SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Beryllium 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Beryllium (40 CFR part 61, subpart C) (Renewal)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Beryllium was proposed on December 7, 1971 (36 FR 23939) and
promulgated on April 6, 1973 

(38 FR 8826).  This standard applies to all extraction plants, ceramic
plants, foundries, incinerators, and propellant plants which process
beryllium ore, beryllium, beryllium oxide, beryllium alloys, or
beryllium-containing waste.  The standard also applies to machine shops
which process beryllium, beryllium oxides, or any alloy when such alloy
contains more than 5 percent beryllium by weight.  All sources known to
have caused, or to have the potential to cause, dangerous levels of
beryllium in the ambient air are covered by the Beryllium NESHAP.  This
information is being collected to assure compliance with 40 CFR part 61,
subpart C.

In general, all NESHAP standards require owners or operators of the
affected facilities to submit one-time-only notifications including:
notification of any physical or operational change to an existing
facility which may increase the regulated pollutant emission rate,
notification of the initial performance test, including information
necessary to determine the conditions of the performance test, and
performance test measurements and results.  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.

Specifically, most facilities subject to 40 CFR part 61, subpart C will
meet the standard by means of a one-time-only initial stack test. 
However, those existing facilities that have elected to comply with an
alternative ambient air quality limit are required to operate a
continuous monitor in the vicinity of the affected facility.  The
monitoring requirements for these facilities provide information on
ambient air quality and ensure that locally, the airborne beryllium
concentration does not exceed 0.01 micrograms/m3.  For those complying
by ambient monitoring, a monthly report of all measured concentrations
will be submitted to the Administrator.

Any owner or operator subject to the provisions of this part will
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.

There are approximately 236 existing sources subject to this rule.  Of
the total number of existing sources, we have assumed that approximately
10 sources have elected to comply with this rule by monitoring ambient
air beryllium concentrations and the remaining 226 sources have elected
to comply with the rule by conducting a one-time only stack test to
determine beryllium emission levels.  We also assumed that 10 percent of
the 226 sources (or 23 respondents) complying with the emission limit
standard will engage in an operational change at their facilities that
could potentially increase beryllium emissions, and would be required to
repeat the stack test to determine the beryllium emission limits, and
consequently will have recordkeeping and reporting requirements
associated with this activity.

Over the next three years, an average of 33 facilities per year will be
subject to the standard, and it is estimated that no additional sources
per year will become subject to the standard.  

There are approximately 33 beryllium facilities in the United States,
which are owned and operated by the beryllium industry.  None of the 33
facilities in the United States are owned by state, local, tribal or the
Federal government.  They are owned and operated by privately owned
for-profit businesses.  You can find the burden to the “Affected
Public” listed below in Table 1: Annual Industry Burden and Cost -
NESHAP for Beryllium (40 CFR part 61, subpart C).  The Federal
government burden does not include work performed by Federal employees. 
The burden refers only to work performed by contractors, which could be
found listed below in Table 2: Average Annual EPA Burden - NESHAP for
Beryllium (40 CFR part 61, subpart C).

The Office of Management and Budget (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 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 HAP.  These standards are
applicable to new or existing sources of HAP and shall require the
maximum degree of emission reduction.  In addition, section 114(a)
states that the Administrator may require any owner or operator subject
to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, beryllium emissions from extraction
plants, ceramic plants, foundries, incinerators, propellant plants and
machine shops which process beryllium ore, beryllium, beryllium oxide,
beryllium alloys, or beryllium-containing waste, cause or contribute to
air pollution that may reasonably be anticipated to endanger public
health or welfare.  Therefore, the NESHAP was promulgated for this
source category at 40 CFR part 61, subpart C.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where 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 tests, 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 ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
61, subpart C.

3(a)  Nonduplication

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

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (72 FR 10736) on March 9, 2007. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by EPA's Office of Compliance. 
OTIS is EPA’s database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts. 
Approximately 33 respondents will be subject to the standard over the
three year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

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
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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 (CBI) (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
beryllium.  The United States Standard Industrial Classification (SIC)
codes which correspond to the North American Industry Classification
System (NAICS) codes are found in the following table:

40 CFR part 61, subpart C	SIC Codes	NAICS Codes

Industrial Inorganic Chemicals, not elsewhere Classified	2819	325188

Primary Smelting and Refining of Nonferrous Metals, except Copper and
Aluminum	3339	331419

Nonferrous Foundries, except Aluminum and Copper	3369	331528

Industrial and Commercial Machinery and Equipment, not elsewhere
Classified	3599	332710

Refuse Systems	4953	562211 

Refuse Systems	4953	562920



4(b)  Information Requested

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

(i)  Data Items

In this ICR, all the data recorded or reported is required by National
Emission Standards for Hazardous Air Pollutants for Beryllium (40 CFR
part 61, subpart C).

