SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ)
(Renewal),                     EPA ICR Number 1850.05, OMB Control
Number 2060-0476

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Primary Copper Smelters were proposed on April 20, 1998, and June
26, 2000, respectively.  This standard applies to each new and existing
affected source found at a primary copper smelter.  New facilities
include those that commenced construction or reconstruction after the
date of the proposal.  This information is being collected to assure
compliance with 40 CFR part 63, subpart QQQ.  The effected sources are
copper concentrate dryer, smelting furnace, slag cleaning vessel, copper
converter department, and the entire group of fugitive emission sources.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  In addition, they 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
affected facilities subject to NESHAP.

Owners and operators of a primary copper smelter are subject to the
regulation only if it is a major source of hazardous air pollutant (HAP)
emitting or has the potential to emit any single HAP at the rate of 10
tons or more per year or any combination of HAP at a rate of 25 tons or
more per year.  In addition, respondents are required to submit an
annual performance test report for each control device, along with a
semiannual compliance report.  These notifications, records and reports
are essential in determining compliance and are required of all sources
subject to this subpart.

Respondents subject to the rule are required to prepare and maintain
on-site two site-specific operating plans: 1) a startup, shutdown,
malfunction plan, and 2) a fugitive dust control plan.  These plans do
not require approval by EPA but are required to be maintained at the
smelter site.  Respondents subject to the provisions of this part are
required to 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.  Each record is to be filed at the
site for at least two years after the date of each occurrence,
measurement, maintenance, report or record and off-site for the
remaining three years.  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.

Approximately three respondents are currently subject to the regulation,
and it is estimated that no additional new respondents will become
subject to the regulation in the next three years.  

There are approximately three primary copper smelter plants in the
United States which are owned and operated by the copper smelter
industry.  All three are owned and operated by privately- owned,
for-profit businesses.  The burden to the “Affected Public” is
listed in Table 1: Annual Industry Burden and Cost - NESHAP for Primary
Copper Smelters (Renewal), (40 CFR Part 63, Subpart QQQ) (attached.) 
The Federal government burden does not include work performed by Federal
employees.  The burden refers to work performed by contractors, and that
burden is found in Table 2: Average Annual EPA Burden - NESHAP for
Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal),
(attached.)

The Office of Management and Budget (OMB) approved the currently active
Information Collection Request (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, HAP emissions from primary copper
smelters 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 63, subpart QQQ.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  In addition, the collected
information is 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.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart QQQ.

3(a)  Non-duplication

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 10735) 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 the EPA Office of Compliance.
 OTIS is the EPA 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 3 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 previously been 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 (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
primary copper smelters.  The United States Standard Industrial
Classification (SIC) code for the respondents affected by the standard
is 3331 which correspond to the North American Industry Classification
System (NAICS) code 331411 for Primary Smelting and Refining of Copper.

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 the
National Emission Standards for Hazardous Air Pollutants for Primary
Copper Smelters (40 CFR Part 63, Subpart QQQ).

A source must make the following reports:

Notifications

Initial notification	63.1454(a) and 63.9(b)

Notification of performance test	63.1454(d), 63.7, and 63.9(e)

Notification of compliance status	63.1454(e) and 63.9(h)



Reports

Performance test reports	63.1454(a) and 63.10(d)

Semiannual summary reports	63.1454(b) and 63.10(e)



A source must keep the following records:

Recordkeeping 

Records of startup, shutdown, and malfunctions	63.1456(a)(2), 63.1454(c)
and 63.10(b)(2)

Records of air pollution control equipment maintenance, malfunctions,
and corrective actions	63.1456(c), 63.1454(c) and 63.10(b)(1)

Records of performance tests and other supporting documentation used to
demonstrate compliance with relevant standards under the rule
63.1456(a)(5), 63.1454(c) and 63.10(b)(2)

Records of monthly capture system visual inspection	63.1454(c) and
63.10(b)(2)

Records of converter capture system operating parameter monitoring
system performance, calibration, and maintenance	63.1454(c) and
63.10(b)(2)

Records of control device operating parameter monitoring system
performance, calibration, and maintenance	63.1454(c) and 63.10(b)(2)

Records of control device or converter capture system operating
parameter deviations	63.1454(c) and 63.10(b)(2)

Copy of site-specific air pollution equipment startup, shutdown, and
malfunction plan	63.1450(c) and 63.6(e)(3)

Copy of site-specific smelter fugitive dust control plan	63.1448(a)



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

Perform initial performance test, Reference Methods 1, 2F, 2G, 3, 3A,
3B, 4, 5, 5D, 17, 29 tests, 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.



