SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Primary
Lead
Smelters
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
which
enhanced
the
requirements
for
bag
leak
detection
systems
in
40
CFR
63.1625
and
40
CFR
63.1655
by
including
an
enforceable
operating
limit
in
this
rule.
These
standards
apply
to
emissions
sources
from
primary
lead
smelters
including
sinter
machine,
blast
furnace,
dross
furnace,
process
fugitive,
and
fugitive
dust
sources.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
TTT.

The
monitoring,
recordkeeping,
and
reporting
requirements
outlined
in
these
rules
are
similar
to
those
required
for
other
NESHAP
regulations.
Consistent
with
the
NESHAP
General
Provisions
(
40
CFR
part
63,
subpart
A),
respondents
are
required
to
submit
initial
notifications,
conduct
performance
tests,
and
submit
periodic
reports.
They
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility;
any
period
during
which
the
monitoring
system
is
inoperative;
the
production
for
unrefined
lead,
copper
matte,
and
copper
speiss;
the
date
and
times
of
bag
leak
detection
system
alarms
and
the
corrective
action
taken;
baghouse
inspection
and
maintenance;
any
records
required
as
part
of
the
source
standard
operating
procedures
(
SOP)
manuals;
and
the
compliance
methods
chosen.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
affected
facilities
subject
to
NESHAP.

Any
owner/
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
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
the
development
of
this
Information
Collection
Request
(
ICR),
we
reviewed
the
Office
of
Management
and
Budget
(
OMB)
A
Terms
of
Clearance@
(
TOC)
section
on
the
active
ICR.
There
were
no
comments
in
the
TOC
section.

Based
on
Agency
information
available
on
the
sector,
we
have
determined
that
two
respondents
(
i.
e.,
primary
lead
smelters),
currently
operating
in
the
United
States,
are
subject
to
the
2
regulation,
and
we
estimate
that
no
additional
respondents
will
become
subject
to
the
regulation
in
the
next
three
years.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
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
(
HAP).
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/
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
hazardous
air
pollutants
from
process
sources,
process
fugitive,
and
fugitive
dust
sources
including
sinter
machines
and
blast
and
dross
furnaces,
and
organic
HAP
emissions
from
blast
furnaces
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
standards
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
TTT.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard
ensure
compliance
with
the
applicable
regulations
that
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.
Performance
tests
are
required
in
order
to
determine
an
affected
facility=
s
initial
capability
to
comply
with
the
emission
standard.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standard
at
all
times.
During
the
performance
test
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
compliance
in
place
of
a
continuous
emission
monitor.

The
notifications
required
in
the
standard
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
3
and
operated,
leaks
are
being
detected
and
repaired,
and
the
standard
is
being
met.
The
performance
test
may
also
be
observed.

The
required
semiannual
compliance
certifications
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation
and
maintenance
procedures
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
TTT.

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
its
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
(
FR
citation,
e.
g.,
70
FR
24020)
on
May
6,
2005.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
After
reviewing
industry
data
gathered
for
the
rule
development
and
by
the
Office
of
Air
Planning
and
Standards
(
OAQPS)
for
the
NESHAP
and
the
Office
of
Compliance
during
the
renewal
of
the
active
ICR,
as
well
as
consultation
with
OAQPS
staff,
we
have
determined
that
additional
consultations
with
industry
are
inappropriate
for
this
ICR
renewal.

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
that
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
4
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications
for
at
least
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.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

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
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
owners
or
operators
of
primary
lead
smelting
and
refining.
The
Standard
Industrial
Classification
(
SIC)
Code
for
this
industry
is
SIC
3339,
Primary
Smelting
and
Refining
of
Nonferrous
Metals,
which
under
the
new
North
American
Industrial
Classification
System
(
NAICS)
codes
would
be
NAIC
code
331419,
Primary
Smelting
and
Refining
of
Nonferrous
Metal
(
except
Copper
and
Aluminum).

