SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Primary
Lead
Smelters
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
National
Emission
Standard
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Primary
Lead
Smelters
1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Primary
Lead
Smelters,
published
at
40
CFR
Part
63,
Subpart
TTT,
were
proposed
on
April
17,
1998
(
63
FR
19200),
and
promulgated
on
June
4,
1999
(
64
FR
30204).
On
February
12,
1999,
the
Agency
publicized
a
supplemental
rulemaking
for
ferroalloys,
mineral
wool,
primary
copper,
primary
lead
and
wool
fiberglass.
The
supplemental
for
this
rule
enhances
the
requirements
of
the
bag
leak
detection
systems
in
40
CFR
63.1625
and
40
CFR
63.1655
of
the
proposed
rule
to
include
an
enforceable
operating
limit.
This
rule
applies
to
emissions
sources
(
i.
e.,
sinter
machine,
blast
furnace,
dross
furnace,
process
fugitive,
and
fugitive
dust
sources)
from
primary
lead
smelters.

In
addition
to
the
records
required
by
40
CFR
Part
63,
Subpart
A
(
General
Provisions),
all
sources
subject
to
this
standard
are
required
to
submit:
an
initial
report
specifying
the
intended
methods
of
compliance;
a
site­
specific
test
plan
prior
to
a
performance
test;
a
standard
operating
procedure
(
SOP)
manual;
a
performance
test
report
for
lead
compounds;
and
a
semiannual
report
that
includes
all
monitoring
results
and
a
summary
of
any
baghouse
leak
detection
system
alarms
including
a
description
of
the
corrective
actions
taken.
Respondents
must
also
submit
reports,
when
applicable,
regarding
startup,
shutdown,
malfunctions,
process
changes,
and
construction
or
reconstruction.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
records
of
production
for
unrefined
lead,
copper
matte,
and
copper
speiss;
the
date
and
times
of
bag
leak
detector
system
alarms
and
the
corrective
action
taken;
baghouse
inspection
and
maintenance;
and
any
records
required
as
part
of
the
source
SOP
manual
and
the
compliance
methods
chosen.
Records
shall
be
maintained
for
a
period
of
5
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
Records
of
the
most
recent
2
years
of
operation
must
be
maintained
on
site.
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.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NESHAP.

Approximately
two
sources
are
currently
subject
to
the
regulation.
Based
on
consultation
with
industry
and
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
we
have
2
determined
that
one
existing
source
closed
operations
over
the
period
of
the
active
Information
Collection
Request
(
ICR),
and
no
new
sources
will
become
subject
to
the
regulation
in
the
next
three
years.

In
the
development
of
this
ICR
we
addressed
the
Office
of
Management
and
Budget
"
Terms
of
Clearance"
on
the
active
ICR.
Specifically,
we
revised
the
current
number
of
sources
affected
by
the
rule
and
revised
the
assumptions
that
were
made
on
the
active
ICR.
We
have
also
accounted
for
the
amortization
of
capital
costs
beyond
the
three
year
period
for
which
the
active
ICR
was
approved.

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,
lead
compounds,
and
other
metal
hazardous
air
pollutants
(
HAP)
including
arsenic,
antimony,
and
cadmium
emissions
from
sinter
machine,
blast
furnace,
dross
furnace,
process
fugitive,
and
fugitive
dust
sources,
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
standards
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
TTT.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
lead
compounds,
and
other
metal
hazardous
air
pollutants
(
HAP)
including
arsenic,
antimony,
and
cadmium
from
the
affected
facilities
3
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
These
emissions
are
the
result
of
operation
of
the
following
sources:
sinter
machine;
blast
furnace;
dross
furnace;
process
fugitive
sources
including
dross
furnace
charging
location,
blast
furnace
and
dross
furnace
tapping
location,
sinter
machine
charging
location,
sinter
machine
discharge
end,
sinter
crushing
and
sizing
equipment;
sinter
machine
area;
and
fugitive
dust
sources.
The
subject
standards
are
achieved
by
the
capture
and
reduction
of
lead
compounds,
and
other
metal
hazardous
air
pollutants
(
HAPs)
including
arsenic,
antimony,
and
cadmium
emissions
using
buildings
that
ventilate
to
baghouses
or
equivalent
control
devices;
ventilated
enclosures
to
further
reduce
process
fugitive
emissions;
and
the
establishment
of
operating
procedures
for
baghouses
and
fugitive
emissions
control
(
e.
g.,
fugitive
dust
sources
are
typically
controlled
by
reducing
the
potential
for
entrainment
through
measures
such
as
wetting,
pavement
cleaning,
use
of
chemical
stabilizers,
and
protection
from
wind).
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
regulations
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
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
local
agency.
If
a
State
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

