	SF-83 SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP For Beryllium Rocket Motor Firing (40 CFR part 61, subpart D)
(Renewal) 

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Beryllium Rocket Motor Firing (40 CFR part 61, subpart D)
(Renewal)

1(b) Short Characterization/Abstract

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

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

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

In order to ensure compliance with the standards, adequate record
keeping and reporting is necessary.  This information enables the Agency
to: (1) identify the sources subject to the standard; (2) ensure initial
compliance with emission limits; and (3) verify continuous compliance
with the standard.  Specifically, the rule requires subject test sites
to test ambient air for beryllium during and after firing of a rocket
motor.  Samples are analyzed within 30 days and results are reported to
the EPA Region by registered letter by the business day following the
determination.  The rule also requires stack sampling of beryllium
combustion products during and after firing of rocket motor, and
analysis and reporting within 30 days.  The results are reported to EPA
by the day following the determination and calculation. 

 There is one test facility and three to four stored beryllium fueled
rockets subject to NESHAP 40 CFR part 61, subpart D.  It is estimated
that there will be no new sources becoming subject to this regulation in
the next three years.  It is assumed that there is one affected facility
per plant.

Under OMB(s terms of clearance for ICR 1125.02, it stated that prior to
submitting the collection to OMB for renewal, EPA should carefully
examine whether the monitoring required by the collection imposes any
financial burden on the respondent(s) that should be included in the
estimate of operations and maintenance costs.  For this rule the
respondent does not incur any capital costs since there are no new
facilities expected or O&M costs since there is no requirement for
continuous emissions monitoring.

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

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended,
to establish standards of performance for new stationary sources and
area sources of hazardous air pollutants.  These standards are
applicable to new or existing sources of hazardous air pollutants and
shall require the maximum degree of emission reduction.  In addition,
Section 114(a) states that the Administrator may require any owner or
operator subject to any requirement of this Act to:

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

In the Administrator's judgment, beryllium emissions from beryllium
rocket motor test sites can cause or contribute to air pollution that
may reasonably be anticipated to endanger public health or welfare. 
Therefore, NESHAP were promulgated for this source category at 40 CFR
Part 61 Subpart D . 

2(b) Practical Utility/Users of the Data

The control of emissions of beryllium from beryllium rocket motor test
sites requires not only the installation of properly designed equipment,
but also the operation and control of that equipment.  Emissions of
beryllium from the beryllium rocket motor test sites are the result of
controlled firing of rocket motors and disposal of propellant.  Since
beryllium is a hazardous air pollutant, these standards rely on the
capture and reduction of beryllium emissions.  The required
notifications are used to inform the Agency when a rocket firing is
planned.  The reviewing authority may then inspect the source to check
if the rocket motor and equipment are properly operated, and the
standard is being met.  Test reports are needed as these are the
Agency's record of the source is in compliance with the emission
standard.  The information generated by the monitoring, record keeping
and reporting requirements described in this ICR is used by the Agency
to ensure that facilities affected by the NESHAP continue to operate in
accordance with the standards.  Adequate monitoring, recordkeeping, and
reporting are necessary to ensure compliance with the applicable
regulations, as required by the Clean Air Act.  The information
collected from record keeping and reporting requirements is also used
for inspections, and is of sufficient quality to be used as evidence in
court.

 

3. Non duplication, Consultations, and Other Collection Criteria

The requested record keeping and reporting are required under 40 CFR
part 61 subpart D. 

3(a) Non duplication

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

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

An  announcement of a public comment period for the planned submission
of this ICR to OMB was published in the Federal Register (69 FR 29718)
on May 25, 2004.  No comments were received.

3(c) Consultations

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

ATK Elkton

55 Thiokol Road

Elkton, MD 21921

3(d) Effects of Less Frequent Collection

 Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the required standards.
 Requirements for information gathering and record keeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the standard for the
rocket testing could not be monitored.

3(e) General Guidelines

None of these reporting or record keeping requirements violate any of
the regulations established by OMB at 5 CFR 1320.5.

3(f) Confidentiality

Any information submitted to the agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions  

 

None of the reporting or record keeping requirements contain sensitive
questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

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

4(b) Information Requested

(i)	Data items

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

A source must make the following reports:

Notification Reports



Notification and application of construction or modification	

61.06 and 61.07



Notification of anticipated date of initial startup	

61.09(a)(1)



Notification of actual startup	

61.09(a)(2)



Notification of physical or operational change which may increase the
emission rate	

61.15



Notification of performance tests	

61.13(f) and 61.14(c)



Notification of anticipated firing 	

61.43 or 61.44



Reports



Emission source reporting	

61.10(a)



Emission test report and ambient air quality report	

61.43 and 61.44



Recordkeeping



Maintain records of monitoring data, monitoring system calibration
checks, and the occurrence and duration of periods where the monitoring
system is malfunctioning or inoperative.  Records shall be retained for
at least 2 years	

61.14(f)



Record air sampling results.  Records are required to be retained for
two years.	