A source must make the following reports:

Notifications

Notification and application of construction or modification	61.07

Notification of actual startup	61.09(a)(2)

Notification of initial performance test	61.13(f) and 61.33(d)

Notification of emission tests	61.13(c) and 61.33(b)

Notification requesting approval to meet an ambient concentration limit
on beryllium in the vicinity of the stationary source (alternative
standard)	61.32(b)

Source status report for facilities complying by ambient monitoring, a
monthly report of all measured beryllium concentrations shall be
submitted to the administrator	61.10(a) and 61.34(d)



A source must keep the following records:

Recordkeeping 

Startup, shutdown, malfunctions period where the continuous monitoring
system is inoperative due to maintenance and calibration, for changing
filters, or for replacement equipment needing major repairs.	61.34(b)

Emission tests results and other data needed to determine emissions.
61.13(g) and 61.34(c)

Records are required to be retained for 2 years	61.34(c)



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  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.

Respondent Activities

Read instructions.

For facilities that have elected to comply with an alternative ambient
air quality limit, install, calibrate, maintain, and operate a
continuous monitor in the vicinity of the affected facility to measure
beryllium concentrations.

For facilities complying by ambient monitoring, perform emission testing
to determine beryllium emissions to the atmosphere according to Method
104 or Method 103 (an alternative method needing approval) of appendix B
to part 61.

Write the notification 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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way e.g., continuous parameter monitoring
system.  Although personnel at the source still need to evaluate the
data, this type of monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.

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,
excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (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 operational.  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 OTIS which is
operated and maintained by EPA's Office of Compliance.  OTIS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses OTIS 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 two years.

5(c)  Small Entity Flexibility

The majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these to be the minimum
requirements needed to ensure compliance and, therefore, cannot reduce
them further for small entities.  To the extent that larger businesses
can use economies of scale to reduce their burden, the overall burden
will be reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Beryllium (40 CFR part 61, subpart C).

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.  Wherever 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 2,627
(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 NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

Managerial 	$93.09     ($44.33 + 110%)

Technical	$64.13     ($30.54 + 110%)

Clerical	$39.65     ($18.88 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, June 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 percent
to account for the benefit packages available to those employed by
private industry.

	

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The only cost to the regulated industry resulting from information
collection activities required by the subject standard is labor costs. 
There are no capital/startup costs required for the purchase or the
installation of equipment because respondents comply by employing
pollution prevention measures.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitor 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 Cost, (B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Ambient Monitor	0	0	$0	$3,500	10	$35,000



The total capital/startup costs for this ICR are $0.  This is the total
of column D in the above table.

The total operation and maintenance (O&M) costs consists of
photocopying, and postage are $35,000.  This is the total of column G.

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 $35,000.

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 $12,856.  

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

Managerial	$54.02   (GS-13, Step 5, $33.76 + 60%)

Technical	$40.08   (GS-12, Step 1, $25.05 + 60%)

Clerical	$21.70   (GS-6, Step 3, $13.56 + 60%)

These rates are from the Office of Personnel Management (OPM)
2004General Schedule which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear in Table 2: Average Annual EPA Burden, NESHAP for Beryllium
(40 CFR part 61, Subpart C), below.

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

	

	Based on our research for this ICR, on average over the next three
years, approximately 33 existing respondents will be subject to the
standard.  It is estimated that no additional sources per year will
become subject.  The overall average number of respondents, as shown in
the table below is 33 per year. 

	The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

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	33	0	0	33

2	0	33	0	0	33

3	0	33	0	0	33

Average	0	33	0	0	33

1 New respondent include sources with constructed, reconstructed and
modified affected facilities.  In this standard existing respondents
submit initial notifications.

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 33.

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 stack test	23	1	n/a	23

Emission level/operational changes	23	1	n/a	23

Monthly ambient concentrations	10	12	n/a	120



	Total (rounded)	166

The number of Total Annual Responses is 166.

The total annual labor costs are $166,160.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NESHAP for Beryllium (40 CFR part 61, subpart C), below.

6(e)  Bottom Line Burden Hours Burden Hours and Cost 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 annual labor costs are $166,160.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NESHAP for Beryllium (40 CFR part 61, subpart C), below.  Furthermore,
the annual public reporting and recordkeeping burden for this collection
of information is estimated to average 16 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $35,000.  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 329 labor hours at a cost of $12,856.  See Table 2.
Annual Agency Burden and Cost: NESHAP for Beryllium (40 CFR part 61,
subpart C), below.

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR compared to
the previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for the industry is very low, negative or non-existent, so there is
no significant change in the overall burden.

Since there are no changes in the regulatory requirements and there is
no significant industry growth, the labor hours and cost figures in the
previous ICR are used in this ICR and there is no change in burden to
industry.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 16 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 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
EPA-HQ-OECA-2007-0048.  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 content of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search” than key in the
docket ID number identified in this document.  The documents are also
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 Avenue, N.W., 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)
566-1752.  Also, you can send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
N.W., Washington, DC 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2007-0048 and OMB Control
Number 2060-0092 in any correspondence.