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
part
63,
subpart
TTT).

A
source
must
make
the
following
reports:
5
Notification
Reports
Initial
notification
requirements
63.9(
b)(
1)

Notification
of
compliance
status
when
a
source
becomes
subject
to
the
standard
63.9(
h)

Notification
that
source
is
subject
to
special
compliance
requirements,
if
applicable
63.9(
d)

Notification
of
performance
test
63.7(
b),
63.9(
e)

Rescheduled
of
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Change
in
information
already
provided
63.9(
j)

Request
for
an
extension
of
compliance
with
relevant
standard
63.9(
c)

Reports
Application
for
approval
of
the
construction
or
reconstruction
of
a
new
major
affected
source,
or
reconstruction
of
a
major
affected
source
63.5(
6)(
d)

Performance
test
results
63.10(
d)(
2)

Report
of
opacity
and
visible
emission
observations
63.9(
f)

Startup,
shutdown
and
malfunction
plan
63.6(
e)(
3)

Periodic
startup,
shutdown
and
malfunction
reports
63.10(
d)(
5)(
i)

Notification
of
compliance
status
63.9(
h)

SOP
for
baghouses
and
fugitive
dust
control
63.1548(
b)

Progress
reports
for
compliance
extension
(
if
applicable)
63.6(
i)

Report
of
annual
compliance
tests
63.10(
d)(
2)

Semiannual
reports
63.1549(
e)

A
source
must
keep
the
following
records:

Recordkeeping
Startup,
shutdown
and
malfunction
plan
63.6(
e)(
3)

All
reports
and
notifications
63.10(
b)(
1)

Records
of
startup,
shut­
down,
and
malfunction
of
process
equipment
63.10(
b)(
2)(
i),
(
iv),
(
v)
6
Recordkeeping
Records
of
malfunctions
of
air
pollution
control
equipment
63.10(
b)(
2)(
ii)
Any
applicability
determination
that
demonstrates
why
owner
or
operator
believes
source(
s)
is/
are
unaffected
63.10(
b)(
3)

Records
of
maintenance
of
air
pollution
control
equipment
63.10(
b)(
2)(
iii)
Records
of
flow
monitoring
system
performance
evaluations,
malfunctions,
calibrations,
and
adjustments
63.10(
b)(
2)(
vi),
(
vii),
(
viii),
(
ix),
(
x),
(
xi),
63.10(
c)
Documentation
required
for
waiver
of
recordkeeping
or
reporting
requirements
(
if
applicable)
63.10(
b)(
2)(
xii)

Documentation
of
initial
notifications
63.10(
b)(
2)(
xiv)
Production
records
of
the
weight
and
lead
content
of
unrefined
lead,
copper
matte,
and
copper
speiss
63.1549(
b)(
1)

Records
of
bag
leak
detection
system
output
63.1549(
b)(
2)
Records
of
bag
leak
detection
system
alarms
and
corrective
actions
63.1549(
b)(
3)
Records
of
fugitive
dust
control
activities
63.1549(
b)(
4)
Records
of
baghouse
inspections
and
maintenance
63.1549(
b)(
5)
Records
of
doorway
in­
draft
checks
63.1549(
b)(
6)
Records
of
flow
monitoring
system
output
(
if
applicable)
63.1549(
b)(
7)
Records
of
damper
position
checks
(
if
applicable)
63.1549(
b)(
8)

Five­
year
retention
of
records
63.10(
b)(
1),
63.1549(
b)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

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.
7
Respondent
Activities
Transmit,
or
otherwise
disclose
the
information.

Regulatory
agencies,
to
the
extent
possible,
are
relying
more
on
automated
techniques
such
as
electronic
submissions
of
reports,
and
are
improving
their
tracking
systems
and
database
systems
to
enhance
the
use
of
these
techniques.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

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
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
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
report
of
annual
compliance
tests
is
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.
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
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
headquarters
and
EPA
regional
offices.
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/
operator
for
five
years.
8
5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses,
as
defined
by
the
Small
Business
Administration
(
SBA),
affected
by
this
regulation.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT).