61.43



Record emission test results	

61.44



Make records available to Agency	

61.43 and 61.44



Electronic Reporting

             Reports and notifications may be submitted through E-mail
as long as the E-mail or fax machine is followed up with hard copy
letter with a signature.  This is to ensure that there is a back up
system to notify the Agency of the reports and notifications.  In
addition, some regulatory entities (government agencies and respondents)
are setting up electronic reporting systems to allow sources to report
electronically which is reducing the reporting burden.  The one facility
that is subject to this rule does not report electronically.

(ii) Respondent Activities

Respondent Activities



Read instructions



During test firing, ambient air concentrations shall be measured during
and after test firing or propellant disposal, in such a manner that
emissions can be compared with the standard.



During test firing, continuously sample emissions from the test tank as
per Method 104 (or alternately, Method 103)



Write the notifications and reports listed above.



Enter information required to be recorded above.



Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.



Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.



Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.



Adjust the existing ways to comply with any previously applicable
instructions and requirements.



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



Transmit, or otherwise disclose the information.



5. The Information Collected ( Agency Activities, Collection
Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities



Observe air sampling tests and emission tests.



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



Audit facility records.



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



5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might
inspect the source to check if the pollution control practices are in
place and properly implemented.  Data obtained during periodic visits by
Agency personnel from records maintained by the respondents are
tabulated and published for internal Agency use in compliance and
enforcement programs.  The  reports are used for problem identification,
as a check on source operation and maintenance, and for compliance
determinations.

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  The AFS is EPA(s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses AFS for tracking air pollution compliance and
enforcement by local and State regulatory agencies, EPA regional offices
and headquarters.  EPA and its delegated authorities can edit, store,
retrieve and analyze the data via.  The records required by this NESHAP
must be retained by the owner or operator for two years.

5(c) Small Entity Flexibility

There are no small businesses affected by this standard.

5(d) Collection Schedule

The specific frequency for each information collection activity within
this request is shown on Table 1: Annual Respondent Burden and Cost,
NESHAP for Beryllium Rocket Motor Fuel Firing (40 CFR part 61, subpart
D). 

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for each of the
record keeping and reporting requirements applicable to the industry for
the subparts included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.  The Agency may not conduct
or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from
these record keeping  and reporting requirements is estimated to be 8.43
hours.  These hours are based on Agency studies and background documents
from the development of the regulation, Agency knowledge and experience
with the NESHAP program, the previously approved ICR and any comments
received. 

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs 

This ICR uses the following labor rates:

Managerial 	$95.32 ($45.39 + 110%)

Technical 	$64.60 ($30.76 + 110%)

Clerical 	$40.09 ($19.09 + 110%)

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

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

The only costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
There are no capital/startup or operation and maintenance costs. 

(iii) Capital/Start-up vs. Operation and Maintenance (O&M) Costs

The only type of industry costs associated with the information
collection activity in the regulations are labor costs.  There are no
capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

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

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

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

Managerial	$54.66	(GS-13, Step 5, $34.16 x 1.6)

Technical		$40.56	(GS-12, Step 1, $25.35 x 1.6)

Clerical		$21.95	(GS-6,   Step 3, $13.72 x 1.6)

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

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

Based on our research for this ICR, one existing source is currently
subject to the standard.  This one facility has 3 to 4 test rockets.  We
expect one firing over a three year period.   

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

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

Number of Existing  Respondents that keep records but do not submit
reports	

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

0	

1	

0	

0	

1



2	

0	

1	

0	

0	

1



3	

0	

1	

0	

0	

1



Average	

0	

1	

0	

0	

1

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

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

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

Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents  	

(C)

Number of Responses	

(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual  Responses 

E=(BxC)+D



Notification of construction or modification	

0	

0	

0	

0



Notification of anticipated initial startup	

0	

0	

0	

0



Notification of actual startup	

0	

0	

0	

0



Notification of physical or operational change	

1	

0	

0	

0



Notification of performance test	

0	

0	

0	

0



Notification of anticipated firing	

1	

1	

0	

1



	

	

	

Total	

1



The number of Total Annual Responses is 1.  This number is shown on the
OMB 83-I form in block 13(b), Total annual responses.

6(e) Bottom Line Burden Hours And Costs Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

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

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

(ii) Agency Tally

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

6(f) Reasons For Change In Burden

Burden hours are unchanged from the currently active ICR.  However, the
increase in industry burden cost from the most recently approved ICR is
due to more accurate hourly rate estimates obtained from the United
States Department of Commerce Bureau of Labor Statistics, March 2000,
Table 2: Employment Costs for Civilian Workers by Occupational and
Industry Group; Column 2, wages and salaries.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 8 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA(s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
OECA-2004-0006, which is available for public viewing at the Enforcement
and Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Avenue, NW, Washington,
DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center is (202) 566-1752.  An electronic version of the
public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket.  Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select (search,( then key in the
Docket ID Number identified above.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number OECA-2004-0006
and OMB Control Number 2060-0394 in any correspondence.

