Supporting Statement for NSPS for Lead Acid Battery Manufacturing 

(40 CFR part 60, subpart KK) 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Lead Acid Battery Manufacturing (40 CFR part 60, subpart KK)

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subpart KK were proposed on January 14,
1980, and promulgated on April 16, 1982.  These regulations apply to the
following affected facilities in lead-acid battery manufacturing plants
with production capacity that is equal to, or exceeds 6.5 tons of lead:
grid casting facilities, paste mixing facilities, three-process
operation facilities, lead-oxide manufacturing facilities, lead
reclamation facilities, and other lead-emitting operations, commencing
construction, modification, or reconstruction after the date of
proposal.  This information is being collected to assure compliance with
40 CFR part 60, subpart KK.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports (e.g., semiannual) if using
continuous emissions monitoring systems.  Owners, or operators also are
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 NSPS.

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

Based on the number of applicable sources in the previous ICR renewal,
approximately 52 sources currently are subject to the standard, and it
is anticipated that no additional sources will become subject to the
standard in the next three years.  This estimate is based on recent data
available on EPA’s Air Facility System (AFS) database, which can be
accessed through the Online Tracking Information System (OTIS) database,
and consultation with the Battery Council International organization.  

The current ICR is based on the most recently approved Information
Collection Request (ICR).  The cost of this ICR will be $ 249,933.  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.

	OMB approved the currently active ICR without any “Terms of
Clearance.”

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  

Section 111 also requires that the Administrator review and, if
appropriate, revise such standards every four years.

In the Administrator’s judgment, lead emissions from lead-acid battery
manufacturing plants cause, or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, NSPS standards were promulgated for this source category at 

40 CFR part 60, subpart KK.

2(b)  Practical Utility/Users of the Data

The control of emissions of lead from lead-acid battery manufacturing
plants requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of lead in the production of lead-acid batteries are the
result of the operation of grid casting, paste mixing, three-process
operation, lead oxide, and lead reclamation facilities, as well as any
other lead-emitting operations.  These standards rely on the capture of
lead emissions by control devices such as scrubbers.  The subject
standards are achieved by the capture of lead emissions using scrubbing
systems and baghouses.  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 records 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.  Operating conditions
include lead emission concentration in the gas stream, volumetric flow
rate of the effluent gas, lead feed rate to the facility, number of
emission points, pressure drop across the scrubbing system, and opacity
of gases.  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 NSPS continue to operate the
control equipment and achieve compliance with the regulation.  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 recordkeeping and reporting
requirements also is used for targeting inspections, and is of
sufficient quality to be used as evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, 

subpart KK.

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 on June 21, 2006 (71 FR 35652). 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

For this information collection, the previous ICR renewal was used to
obtain burden estimates since this ICR renewal was processed under the
“renew without change” option.  Per this guidance, all data and
assumptions from the previous ICR renewal were used as the basis for
estimating the hourly and cost burdens associated with this renewal.  

  SEQ CHAPTER \h \r 1 As mentioned in Section 1(a), the estimate on the
number of sources in the previous ICR renewal was determined based on
recent data available in AFS, which can be accessed through the OTIS
database.  In addition, the originator consulted the Battery Council
International organization located in Washington, D.C.  Based on these
resources, it was determined that the number of sources significantly
decreased when compared to the most recently approved ICR, which used
estimates from a 1995 survey conducted by EPA.

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 violates any of
the regulations established by OMB at 5 CFR 1320.5.

3(f)  Confidentiality

The required information has been determined not to be confidential. 
However, any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contains sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
lead-acid battery manufacturing plants.  The SIC code for the
respondents affected by the standards is SIC (United States Standard
Industrial Classification) 3691, Storage Batteries, which corresponds to
the NAICS (The North American Industry Classification System) code
335911, Storage Battery Manufacturing.

4(b)  Information Requested

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
40 CFR part 60, subpart KK.

A source must make the following reports:

Reports for 40 CFR part 60, subpart KK



Notification of construction/reconstruction	

60.7(a)(1) 



Notification of initial startup	

60.7(a)(3)



Notification of initial performance test	

60.8(d)



Physical or operational change	

60.7(a)(4)



Report opacity results (reported with the initial performance test
results) and at other times opacity observations are required 	

60.11(e)



Report of performance test results	

60.8(a)



Periodic reports if using continuous emissions monitoring systems (e.g.,
semiannual)	

60.7(c)

60.7(e)



A source must maintain the following records:



Recordkeeping for 40 CFR part 60, subpart KK



Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	

60.7(b)



Performance test records	

60.7(d)



Pressure drop monitoring records for sources using a scrubber system 	

60.7(e),

60.373



Maintain a file of all measurements, maintenance, reports, and records,
for at least two years	

60.7(f)



(ii)  Respondent Activities

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate a monitoring device that
measures pressure drop across the scrubbing system every 15 minutes.



Perform initial performance test using Reference Method 12 to determine
lead concentration and volumetric flow rate, and Reference Method 9 for
opacity readings, 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.