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
October
29,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
However,
we
contacted
the
Environmental
Manager
responsible
for
the
two
existing
sources
to
this
rule
on
their
capital
and
operation
and
maintenance
costs
which
was
highlighted
by
OMB
under
the
"
Terms
of
Clearance."
4
3(
c)
Consultations
For
this
information
collection,
the
originator
conducted
a
query
on
the
Facility
Subsystem
(
AFS)
database
of
the
Aerometric
Information
Retrieval
System
maintained
by
the
Office
of
Air
Quality,
Planning
and
Standards
(
OAQPS)
and
contacted
the
OAQPS
lead
staff
for
this
rule,
Kevin
Cavender.
In
addition,
the
originator
contacted
the
Environmental
Specialist
of
the
Herculaneum
Division
and
the
Glover
Division
for
the
Doe
Run
Company,
to
discuss
capital
and
operation
and
maintenance
costs.
The
two
industry
contacts
are
listed
below.

James
M.
Lanzafame
The
Doe
Run
Company­
Smelting
Division
Herculaneum,
Missouri
(
636)
933­
3143
Scott
Lamb
The
Doe
Run
Company­
Glover
Division
Glover,
Missouri
(
573)
546­
2674
3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
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
the
Office
of
Management
and
Budget
(
OMB)
at
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).
5
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
to
the
recordkeeping
and
reporting
requirements
are
primary
lead
smelters.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
3339
(
Primary
Smelting
and
Refining
of
Nonferrous
Metals)
which
corresponds
to
the
following
NAICS
(
The
North
American
Industry
Classification
System)
331419
for
Primary
Smelting
and
Refining
of
Nonferrous
Metal
(
except
Copper
and
Aluminum).
Other
industries
listed
in
this
SIC
code
are
not
respondents
to
this
ICR.

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
TTT.

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
63,
Subpart
TTT
Construction/
reconstruction
63.5,
63.1163(
a)

Initial
notifications
63.9(
b)

Anticipated
start­
up
63.9(
a),
63.1163(
a)

Actual
start­
up
63.9(
a),
63.1163(
a)

Initial
performance
test
results
63.10(
d)(
2),
63.1164(
a)

Initial
performance
test
63.7(
b),
63.9(
e),
63.1163(
d)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system,
if
applicable
63.9(
g)

Request
for
an
extension
of
compliance
63.9(
c),
63.1163(
b)
6
Reports
for
40
CFR
Part
63,
Subpart
TTT
Notification
seeking
approval
of
standard
operating
procedures
manual
for
baghouses
and
the
standard
operating
procedures
manual
for
fugitive
dust
control
63.1548
Compliance
status
63.9(
h),
63.1163(
e)

Physical
or
operational
change
N/
A
Opacity
or
visible
emissions
63.10(
d)(
3)

Semi­
annual
reports
containing
(
1)
records
of
all
alarms
from
the
bag
leak
detection
system
including
a
description
of
the
procedures
taken
following
each
bag
leak
detection
system
alarm,
(
2)
a
summary
of
the
records
maintained
as
part
of
the
practices
described
in
the
baghouse
SOP;
and
(
3)
a
summary
of
the
fugitive
dust
control
measures
performed
during
the
required
reporting
period.
63.1164(
b),
63.1549(
e)