Part B of the Supporting Statement

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

Table 1:  Annual Respondent Burden and Cost – NESHAP for Beryllium
(40 CFR part 61, subpart C) 

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)

Respondentsper year  a	(E)

Technicalperson- 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









  a.  Application for approval of construction/

       Modification	4	1	4	0	0	0	0	$0

  b.  Request for ambient air monitoring alternative	4	1	4	0	0	0	0	$0

2.  Survey and Studies	N/A







	3.  Reporting requirements









     A.  Read instructions 	1	1	1	0	0	0	0	$0

     B.  Required activities









           Initial emissions test	20	1	20	0	0	0	0	$0

           Determine emission level from stack test c	8	1	8	23	184	9.2
18.4	$13,385.91

           Monitoring of ambient beryllium

           concentrations	See 3E







	     C.  Create information	See 3E







	     D.  Gather existing information	See 3E







	     E.  Write Report









           Notification of actual startup	2	1	2	0	0	0	0	$0

           Notification of  stack test d	2	1	2	23	46	2.3	4.6	$3,346.48

           Report of emission level determination/

           operational change                          	8	1	8	23	184	9.2
18.4	$13,385.91

           Plan for locating monitors	16	1	16	0	0	0	0	$0

           Report monthly ambient concentrations e	8	12	96	10	960	48	96
$69,839.52

4.  Recordkeeping requirements









     A.  Read instructions 	See 3A







	     B.  Plan activities	See 4C







	     C.  Implement Activities 	See 3B







	    D.  Develop record system	N/A







	    E.  Time to enter information









          Records of operating parameters and

          emissions f	0.25	365	91	10	910	45.5	91	$66,202.04

    F.  Time to train personnel	N/A







	   G.  Time for audits	N/A







	Subtotals Labor Burden and cost  



	2,284	114.2	228.4	$166,159.86

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	2,627	$166,160



Assumptions:

a  We have assumed that the average number of major sources that will be
subject to the rule will be 33 existing sources.  There are
approximately 236 existing sources subject to this rule, but of the
total number of existing sources, we have assumed that approximately 10
sources will elect to comply with this rule by monitoring ambient air
beryllium concentrations and the remaining 226 sources have elected to
comply with the rule by conducting a one-time only stack test.  We have
also assumed that 10 percent of the 226 sources (23 respondents) will
engage in an operational change that could potentially increase
beryllium emissions, thus, requiring sources to repeat the stack test,
and consequently will have recordkeeping and reporting requirements. 
Therefore, there are 33 respondents for the purpose of determining the
recordkeeping and reporting burdens associated with this rule. 

b  This ICR uses the following labor rates: $93.09 per hour for
Executive, Administrative, and Managerial labor; $64.13 per hour for
Technical labor, and $39.65 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, June 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 percent to account for the benefit
packages available to those employed by private industry.

c  We have assumed that each respondent will take eight hours to
determine the emission level from the stack test.

d  We have assumed that each respondent will take two hours to write
notification report of stack test.

e  We have assumed that each respondent will take eight hours once per
month to write monthly ambient concentrations report.

f  We have assumed that each of the ten respondents will take fifteen
minutes each day to enter records of operating parameters and emissions
information.

Table 2:  Average Annual EPA Burden - NESHAP for Beryllium (40 CFR part
61, subpart C) 

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

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

Initial performance test









      New plant	20	1	20	0	0	0	0	$0

Report review









      Notification of construction	2	1	2	0	0	0	0	$0

      Request to use ambient air concentration

      alternative	2	1	2	0	0	0	0	$0

      Notification of actual startup	0.5	1	0.5	0	0	0	0	$0

      Notification of initial stack test	0.5	1	0.5	0	0	0	0	$0

      Report of initial analysis	2	1	2	0	0	0	0	$0

 Existing plant









      Notification of stack test









           Report of emission level determination/

           operational change c	2	1	2	23	46	2.3	4.6	$2,067.75

           Report of monthly ambient 

           concentrations d	2	12	24	10	240	12	24	$10,788.24

Subtotals Labor Burden and cost



	286	14.3	28.6	$12,855.99

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	329	$12,856



Assumptions:

 a  We have assumed that the average number of major sources that will
be subject to the rule will be the 33 existing sources.  There are
approximately 236 existing sources subject to this rule, but of the
total number of existing sources, we have assumed that approximately 10
sources will elect to comply with this rule by monitoring ambient air
beryllium concentrations and the remaining 226 sources have elected to
comply with the rule by conducting a one-time only stack test.  We have
also assumed that 10 percent of the 226 sources (23 respondents) will
engage in an operational change that could potentially increase
beryllium emissions, thus, requiring sources to repeat the stack test,
and consequently will have recordkeeping and reporting requirements. 
Therefore, there are 33 respondents for the purpose of determining the
recordkeeping and reporting burdens associated with this rule. 

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 $54.02 (GS-13, Step 5, $33.76 x 1.6), Technical rate of $40.08
(GS-12, Step 1, $25.05 x 1.6), and Clerical rate of $21.70 (GS-6, Step
3, $13.56 x 1.6).  These rates are from the Office of Personnel
Management (OPM) (2003 General Schedule( which excludes locality rates
of pay.

   c  We have assumed that each respondent will take two hours to review
the emission level determination/operational change report.

   d  We have assumed that each respondents will take two hours once per
month to review the monthly ambient concentrations report.

   

 PAGE   

 PAGE   12 

 PAGE   