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
12,190
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:

Managerial
$
97.46
($
46.41
+
110%)
Technical
$
83.71
($
39.86
+
110%)
Clerical
$
42.55
($
20.26
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
A
Table
2.
Civilian
Workers,
by
occupational
and
industry
group.@
The
rates
are
from
column
1,
A
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
9
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standards
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
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
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost
(
B
X
C)
(
E)
Total
Annual
O&
M
Costs
for
Both
Respondents
(
F)
Total
Annualized
Cost
Bag
Leak
detection
system
­
continuous
particulate
matter
sensor
$
10,500
0
$
0
$
9,500
Flow
monitors
with
high/
low
alarms
$
6,500
0
$
0
$
9,500
Total
Capital
Cost/
Total
O&
M
Cost
$
0
$
19,000
$
19,000
There
are
no
capital/
startup
costs
for
this
ICR.
This
cost
is
based
on
the
assumption
that
both
existing
plants
have
already
purchased
and
installed
bag
leak
detector
systems
at
baghouses
and
flow
monitoring
systems
and
recorders.
The
cost
for
monitors
was
provided
to
OAQPS
by
vendors.
We
have
also
assumed
that
no
new
plants
will
be
constructed.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
19,000.
This
cost
is
based
on
the
assumption
that
each
baghouse
will
have
a
continuous
bag
leak
detector
and
a
continuous
flow
monitor.
The
O&
M
costs
are
estimated
at
$
500
per
year
per
monitoring
system
per
baghouse.
We
have
determined
that
there
is
a
total
of
19
baghouses
at
two
existing
plants
(
i.
e.,
respondents)
owned
by
the
same
corporation,
i.
e.,
one
plant
has
6
baghouses
and
the
other
plant
has
13
baghouses.
Therefore,
the
total
O&
M
cost
for
each
monitoring
system
is
$
9,500
resulting
in
a
total
O&
M
cost
of
$
19,000.
This
is
the
total
of
column
E
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
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
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
19,000.
This
is
the
total
of
column
F
in
the
above
table.
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.
The
figures
on
the
OMB
10
83­
I
form
reflect
the
rounding
up
of
each
cost
individually,
so
the
total
cost
is
$
19,000
(
rounded).

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
labor
costs
associated
with
analysis
of
the
reported
information.
Respondents
will
bear
the
cost
through
permit
fees,
for
daily
performance
tests
conducted
at
the
plant
by
a
certified
observer
provided
by
the
State
enforcement
agency.
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
$
2,611
(
rounded).
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
A
2005
General
Schedule@
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
and
Cost
to
the
Federal/
State
Government:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
two
respondents,
currently
operating
in
the
United
States,
are
subject
to
the
regulation.
It
is
estimated
that
no
new
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

The
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
2
0
0
2
2
0
2
0
0
2
11
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)

3
0
2
0
0
2
Average
0
2
0
0
2
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
two.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
Total
Annual
Responses
is
four,
as
described
below.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

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
Semiannual
reports
2
2
0
4
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
12,190.
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
Cost:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT),
attached.

There
are
no
annualized
capital/
startup
and
O&
M
costs
to
the
regulated
entities
subject
to
the
regulation.
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.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
101
labor
hours
at
a
cost
of
$
2,611
(
rounded).
See
Table
2.
Annual
Agency
Burden
and
Cost:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT),
attached.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
12
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
12,190
(
rounded).
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
Cost:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT),
attached.