Periodic
start­
up,
shutdown,
malfunction
reports
63.10(
d)(
5)(
i),
63.1164(
c)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
63,
Subpart
TTT
Start­
ups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2),
63.1165(
a),
63.1549(
b)

Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g),
63.1165(
a)(
7)

All
reports
and
notifications
63.9,
63.10(
b),
63.1165(
a)(
10)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)

Records
of
bag
leak
detection
system;
standard
operating
procedures
manuals
for
baghouses
and
fugitive
dust
control;
and
specific
parameters
to
demonstrate
compliance
with
the
sinter
building
in­
draft
standard
63.1165(
b),
63.1549(
b)

Records
are
required
to
be
retained
for
5
years.
The
first
two
years
of
records
must
be
retained
at
the
facility.
63.1165(
a­
c),
63.1549(
c)
7
(
ii.)
Respondent
Activities
Respondent
Activities
Read
instructions.

Owners
are
required
to
equip
process
fugitive
sources
with
a
hood
that
is
ventilated
to
a
baghouse
or
equivalent
control
device
and
to
enclose
the
sinter
machine
area
in
a
building
that
is
ventilated
to
a
baghouse
or
equivalent
control
device.

Owners
are
required
to
follow
the
standard
operating
procedures
for
baghouses
and
fugitive
dust
control.

Perform
initial
performance
test,
Reference
Methods
1,
2,
3,
4
and
12
test
or
approved
alternative
method,
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.

There
is
a
trend
in
the
industry
toward
using
computer
controlled
operating
systems
that
handle
much
of
the
data
that
had
traditionally
been
handled
by
hand,
which
has
significantly
reduced
the
time
needed
to
record
and
store
data.
Some
delegated
offices
are
setting
up
electronic
reporting
systems
to
enable
facilities
to
report
electronically,
which
is
further
reducing
labor
costs.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
8
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
emissions
reports,
maintenance
plan
and
startup,
shutdown
and
malfunction
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
start­
up
or
operational
changes,
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.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
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,
EPA
Regional
Offices
and
EPA
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.

5(
c)
Small
Entity
Flexibility
9
The
Small
Business
Administration
(
SBA)
defines
a
small
business
for
SIC
3341
as
any
company
with
500
or
fewer
employees.
Neither
of
the
two
companies
in
this
industry
meet
the
small
business
criterion.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden.
Existing
sources
have
2
years
from
the
date
of
publication
to
achieve
compliance
with
the
standard.
Therefore,
the
compliance
date
for
this
rule
is
June
4,
2002.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
12,246
(
Total
Labor
Hours
from
Table
1).
This
estimate
is
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
consultation
with
industry
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
labor;
$
55.34
per
hour
for
Technical
labor,
and
$
35.64
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
78.54
($
37.40
+
110%)
Technical
$
55.34
($
26.35
+
110%)
Clerical
$
35.64
($
16.97
+
110%)
10
(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor,
continuous
operation
of
baghouses
and
continuous
emission
monitors
(
CEMs).
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
baghouses,
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
This
estimate
includes
the
cost
of
equipment,
parts,
energy
consumption
and
contracted
maintenance
labor.

Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
($)
for
One
Affected
Facility
*
(
C)
Number
of
Affected
Facilities
with
Startup
Costs*
(
D)
Total*
Capital/
Startup
Costs
(
B
X
C)
(
E)
Total
Annual
O&
M
Costs
($)
for
the
Two
Affected
Facilities
**
(
F)

Total
Annualized
Costs
(
D
+
E)

Flowmeters
with
high/
low
alarms
0
0
0
$
212
(
106
x
2)
$
212
Baghouses
4,000,000
1
4,000,000
$
2,451,666
($
1,476,666
+
$
975,00)
$
6,451,666
Total
$
4,000,000
$
2,451,878
$
6,451,878
*
There
are
two
existing
sources.
One
of
the
existing
sources
is
currently
in
the
process
of
completing
the
installation
of
3
baghouses
and
associated
ductwork,
new
building
enclosures
and
new
material
handling
equipment,
which
has
not
been
accounted
for
on
the
active
ICR,
for
a
total
cost
of
about
12
million
dollars.
The
other
existing
source
will
not
be
installing
any
new
equipment.