Presently sources are using monitoring equipment that provides parameter
data in an automated way (e.g., pressure drop indicators); however,
personnel at the facility still need to evaluate the data.  However,
this type of monitoring equipment has significantly reduced the burden
associated with monitoring and recordkeeping.  In addition, some
regulatory agencies are setting up electronic reporting systems to allow
sources to report electronically, or by means of a disk, which is
reducing the reporting burden.  However, electronic reporting systems
still are not widely used by the regulatory agencies.

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 results,
required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AFS database, which can be
accessed through 

the OTIS.



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.  Performance test reports are used by
the Agency to discern a source’s initial capability to comply with the
emission standard, and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

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
and annual emission inventory data for more than 100,000 industrial and
government-owned facilities.  EPA uses the 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 at least two years.

5(c)  Small Entity Flexibility

The recordkeeping and reporting requirements were selected within the
context of a small collection of process equipment and reflect the
burden on small businesses.  To the extent that larger businesses can
use economies of scale to reduce their burden, the overall burden will
be reduced.  Although the recordkeeping and reporting requirements are
the same for small and larger businesses, the Agency considers these
requirements the minimum needed to ensure compliance and, therefore,
cannot reduce them further for small businesses.

The information available on the Lead Acid Battery Manufacturing sector
indicates that small operations are being bought by larger facilities. 
It was assumed for this ICR that none of the existing sources is a small
entity.

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 -
NSPS for Lead Acid Battery Manufacturing (40 CFR part 60, subpart KK).

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 in Table 1. 
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 $
249,933 (rounded) (See Total Labor Hours from Table 1).  These hours are
based on Agency studies and background documents from the development of
the regulation, Agency knowledge and experience with the NSPS program,
the most recently approved ICR, consultation with industry, and any
comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses a Technical Labor Rate of $ 61.66 per hour.  This rate is
from the United States Department of Labor, Bureau of Labor Statistics,
September 2002, “Table 10. Private industry, by occupational and
industry group.”  The rates are from column 1, “Total
compensation.”  The rate has 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 type of industry costs associated with the information collection
activities in the subject standard are both labor costs, which are
addressed elsewhere in this ICR, and the costs associated with
continuous parameter (i.e., pressure drop) monitoring when a scrubbing
system is used as the control device.  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

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 Costs, 

 (B X C)	

(E)

Annual O&M Costs for One Respondent	

(F)

Number of Respondents with O&M	

(G)

Total O&M Costs,

(E X F)



Pressure Drop Monitors 	

$ 0	

0	

0	

$ 900	

13	

$ 12,000

(rounded)



There are no capital/startup costs for this regulation since there are
no new sources anticipated over the three-year period of this ICR.  This
is the total of column D in the above table.  The total operation and
maintenance (O&M) costs for this ICR are $ 12,000 (rounded).  This is
the total of column G.  

The total respondent costs have been calculated as the addition of the
capital/startup costs, and the annual operation and maintenance costs. 
The average annual cost for capital/startup and operation and
maintenance costs to industry over the three-year period of this ICR are
estimated to be $ 12,000.  

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information (i.e., notifications, performance test results
and periodic reports).  Publication and distribution of the information
are part of the compliance and enforcement program.  Examination of
records to be maintained by the respondents will occur as part of the
periodic inspection of sources, which is part of EPA’s overall
compliance and enforcement program.

The average annual Agency cost associated with 40 CFR part 60, subpart
KK, is $ 4,107 over the three-year period of this ICR.  The cost to the
Agency is based on the average hourly labor rate at a GS-12, Step 1,
times a 1.6 benefits multiplication factor to account for government
overhead expenses for a total of $ 39.49.  This rate is from the Office
of Personnel Management (OPM) “2003 General Schedule” which excludes
locality rates of pay.  Details upon which this estimate is based appear
in Table 2: Annual Federal Government Burden and Cost - NSPS for Lead
Acid Battery Manufacturing (40 CFR part 60, subpart KK), attached.

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Approximately 52 sources are currently subject to the regulation, and it
is estimated that no new sources per year will become subject to the
regulation in the three-year period of this ICR.

Respondent Universe and Number of Responses Per Year



Regulation Citation	

(A)

Average Number of New Respondents per Year	

(B)

Number of Reports for New Sources	

(C)

Number of Existing Respondents	

(D)

Number of Reports for Existing Sources	

(F)

Number of Respondents that keep records but do not submit reports	

(E)

Total Annual Responses =

(AxB)+(CxD)+F



NSPS, subpart KK	

0 1	

4	

13	

2	

39	

65



The number of total respondents is 52.  This number is the sum of column
C and column F of the Respondent Universe and Number of Responses Per
Year table.  This represents the number of existing sources plus the
number of new sources averaged over the three-year period (i.e., the
total of the number of new respondents over the three-year period
divided by three years).  

The number of Total Annual Responses is 65.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table above.  

