1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
For
Beryllium
Rocket
Motor
Firing
(
40
CFR
part
61,
subpart
D)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Beryllium
Rocket
Motor
Firing
(
40
CFR
part
61,
subpart
D)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
regulations
published
at
40
CFR
61.40
were
promulgated
on
April
6,
1973
and
amended
on
November
7,
1985
for
this
source
category.
These
regulations
apply
to
existing
facilities
and
new
facilities
that
test
rocket
motors
that
use
beryllium
propellant.
New
facilities
are
those
that
commenced
construction
or
reconstruction
after
the
date
of
promulgation.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
61,
subpart
D.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
2
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

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
part
61,
subpart
D.
It
is
estimated
that
there
will
be
no
new
sources
becoming
subject
to
this
regulation
in
the
next
three
years.
It
is
assumed
that
there
is
one
affected
facility
2
per
plant.

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.
For
this
rule
the
respondent
does
not
incur
any
capital
costs
since
there
are
no
new
facilities
expected
or
O&
M
costs
since
there
is
no
requirement
for
continuous
emissions
monitoring.

The
cost
of
this
ICR
is
$
538.08
on
an
average
annual
basis.

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
new
stationary
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
test
sites
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
beryllium
rocket
motor
test
sites
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
control
of
that
equipment.
Emissions
of
beryllium
from
the
beryllium
rocket
motor
test
sites
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
3
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.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
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
The
requested
record
keeping
and
reporting
are
required
under
40
CFR
part
61
subpart
D.

3(
a)
Non
duplication
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
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
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
planned
submission
of
this
ICR
to
OMB
was
published
in
the
Federal
Register
(
69
FR
29718)
on
May
25,
2004.
No
comments
were
received.

3(
c)
Consultations
To
determine
industry
size
and
growth
rate
the
EPA
database
OTIS
was
used
as
well
as
consultation
with
industry.
An
industry
representative
(
Robert
Peters,
Aerospace
Industries
Association;
703­
358­
8335)
was
consulted
to
determine
whether
it
would
be
possible
for
the
Agency
to
reduce
the
recordkeeping
and
reporting
burden,
or
improve
the
language
in
the
standards
to
facilitate
industry
compliance,
and
if
any
industry
reports
electronically.
Also
this
industry
representative
determined
by
polling
its
members
that
one
facility
is
subject
to
this
regulation
and
it
has
been
between
5
to
10
years
since
this
facility
was
used.
This
facility
has
no
concerns
with
the
reporting
or
recordkeeping
requirements
of
this
rule.
The
one
facility
subject
to
NESHAP
subpart
D
is:

ATK
Elkton
55
Thiokol
Road
Elkton,
MD
21921
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
record
4
keeping
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
standard
for
the
rocket
testing
could
not
be
monitored.

3(
e)
General
Guidelines
None
of
these
reporting
or
record
keeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

3(
f)
Confidentiality
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
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
beryllium
rocket
motor
test
sites.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Industry
Classification)
3764
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
336415
for
rocket
motor
test
sites.

4(
b)
Information
Requested
(
i)
Data
items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
the
National
Emission
Standards
for
Beryllium
Rocket
Motor
Firing
(
40
CFR
part
61
subpart
D).

A
source
must
make
the
following
reports:

Notification
Reports
Notification
and
application
of
construction
or
modification
61.06
and
61.07
Notification
of
anticipated
date
of
initial
startup
61.09(
a)(
1)

Notification
of
actual
startup
61.09(
a)(
2)
5
Notification
of
physical
or
operational
change
which
may
increase
the
emission
rate
61.15
Notification
of
performance
tests
61.13(
f)
and
61.14(
c)

Notification
of
anticipated
firing
61.43
or
61.44
Reports
Emission
source
reporting
61.10(
a)

Emission
test
report
and
ambient
air
quality
report
61.43
and
61.44
Recordkeeping
Maintain
records
of
monitoring
data,
monitoring
system
calibration
checks,
and
the
occurrence
and
duration
of
periods
where
the
monitoring
system
is
malfunctioning
or
inoperative.
Records
shall
be
retained
for
at
least
2
years
61.14(
f)