	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 the EPA Office of Compliance.  OTIS is the
EPA 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 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 five 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
Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal),
(attached.)

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 8,837
(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 

	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 Labor, Bureau of
Labor Statistics, September 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 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
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the 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)

Monitoring control device 	$2,800	0	$0	$1,540	3	$4,620

Monitoring converter hood	$10,800	0	$0	$1,200	3	$3,600



	$0

	$8,220



The average annual cost for capital/startup, operation and maintenance
costs, and labor costs to industry over the next three years of the ICR
is estimated to be $575,068.  This latter total   includes $566,848 for
labor costs plus, as shown in the above table, $8,220 for operation and
maintenance (O&M) costs for photocopying and postage (column G) and zero
for capital/startup costs (column D).   

6(c)  Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is
estimated to be $2,185.

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

Managerial	$54.66   (GS-13, Step 5, $34.16 + 60%)

Technical	$40.56   (GS-12, Step 1, $25.35 + 60%)

Clerical	$21.95   (GS-6, Step 3, $13.72 + 60%)

These rates are from the Office of Personnel Management (OPM) “2004
General 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 Primary
Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal), (attached.)

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 3 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 3 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	3	0	0	3

2	0	3	0	0	3

3	0	3	0	0	3

Average	0	3	0	0	3

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 3.

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

Initial notification	3	1	N/A	3

Notification of performance test	3	5.5	N/A	16.5

Initial compliance determination	3	1	N/A	3

Performance test reports	3	5.5	N/A	16.5

Summary reports	3	2	N/A	6



	Total	45



The number of Total Annual Responses is 45.

The total annual labor costs are $566,848.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden and Cost -
NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ)
(Renewal), (attached.)

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 $566,848.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ). 
(Attached.)  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 196
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $8,220.

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 55 labor hours at a cost of $2,185.  See Table 2: Annual
Agency Burden and Cost: NESHAP for Primary Copper Smelters (40 CFR Part
63, Subpart QQQ) (Renewal), (attached.)

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 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.  It should be noted that
the previous ICR rounded the burden cost down to the nearest one
thousand.  In this ICR, the exact cost figure is reported which results
in an apparent increase in the cost when, in fact, no increase has
occurred.  Also the total labor burden cost in Table 1 was changed due
to a mathematical error.  The previous cost was incorrectly reported as
$556,848 whereas the correct figure is $566,848.

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 196 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-2007-0063.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
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) 566-1927. 
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-2007-0063 and OMB Control Number
2060-0476 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 Primary
Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)

Burden item	(A)

Person hours per occurrence	(B)

No. of occurrences per respondent per year	(C)

Person hours per respondent per year

(C=AxB)	(D)

Respondents per year  a	(E)

Technical person- hours per year

(E=CxD)	(F)

Management person hours per year

(Ex0.05)	(G)

Clerical person hours per year

(Ex0.1)	(H)