The total annual labor costs are $ 249,933 (rounded).  Details upon
which this estimate is based appear in Table 1: Annual Respondent Burden
and Cost - NSPS for Lead Acid Battery Manufacturing (40 CFR part 60,
subpart KK).

 

Note that the total annual capital and O&M costs to the regulated entity
are $ 11,700.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached below.  The annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 62 (rounded) hours per response.

6(f)  Reasons for Change in Burden

There is no change in burden from the most recently approved ICR.  This
ICR renewal was approved under the “renew without change” option and
reflects no increase in the number of new or modified sources.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 62 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 and review the collection of information; and transmit, or
otherwise disclose the information.  An agency may not conduct, or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 
The OMB control numbers for EPA’s regulations are listed in 40 CFR
part 9 and 48 CFR chapter 15.

	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
EPA-HQ-OECA-2006-0415. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information; submit, or view public
comments; access the index listing of the contents of the 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 in this document.  The documents also
are available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., 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 Docket is (202)
566-1514.  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 EPA-HQ-OECA-2006-0415 and OMB Control
Number 2060-0081 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.



	(A)	(B)	(C=AxB)	(D)	(E=CxD)	(F)





Occurrence/	Hours/







Hours/	respondent/	respondent/	Respondents/	Hours/	Cost/

Burden Type

occurrence	year	year	yeara	year	yearb

 	 	 	 	 	 	 	 	 

1. APPLICATIONS

Not applicable















	2. SURVEYS AND STUDIES	Not applicable















	3. REPORTING REQUIREMENTS 







A. Read Instructions

Included in 3B





	B. Required Activities 







New Sources







	Initial performance test	24	1	24	0	0	0.00

	Reference Method 9 c







	Reference Method 12 d







	Other method approved by







	Administrator e







Repeat of performance test f	24	1	24	0	0	0.00

New and Existing sources 







 Monitoring of emissions 	Included in 4E







and operations g	Included in 4E





	C. Create Information	Included in 3B





	D. Gather Existing Information	Included in 3E 





	E. Write Report 







	New Sources







	Notification of construction/	2	1	2	0	0	0.00

	reconstruction/modification







Notification of initial startup	2	1	2	0	0	0.00

Notification of CMS demonstration	2	1	2	0	0	0.00

Notification of initial 	2	1	2	0	0	0.00

	performance test







Report of performance test results	Included in 3B





	New and Existing sources







Semi-annual Reports h 	16	2	32	13	416	$25,650.56 

Process Change

2	1	2	0	0	$0.00 

F. Subtotal





416	$25,650.56 











4. RECORDKEEPING REQUIREMENTS 







 A. Read Instructions	Included in 3A





	 B. Plan Activities

Included in 4E





	 C. Implement Activities	Included in 4E





	 D. Develop Record System	Not applicable 





	 E. Time to Enter Information 







Records of monitoring of emissions







and operations g 	0.75	365	273.8	13	3,559.40	$219,472.60 

Records of startups, shutdowns,







malfunctions, etc.	1.5	1	1.5	52	78	$4,809.48 

 F. Train Personnel	Not applicable 





	 G. Audits

Not applicable 

 



	 H. Subtotal





3,637.40	$224,282.08 











 









TOTAL ANNUAL BURDEN (Rounded)



	4,053	$249,933 











ASSUMPTIONS

















	a  We have assumed that there are approximately 52 sources currently
subject to NSPS, subpart KK. We have assumed that there will be no new
sources

over the period of this ICR. Therefore, the average number of
respondents per year is estimated to be 52. 



	b  We have assumed a Technical Labor Rate of $61.66 per hour which is
based on the United States Department of Labor, Bureau of Labor
Statistics, 

September 2002, “Table 10. Private industry, by occupational and
industry group.” The rate is from column 1, “Total compensation.”
The rate has been 

increased by 110% to account for the benefit packages available to those
employed by private industry.



	c  All sources are required to use Method 9 for opacity observations,
except for lead oxide manufacturing facilities. 



d  All respondents would have to perform Method 12 to calculate the lead
concentration and the volumetric flow rate of the effluent gases. It
requires at 

least three runs of 60 minutes and 0.85 dscm. 







f  We have assumed that 20 percent of initial performance tests must be
repeated due to failure. 



	g  Monitoring of emissions and operations requirements includes
pressure drop measurements across the scrubbing system at least every 15
minutes, if 

applicable. We have assumed that 25 percent of the sources (i.e., 13
sources) have scrubbing systems. 



	h  Semi-annual reports are required by this rule for those sources that
have to install continuous monitoring systems (e.g., pressure drop
monitors 

	across the scrubbing systems).



















 			

  It is estimated that 25 percent of the 52 existing sources (i.e., 13
sources) have scrubber systems and are, therefore, required to install
and maintain a monitor to measure and record pressure drop across the
scrubbing system.

1  The information available on the sector indicates that facilities are
closing operations or are that small operations are being bought by
larger facilities.  We have assumed that there will be no significant
process changes triggering NSPS, subpart KK, applicability.

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