Record
air
sampling
results.
Records
are
required
to
be
retained
for
two
years.
61.43
Record
emission
test
results
61.44
Make
records
available
to
Agency
61.43
and
61.44
Electronic
Reporting
Reports
and
notifications
may
be
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.
In
addition,
some
regulatory
entities
(
government
agencies
and
respondents)
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
The
one
facility
that
is
subject
to
this
rule
does
not
report
electronically.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions
During
test
firing,
ambient
air
concentrations
shall
be
measured
during
and
after
test
firing
or
propellant
disposal,
in
such
a
manner
that
emissions
can
be
compared
with
the
standard.
Respondent
Activities
6
During
test
firing,
continuously
sample
emissions
from
the
test
tank
as
per
Method
104
(
or
alternately,
Method
103)

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.

Agency
Activities
Observe
air
sampling
tests
and
emission
tests.

Review
notifications
and
reports,
including
emission
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
check
if
the
pollution
control
practices
are
in
place
and
properly
implemented.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
7
tabulated
and
published
for
internal
Agency
use
in
compliance
and
enforcement
programs.
The
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
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
The
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
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
and
its
delegated
authorities
can
edit,
store,
retrieve
and
analyze
the
data
via.
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
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Beryllium
Rocket
Motor
Fuel
Firing
(
40
CFR
part
61,
subpart
D).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
each
of
the
record
keeping
and
reporting
requirements
applicable
to
the
industry
for
the
subparts
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.
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
and
reporting
requirements
is
estimated
to
be
8.43
hours.
These
hours
are
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
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
8
Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
December
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
information
collection
activities
required
by
the
subject
standard
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
211.82.

This
cost
is
based
on
the
average
hourly
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
the
OPM
web
site,
http//
www.
opm.
gov/
oca/
payrates/
index/
htm.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Beryllium
Rocket
Motor
Firing
(
40
CFR
part
61,
subpart
D),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
one
existing
source
is
currently
subject
to
the
standard.
This
one
facility
has
3
to
4
test
rockets.
We
expect
one
firing
over
a
three
year
period.
9
Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
1
0
0
1
2
0
1
0
0
1
3
0
1
0
0
1
Average
0
1
0
0
1
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
1.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
construction
or
modification
0
0
0
0
Notification
of
anticipated
initial
startup
0
0
0
0
Notification
of
actual
startup
0
0
0
0
Notification
of
physical
or
operational
change
1
0
0
0
Notification
of
performance
test
0
0
0
0
Notification
of
anticipated
firing
1
1
0
1
Total
1
The
number
of
Total
Annual
Responses
is
1.
This
number
is
shown
on
the
OMB
83­
I
10
form
in
block
13(
b),
Total
annual
responses.

6(
e)
Bottom
Line
Burden
Hours
And
Costs
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
zero.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Costs,
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Beryllium
Rocket
Firing
(
40
CFR
Part
61,
Subpart
D)
below.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
8
hours
per
response.

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

(
ii)
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
the
next
three
years
is
estimated
to
be
5.35
labor
hours
at
a
cost
of
$
211.82.
See
Table
2.
Annual
Agency
Burden
and
Cost,
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Beryllium
Rocket
Firing
(
40
CFR
part
61,
subpart
D)
below.

6(
f)
Reasons
For
Change
In
Burden
Burden
hours
are
unchanged
from
the
currently
active
ICR.
However,
the
increase
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
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
8
hours
per
response.
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
11
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0006,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
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.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0006
and
OMB
Control
Number
2060­
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.
12
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Beryllium
Rocket
Motor
Firing
(
40
CFR
Part
61,
Subpart
D).

Activity
Technical
Hrs./
Occurrence
(
A)
Occurrence/

Respondent/

Yr.

(
B)
Hours/
Respondent/
Yr.

(
C)

[
C
=
A
x
B]
Number
of
Respondents
(
D)
Technical
Hrs./
Yr.

(
E)

[
E
=
C
x
D]
Management
Hrs./
Yr.

(
F)

[
F
=
0.05
x
E]
Clerical
Hrs./
Yr.

(
G)

[
G
=
0.1
x
E]
Total
Labor
Costs/
Yr.