Total Cost 

Per year b



1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting requirements









     A.  Read instructions 	16	1	16	0	0	0	0	$0

     B.  Required activities









        Conduct control device performance test c	120	4.5	540	3	1,620	81
162	$118,867.50

        Conduct converter building performance test d	240	1	240	3	720	36
72	$52,830.00

     C.  Create information	See 3B and 4E







	     D.  Gather existing information	See 3B and 4E







	     E.  Write Report









         Initial notification	8	1	8	3	24	1.2	2.4	$1,761.00

         Notification of performance test	2	5.5	11	3	33	1.65	3.3
$2,421.38

         Initial compliance determination	40	1	40	3	120	6	12	$8,805.00

         Performance test reports e	80	5.5	440	3	1,320	66	132	$96,855.00

         Summary report f	40	2	80	3	240	12	24	$17,590.00

Subtotal for Reporting Requirements



	4,688.55











	4.  Recordkeeping requirements









     A.  Read instructions 	40	1	40	0	0	0	0	$0

     B.  Plan activities	100	1	100	0	0	0	0	$0

     C.  Implement Activities 









      i.  Prepare startup, shutdown, malfunction plan 	80	1	80	0	0	0	0
$0

     ii.  Copper concentrate dryer









              Monitor control device parameters g	0.5	365	182.5	3	547.5
0	0	$35,368.50

    iii.  Smelting vessel









             Inspect tapping hood system h	4	12	48	3	144	0	0	$9,302.40

             Monitor control device parameters g	0.5	365	182.5	3	547.5	0
0	$35,368.50

    iv.  Slag cleaning vessel









             Inspect tapping hood system i	4	12	48	1	48	0	0	$3,100.80

             Monitor control device parameters i, g	0.5	365	182.5	1
182.5	0	0	$11,789.50

     v.  Batch copper converters









             Inspect converter hood system	4	12	48	3	144	0	0	$9,302.40

             Monitor hood system ventilation 

             Parameters g	0.5	365	182.5	3	547.5	0	0	$35,368.50

             Monitor control device parameters g	0.5	365	182.5	3	547.5	0
0	$35,368.50

    vi.  Prepare fugitive dust control plan	100	1	100	0	0	0	0	$0

    D.  Develop record system	100	1	100	0	0	0	0	$0

    E.  Time to enter information j	1	365	365	3	1,095	0	0	$70,737.00

    F.  Time to train personnel k	100	1	100	3	300	15	30	$22,012.50

Subtotal for Recordkeeping Requirements



	4,148.5











	Subtotals Labor Burden and Cost  



	8,180.5	218.85	437.7	$566,848.48

TOTAL LABOR BURDEN AND COST (rounded)





8,837.05

8,837 (rounded)

$566,848



Assumptions:

a  We have assumed that there are approximately three sources that are
subject to the standard, with no new additional sources expected over
the next three years.

b  This ICR uses the following labor rates:  $95.32 per hour for
Executive, Administrative, and Managerial labor; $64.60 per hour for
Technical labor, and $40.09

per hour for Clerical labor.  These rates are from the United States
Department of Labor, 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 percent to account for the benefit packages available
to those employed by private industry.

c  We have assumed that each of the three respondents will 120 hours to
conduct control device performance test.

d  We have assumed that each of the three respondents will take 240
hours to conduct converter building performance test.

e  We have assumed that each of the respondents will take eighty hours
to complete a performance test report.

f  We have assumed that it will take each respondent forty hours to
write summary report twice a year.

g  Recordkeeping requirements are required daily on all monitor control
device parameters.

h  We have assumed that inspections on all tapping hood systems are done
on a monthly basis.

i  We have assumed that one of the three existing sources will be
equipped with a slag cleaning vessel.

j  Each respondent is required to record information on a daily basis.

k  We have assumed that it will take each of the respondent 100 hours to
train personnel once a year.

Table 2:  Average Annual EPA Burden - NESHAP for Primary Copper Smelters
(40 CFR Part 63, Subpart QQQ) (Renewal)

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

Activity









Review reports









   a.  Report of no deviations 	4	1	4	0	0	0	0	$0

   b.  Report of deviations 	4	1	4	0	0	0	0	$0

   c.  Report of SSM	8	1	8	0	0	0	0	$0

   d.  Reports of equipment leaks 	8	1	8	0	0	0	0	$0

   e.  Report on wastewater c 	8	2	16	3	48	2.4	4.8	$2,185.42

Subtotals Labor Burden and cost



	48	2.4	4.8	$2,185.42

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	55.2

55 (rounded)	$2,185



 	Assumptions:

    a  We have assumed that there are approximately three sources that
are subject to the standard, with no new additional sources expected
over the next three years.

b  This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $54.66 for Managerial (GS-13, Step 5, $34.16 x 1.6), $40.56
for Technical (GS-12, Step 1, $25.35 x 1.6) and $21.95 Clerical (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.

c  It is assumed that all of the three respondents are required to
review reports on wastewater on a semiannual basis.

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