There
are
no
annualized
capital/
startup
and
O&
M
costs
to
the
regulated
entities.
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)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
64
labor
hours
at
a
cost
of
$
2,611.
See
Table
2.
Annual
Agency
Burden
and
Cost:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT),
attached.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
labor
burden
to
industry
from
the
most
recently
approved
ICR
from
12,246
hours
to
12,190
hours
is
due
to
adjustments.
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
the
assumption
that
all
three
existing
respondents
have
complied
with
the
initial
requirements
of
the
rule.
We
have
also
assumed
that
there
will
be
no
new
growth
in
this
industry
sector.

The
total
annualized
capital
and
operations
and
maintenance
costs
decreased
from
$
40,000
to
$
19,000
due
to
a
lack
of
capital/
startup
costs
associated
with
new
sources
purchasing
continuous
emission
monitoring
equipment.
The
operation
and
maintenance
costs
for
the
monitoring
equipment
at
existing
sources
are
anticipated
to
continue
over
the
next
three
years.

Although
there
was
an
increase
in
labor
rates
for
both
industry
and
the
Federal
government,
it
did
not
offset
the
reduction
in
labor
burden
due
to
the
assumptions
stated
above.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
3,048
(
rounded)
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,
13
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
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
2005­
0046,
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,
N.
W.,
Washington,
D.
C.
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
Docket
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
A
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2005­
0046
and
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.
14
Table
1.
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT)

Burden
item
(
A)
Person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Person­

hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
person­

hours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
person­

hours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,

and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
A.
Read
instructions
1
1
1
0
0.0
0.0
0.0
$
0.00
B.
Required
activities:

i.
Initial
Performance
tests:
c
8
1
8
0
0.0
0.0
0.0
$
0.00
ii.
Monitoring
of
operations
and
equipment:
d
­
Implement
baghouses
SOP
13.4
365
4,891
2
9,782.0
489.1
978.2
$
908,141.32
­
Annual
compliance
stack
test
for
lead
compounds
e
8
1
8
3
24.0
1.2
2.4
$
2,228.11
15
Burden
item
(
A)
Person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Person­

hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
person­

hours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
person­

hours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
D.
Gather
Existing
Information
Included
in
4B
and
5E
E.
Write
report
a,
c
i.
Notification
of
compliance
status
2
1
2
0
0.0
0.0
0.0
$
0.00
ii.
Notification
of
actual
startup
2
1
2
0
0.0
0.0
0.0
$
0.00
iii.
Notification
of
construction/
reconstruction
a
2
1
2
0
0.0
0.0
0.0
$
0.00
iv.
Notification
of
Performance
Test
2
1
2
0
0.0
0.0
0.0
$
0.00
v.
Notification
of
actual
startup
2
1
2
0
0.0
0.0
0.0
$
0.00
vi.
Reports
of
performance
test
results
4
1
4
0
0.0
0.0
0.0
$
0.00
vii.
Operation
and
maintenance
reports
10
1
10
0
0.0
0.0
0.0
$
0.00
viii.
Semi­
annual
reports
e
16
2
32
2
64
3.2
6.4
$
5,941.44
ix.
Notification
of
f
physical/
operational
changes
2
1
2
0
0.0
0.0
0.0
$
0.00
16
Burden
item
(
A)
Person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Person­

hours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
person­

hours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
person­

hours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
5.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
4A
B.
Plan
activities
Included
in
4B
C.
Implement
activities
Included
in
4B
D.
Develop
record
system
N/
A
E.
Time
to
enter
and
transmit
information:

­
Records
of
operating
parameters
­
Records
of
compliance
inspections
­
Records
of
performance
tests
1
365
365
2
730.0
36.5
73.0
$
67,771.74
F.
Time
to
train
personnel
N/
A
G.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
10,600.0
530.0
1,060.0
$
984,082.80
TOTAL
LABOR
HOURS
(
Rounded)
12,190
$
984,083
17
Assumptions:

a
There
are
an
estimated
two
respondents
which
are
subject
to
this
standard.
We
have
assumed
that
there
will
be
no
new
net
growth
for
this
industry
over
the
three
year
period
of
this
ICR.