($)

(
H)
1
1.
Applications
A.
Application
for
approval
of
construction/
modificatio
n
12
0
0
0
0
0
0
0
B.
Source
information
report/
application
6
0
0
0
0
0
0
0
C.
Request
for
ambient
air
monitoring
alternative
18
0
0
0
0
0
0
0
2.
Survey
and
Studies
3.
Reporting
Requirements
A.
Read
Instructions
3
0.33
1
0
0
0
0
0
B.
Required
Activities
Emission
test
6
0.33
2
1
2
0.1
0.2
146.75
Calculation
of
emission
estimates
3
0.33
1
1
1
0.05
0.1
73.38
Monitoring
ambient
beryllium
concentrations
3
0.33
1
1
1
0.05
0.1
73.38
C.
Create
Information
2
0
0
1
0
0
0
0
Activity
Technical
Hrs./
Occurrence
(
A)
Occurrence/

Respondent/

Yr.

(
B)
Hours/
Respondent/
Yr.

(
C)

[
C
=
A
x
B]
Number
of
Respondents
(
D)
Technical
Hrs./
Yr.

(
E)

[
E
=
C
x
D]
Management
Hrs./
Yr.

(
F)

[
F
=
0.05
x
E]
Clerical
Hrs./
Yr.

(
G)

[
G
=
0.1
x
E]
Total
Labor
Costs/
Yr.

($)

(
H)
1
13
D.
Gather
Existing
Information
3
0.33
1
1
1
0.05
0.1
73.38
E.
Write
Report
Notification
of
test
1
0.33
0.33
1
0.33
0.02
0.03
24.43
Report
of
test
3
0.33
1
1
1
0.05
0.1
73.38
Report
of
calculated
emission
levels
3
0
0
0
0
0
0
0
Plan
for
locating
monitors
1
0
0
0
0
0
0
0
Report
monthly
ambient
concentrations
1
0
0
1
0
0
0
0
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
B.
Plan
Activities
C.
Implement
Activities
D.
Develop
Record
System
E.
Time
to
Enter
Information
3
0.33
1
1
1
0.05
0.1
73.38
F.
Train
Personnel
Activity
Technical
Hrs./
Occurrence
(
A)
Occurrence/

Respondent/

Yr.

(
B)
Hours/
Respondent/
Yr.

(
C)

[
C
=
A
x
B]
Number
of
Respondents
(
D)
Technical
Hrs./
Yr.

(
E)

[
E
=
C
x
D]
Management
Hrs./
Yr.

(
F)

[
F
=
0.05
x
E]
Clerical
Hrs./
Yr.

(
G)

[
G
=
0.1
x
E]
Total
Labor
Costs/
Yr.

($)

(
H)
1
14
G.
Audits
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
8.43
$
538.08
1
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
rates
[(
Technical
hours
x
$
64.60
+
(
Management
hours
x
$
95.32)
+
(
Clerical
hours
x
$
40.09)].
15
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Beryllium
Rocket
Motor
Firing
(
40
CFR
Part
61,
Subpart
D)

Activity
Technical
Hrs./
Occurrence
(
A)
Occurrence/

Respondent/

Yr.

(
B)
Hours/
Respondent/
Yr.

(
C)

[
C
=
A
x
B]
Number
of
Respondents
(
D)
Technical
Hrs./
Yr.

(
E)

[
E
=
C
x
D]
Management
Hrs./
Yr.

(
F)

[
F
=
0.05
x
E]
Clerical
Hrs./
Yr.

(
G)

[
G
=
0.1
x
E]
Total
Labor
Costs/
Yr.

($)

(
H)
1
1.
Performance
Test
A.
Rocket
Motor
Firing
6
0.33
2
1
2
0.1
0.2
90.98
2.
Report
Review
A.
Test
Firing
Report
Review
4
0.33
1.32
1
1.32
0.07
0.13
60.22
B.
Application
of
Construction
0
0.33
0
1
0
0
0
0
C.
Notification
of
Anticipated
Firing
of
Rocket
Motor
3
0.33
1
1
1
0.05
0.1
45.49
D.
Review
Report
of
Test
Results
1
0.33
0.33
1
0.33
0.02
0.03
15.13
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
5.35
$
211.82
1
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
rates
[(
Technical
hours
x
$
40.56)
+
(
Management
hours
x
$
54.66)
+
(
Clerical
hours
x
$
21.95)].