Part B of the Supporting Document

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

Table 1: Annual Respondent Burden and Cost, NESHAP for Beryllium Rocket
Motor Firing (40 CFR Part 61, Subpart D).

Activity	

Technical Hrs./ Occurrence

(A)	

Occurrence/ Respondent/ Yr.

(B)	

Hours/ Respondent/Yr.

(C)

[C = A x B]	

Number of Respondents

(D)	

Technical Hrs./ Yr.

(E)

[E = C x D]	

Management Hrs./ Yr.

(F)

[F = 0.05 x E]	

Clerical Hrs./ Yr.

(G)

[G = 0.1 x E]	

Total Labor Costs/ Yr. ($)

(H)1



1. Applications	

	

	

	

	

	

	

	





A. Application for approval of construction/modification	

12	

0	

0	

0	

0	

0	

0	

0



B. Source information report/application	

6	

0	

0	

0	

0	

0	

0	

0



C. Request for ambient air monitoring alternative	

18	

0	

0	

0	

0	

0	

0	

0



2. Survey and Studies	

	

	

	

	

	

	

	





3. Reporting Requirements	

	

	

	

	

	

	

	





A. Read Instructions	

3	

0.33	

1	

0	

0	

0	

0	

0



B. Required Activities	

	

	

	

	

	

	

	





Emission test	

6	

0.33	

2	

1	

2	

0.1	

0.2	

146.75



Calculation of emission estimates	

3	

0.33	

1	

1	

1	

0.05	

0.1	

73.38



Monitoring ambient beryllium concentrations	

3	

0.33	

1	

1	

1	

0.05	

0.1	

73.38



C. Create Information	

2	

0	

0	

1	

0	

0	

0	

0



D. Gather Existing Information	

3	

0.33	

1	

1	

1	

0.05	

0.1	

73.38



E. Write Report	

	

	

	

	

	

	

	





Notification of test	

1	

0.33	

0.33	

1	

0.33	

0.02	

0.03	

24.43



Report of test	

3	

0.33	

1	

1	

1	

0.05	

0.1	

73.38



Report of calculated emission levels	

3	

0	

0	

0	

0	

0	

0	

0



Plan for locating monitors	

1	

0	

0	

0	

0	

0	

0	

0



Report monthly ambient concentrations	

1	

0	

0	

1	

0	

0	

0	

0



4. RECORDKEEPING REQUIREMENTS	

	

	

	

	

	

	

	





A. Read Instructions	

	

	

	

	

	

	

	





B. Plan Activities	

	

	

	

	

	

	

	





C. Implement Activities	

	

	

	

	

	

	

	





D. Develop Record System	

	

	

	

	

	

	

	





E. Time to Enter Information	

3	

0.33	

1	

1	

1	

0.05	

0.1	

73.38



F. Train Personnel	

	

	

	

	

	

	

	





G. Audits	

	

	

	

	

	

	

	





TOTAL LABOR BURDEN AND COST (rounded)	

8.43	

$538.08

1 This cost is based on the sum of personnel hours multiplied by their
hourly rates [(Technical hours x $64.60 + (Management hours x $95.32) +
(Clerical hours x $40.09)].



Table 2: Annual Agency Burden and Cost, NESHAP for Beryllium Rocket
Motor Firing (40 CFR Part 61, Subpart D)

Activity	

Technical Hrs./ Occurrence

(A)	

Occurrence/ Respondent/ Yr.

(B)	

Hours/ Respondent/Yr.

(C)

[C = A x B]	

Number of Respondents

(D)	

Technical Hrs./ Yr.

(E)

[E = C x D]	

Management Hrs./ Yr.

(F)

[F = 0.05 x E]	

Clerical Hrs./ Yr.

(G)

[G = 0.1 x E]	

Total Labor Costs/ Yr. ($)

(H)1



1.Performance Test	

	

	

	

	

	

	

	





A. Rocket Motor Firing	

6	

0.33	

2	

1	

2	

0.1	

0.2	

90.98



2. Report Review	

	

	

	

	

	

	

	





A. Test Firing Report Review	

4	

0.33	

1.32	

1	

1.32	

0.07	

0.13	

60.22



B. Application of Construction	

0	

0.33	

0	

1	

0	

0	

0	

0



C. Notification of Anticipated Firing of Rocket Motor	

3	

0.33	

1	

1	

1	

0.05	

0.1	

45.49



D. Review Report of Test Results	

1	

0.33	

0.33	

1	

0.33	

0.02	

0.03	

15.13



TOTAL LABOR BURDEN AND COST (rounded)	

5.35	

$211.82

1 This cost is based on the sum of personnel hours multiplied by their
hourly rates [(Technical hours x $40.56) + (Management hours x $54.66) +
(Clerical hours x $21.95)].

 PAGE  14 