b
This
ICR
uses
the
following
labor
rates:
$
97.46
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
83.71
per
hour
for
Technical
labor,
and
$
42.55
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
A
Table
2.
Civilian
Workers,
by
occupational
and
industry
group.@
The
rates
are
from
column
1,
A
Total
compensation.@
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c
We
have
assumed
that
all
sources
are
in
compliance
with
initial
rule
requirements
including
initial
performance
test
using
Method
12
for
lead
emissions
and
initial
sinter
building
in­
draft
compliance
demonstration.

d
Monitoring
of
operations
includes:
1)
implementation
of
Standard
Operating
Procedures
(
SOP)
for
operation
and
maintenance
of
baghouses
on
a
daily
basis
such
that
its
bag
leak
detection
system
does
not
alarm
more
than
five
percent
of
the
time
in
any
6­
month
period
which
we
have
assumed
it
takes
about
13.4
labor
hours
per
24
hour
day
to
implement
the
monitoring
and
recordkeeping
requirements;
2)
an
annual
compliance
test
for
lead
compounds;
3)
and
the
monitoring
of
sinter
building
in­
draft
for
which
the
operators
are
given
three
options
to
comply
including:
daily
checks
for
in­
draft
at
all
doorway
openings
using
an
anemometer
or
equivalent
device;
establish
and
maintain
the
ventilation
exhaust
rate
and
damper
positions
at
settings
that
result
in
an
in­
draft
at
each
open
doorway;
and
an
alternative
monitoring
method.

e
We
have
assumed
that
sources
are
conducting
annual
compliance
tests.
However,
upon
demonstrating
compliance
for
three
consecutive
years,
operators
will
be
allowed
up
to
24
months
between
compliance
tests.
Operators
will
retain
the
24
month
compliance
test
schedule
as
long
as
each
subsequent
test
demonstrates
that
the
facility
is
in
compliance
with
the
plant
wide
emission
limit.
The
annual
test
results
are
submitted
with
the
semiannual
reports.

f
We
are
assuming
that
sources
will
not
be
changing
operating
parameters
even
when
sources
may
purchased
new
equipment.
18
Table
2.
Annual
Burden
and
Cost
for
The
Federal
Government:

NESHAP
for
Primary
Lead
Smelters
(
40
CFR
Part
63,
Subpart
TTT)

Activity
(
A)
EPA
person­

hours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)

EPA
person­

hours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
person­

hours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
Initial
Notifications
c
2
1
2
0
0
0
0
$
0.00
Reports
of
performance
test
results
c
8
3
2
0
0
0
0
$
0.00
Notification
of
physical
or
Operational
changes
c
4
1
2
0
0
0
0
$
0.00
Semi­
annual
reports
d
10
2
20
2
40
2.0
4.0
$
1,864.84
Review
annual
test
results
d
8
1
8
2
16
0.8
1.6
$
745.94
Subtotal
Burden
and
Cost
56
2.8
5.6
$
2,610.78
TOTAL
ANNUAL
BURDEN
AND
COST
(
rounded)
64
$
2,611
Assumptions:

a
We
have
assumed
that
there
are
approximately
two
respondents
currently
operating
in
the
United
States.
It
is
estimated
that
no
additional
respondents
will
become
subject
to
the
regulation
in
the
next
three
years
based
on
information
available
on
the
sector.

b
This
cost
is
based
on
the
following
labor
rates
which
incorporates
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
Managerial
rate
of
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6),
Technical
rate
of
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6),
and
Clerical
rate
of
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
A
2005
General
Schedule@
which
excludes
locality
rates
of
pay.

c
We
have
assumed
that
all
existing
sources
are
in
compliance
with
the
initial
rule
requirements.
19
d
Although
the
semi­
annual
reports
will
include
the
annual
stack
test
results,
we
have
accounted
its
burden
separately
since
it
will
only
occur
once
a
year.