**
Cost
of
operation
and
maintenance
of
baghouses
is
based
on
a
total
of
19
baghouses.
The
major
expenses
on
baghouses
are
associated
with
the
replacement
of
bags
and
electricity
to
run
them.
The
annual
cost
of
electricity
for
the
two
sources
are
significant
different
due
to
one
source
having
double
the
number
of
baghouses
(
i.
e.,
one
source
has
6
baghouses
and
the
other
source
has
13
baghouses)
and
the
variation
of
baghouses
size
being
operated
by
each
source.
Other
miscellaneous
costs
are
associated
with
contractor
support,
repairs
and
other
miscellaneous
items.

The
total
annual
capital/
startup
costs
for
this
ICR
are
$
4,000,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
11
the
OMB
83­
I
form
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
2,451,878.
This
is
the
total
of
column
E.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
6,451,878.
This
is
the
total
of
column
F.
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
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
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.
We
assumed
that
the
Agency
will
be
attending
one
stack
test
at
each
source
during
the
3
years
of
this
ICR.

The
average
annual
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
4,610.45
[
Total
Cost
from
Table
2
attached].
This
cost
is
based
on
the
average
hourly
labor
rates
specified
by
the
Office
of
Personnel
Management
"
2002
General
Schedule"
(
excludes
locality
rates
of
pay)
for
the
managerial,
technical
and
clerical
categories
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
as
described
below:

Managerial
$
51.62
(
GS­
13,
Step
5,
$
32.26
x
1.6)
Technical
$
38.30
(
GS­
12,
Step
1,
$
23.94
x
1.6)
Clerical
$
20.72
(
GS­
6,
Step
3,
$
12.95
x
1.6)

Details
upon
which
this
estimate
is
based
appear
in
Table
1,
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Citation
(
A)
Number
of
New
Sources
per
Year
(
B)
Number
of
Initial
Reports
for
New
Sources
(
C)
Number
of
Existing
Sources
(
D)
Number
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)

40
CFR
Part
63,
Subpart
TTT
0
0
2
2
4
12
The
number
of
total
respondents
is
2.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
total
annual
responses
is
4.
This
is
the
number
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
are
$
669,100.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
1,
Annual
Respondent
Burden
and
Cost.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
6,451,878.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
is
caused
by
better
estimates
of
the
burden
associated
with
the
monitoring
requirements
for
baghouses.
This
ICR
also
assumes
that
both
sources
are
already
complying
with
the
requirements
of
this
rule
since
the
compliance
date
has
almost
expired,
and
therefore,
the
burden
is
not
phased­
in
by
year
as
was
done
in
the
active
ICR.
In
addition,
the
annual
capital/
startup
costs
and
operation
and
maintenance
costs
for
this
ICR
have
significantly
increased
due
to
one
source
purchasing
new
baghouses
and
better
estimates
of
the
operation
and
maintenance
costs
associated
with
baghouses
(
e.
g.,
cost
of
electricity
and
replacement
of
bags).
During
the
development
of
this
ICR,
we
contacted
industry
representatives
(
see
Consultation
Section)
to
confirm
these
burden
estimates
associated
with
the
implementation
of
the
NESHAP
for
Primary
Lead
Smelters.
Because
the
values
obtained
from
industry
are
a
projection
over
the
next
3
years,
they
are
considered
estimates
only.

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
13
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
standards
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
2822T),
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
Number
1856.03
and
the
OMB
Control
Number
2060­
0414
in
any
correspondence.

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