
ICR
to
OMB
was
published
in
the
Federal
Register
on
May
23,
2001,
(
66FR28462).
No
comments
were
received.

3(
c)
Consultations
For
the
burden
analysis,
EPA
Regional
Offices,
Research
Triangle
Park,
other
Federal
Agencies
and
industry
were
consulted.

3(
d)
Effects
of
Less
Frequent
Collection
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
main
consequence
would
be
that
the
standard
for
the
rocket
testing
could
not
be
monitored.
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
record
keeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.

3(
e)
General
Guidelines
None
of
the
reporting
or
record
keeping
requirements
contained
in
40
CFR
Part
61
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.5.

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
record
keeping
requirements
contained
in
40
CFR
Part
61
subpart
D
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
record
keeping
and
reporting
requirements
are
NESHAP
subpart
D
­
Beryllium
Rocket
Motor
Fuel
Firing
(
SIC
Code
3911)
for
missile
and
space
vehicle
propulsion
units
and
propulsion
unit
parts.

4(
b)
Information
Requested
(
i)
Data
items,
including
record
keeping
requirements
All
data
in
this
ICR
that
are
recorded
and
reported
is
required
by
40
CFR
61
Subpart
D.
Subpart
D
­
National
Emission
Standard
for
Beryllium
Rocket
Motor
Firing
and
general
provisions.

Emissions
testing
­
sample
tests
­
rocket
firing
or
propellent
disposal
­
40
CFR
61.43.

Stack
sampling
­
40
CFR
61.44.

Reports:

­
anticipated
firing
date
notification
­
40
CFR
61.43
or
61.44.
­
emissions
or
air
quality
­
40
CFR
61.10(
a).
­
emissions
test
report
and
ambient
air
quality
report
­
61.43
and
61.44.

Records
­
recording
air
sampling
test
results
­
40
CFR
61.43
.
­
recording
emission
test
results
­
40
CFR
61.44.
­
make
records
available
to
Agency
­
40
CFR
61.43
&
61.44.

Records
are
required
to
be
retained
for
a
minimum
of
two
years
for
the
air
sampling
test
results.
They
are
retained
at
the
source.

The
information
reported
is
reviewed
by
the
Regional
Office
and
data
may
be
entered
into
the
AIRS
data
base.
Reports
and
notifications
submitted
through
E­
mail
as
long
as
the
E­
mail
or
fax
machine
is
followed
up
with
hard
copy
letter
with
a
signature.
This
is
to
ensure
that
there
is
a
back
up
system
to
notify
the
Agency
of
the
reports
and
notifications.

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,
5
and
distribution
of
the
information
required
under
40
CFR
61
Subpart
D:
­
observes
air
sampling
tests
and
emission
tests
­
reviews
notifications
and
reports,
including
emission
reports,
required
to
be
submitted
by
industry
­
audits
facility
records
­
compiles
data
in
the
AIRS
database
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
tabulated
and
published
for
internal
Agency
use
in
compliance
and
enforcement
programs.
The
semiannual
and
other
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
may
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
The
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
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,
EPA
Regional
Offices
and
Headquarters.
EPA
can
edit,
store,
retrieve
and
analyze
the
data
via
PC
terminals.
The
records
required
by
this
NESHAP
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
standard.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
record
keeping
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.
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
record
keeping
6
and
reporting
requirements
is
estimated
at
annual
average
of
8.33
person­
hours.
We
expect
one
rocket
firing
over
a
three
(
3)
year
period.
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
program,
and
the
rule.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.
For
this
ICR
and
Regulation,
we
are
using
the
technical
rate
in
estimates.
(
The
technical
rate
is
used
at
$
55.34
($
26.35
per
hour
+
110%
overhead)
because
the
standard
requires
technical
hours
and
does
not
require
clerical
and
management
hours).

(
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.

(
iii)
Capital/
Start­
up
Operating
and
Maintenance
(
O&
M)
Costs
There
are
no
capital
start
up
costs
because
there
are
no
new
facilities,
and
no
maintenance
costs
because
there
are
no
continuous
monitors.

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
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards.
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
is
in
Table
1,
and
is
$
152.01.
(
This
cost
is
based
on
an
average
wage
of
a
GS­
10
Step
1
employee
rate
and
travel
associated
with
compliance
activities.)

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
61
Subpart
D
is
one.
There
is
one
facility
with
3­
4
test
rockets.
We
expect
one
firing
over
a
three
year
period.
The
total
average
annual
costs
are
$
452.65.
The
details
of
the
calculation
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Costs
Tables
7
See
Tables
1
and
2
(
attached)

6(
f)
Reasons
For
Change
In
Burden
Burden
hours
remain
unchanged.
However,
the
decrease
in
industry
burden
cost
from
the
most
recently
approved
ICR
is
due
to
more
accurate
hourly
rate
estimates
obtained
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group;
Column
2,
wages
and
salaries.

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
Ms
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822),
Office
of
Environmental
Information,
United.
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number1125.03
and
OMB
control
number2060­
0394
in
any
correspondence.

Part
B
of
the
Supporting
Document
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
8
