SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

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

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Primary Lead Smelters were proposed on April 17, 1998 (63 FR 19200),
and promulgated on June 4, 1999 (64 FR 30204).  On February 12, 1999,
the Agency publicized a supplemental rulemaking for ferroalloys, mineral
wool, primary copper, primary lead and wool fiberglass which enhanced
the requirements for bag leak detection systems in 40 CFR 63.1625 and 40
CFR 63.1655 by including an enforceable operating limit in this rule. 
These standards apply to emissions sources from primary lead smelters
including sinter machine, blast furnace, dross furnace, process
fugitive, and fugitive dust sources.  This information is being
collected to assure compliance with 40 CFR part 63, subpart TTT.

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

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

In the development of this Information Collection Request (ICR), we
reviewed the Office of Management and Budget (OMB) (Terms of Clearance(
(TOC) section on the active ICR.  There were no comments in the TOC
section.

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

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

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

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

In the Administrator's judgment, metal hazardous air pollutants from
process sources, process fugitive, and fugitive dust sources including
sinter machines and blast and dross furnaces, and organic HAP emissions
from blast furnaces cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP standards were promulgated for this source
category at 40 CFR part 63, subpart TTT.

2(b)  Practical Utility/Users of the Data

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

The notifications required in the standard are used to inform the Agency
or delegated authority when a source becomes subject to the requirements
of the regulations.  The reviewing authority may then inspect the source
to check if the pollution control devices are properly installed and
operated, leaks are being detected and repaired, and the standard is
being met.  The performance test may also be observed.

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

3.  Nonduplication, Consultations, and Other Collection Criteria

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

3(a)  Nonduplication

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

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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (FR citation, e.g., 70 FR 24020)
on May 6, 2005.  No comments were received on the burden published in
the Federal Register.

3(c)  Consultations

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

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and that emission limitations are met.  If the information
required by these standards was collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

3(e)  General Guidelines

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

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
the part 70 permit program and the five-year statute of limitations on
which the permit program is based.  Also, the retention of records for
five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

3(f)  Confidentiality

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

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

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

4(b)  Information Requested

(i)  Data Items

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

A source must make the following reports:

Notification Reports

Initial notification requirements	63.9(b)(1)

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

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



Notification of performance test	

63.7(b), 63.9(e)



Rescheduled of performance test	

63.7(b)(2)



Demonstration of continuous monitoring system	

63.9(g)



Change in information already provided	

63.9(j)



Request for an extension of compliance with relevant standard	

63.9(c)



Reports



Application for approval of the construction or reconstruction of a new
major affected source, or reconstruction of a major affected source	

63.5(6)(d)



Performance test results	

63.10(d)(2)



Report of opacity and visible emission observations	

63.9(f)



Startup, shutdown and malfunction plan	

63.6(e)(3)



Periodic startup, shutdown and malfunction reports	

63.10(d)(5)(i)



Notification of compliance status	

63.9(h)



SOP for baghouses and fugitive dust control	

63.1548(b)



Progress reports for compliance extension (if applicable)	

63.6(i)



Report of annual compliance tests	

63.10(d)(2)

Semiannual reports	63.1549(e)



A source must keep the following records:

Recordkeeping

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

All reports and notifications	63.10(b)(1)

Records of startup, shut-down, and malfunction of process equipment
63.10(b)(2)(i), (iv), (v)

Records of malfunctions of air pollution control equipment
63.10(b)(2)(ii)

Any applicability determination that demonstrates why owner or operator
believes source(s) is/are unaffected	63.10(b)(3)

Records of maintenance of air pollution control equipment
63.10(b)(2)(iii)

Records of flow monitoring system performance evaluations, malfunctions,
calibrations, and adjustments	63.10(b)(2)(vi), (vii), (viii), (ix), (x),
(xi), 63.10(c)

Documentation required for waiver of recordkeeping or reporting
requirements (if applicable)	63.10(b)(2)(xii)

Documentation of initial notifications	63.10(b)(2)(xiv)

Production records of the weight and lead content of unrefined lead,
copper matte, and copper speiss	63.1549(b)(1)

Records of bag leak detection system output	63.1549(b)(2)

Records of bag leak detection system alarms and corrective actions
63.1549(b)(3)

Records of fugitive dust control activities	63.1549(b)(4)

Records of baghouse inspections and maintenance	63.1549(b)(5)

Records of doorway in-draft checks	63.1549(b)(6)

Records of flow monitoring system output (if applicable)	63.1549(b)(7)

Records of damper position checks (if applicable)	63.1549(b)(8)

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



(ii)  Respondent Activities	

Respondent Activities



Read instructions.

Write the notifications and reports listed above.

Enter information required to be recorded above.



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



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



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



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



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



Transmit, or otherwise disclose the information.



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

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

5(a)  Agency Activities 

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

Agency Activities



Observe initial performance tests and repeat performance tests if
necessary.



Review notifications and reports, including performance test reports,
and excess emissions reports, required to be submitted by industry.



Audit facility records.



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



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operated.  Data and records maintained by the
respondents are tabulated and published for use in compliance and
enforcement programs.  The report of annual compliance tests is used for
problem identification, as a check on source operation and maintenance,
and for compliance determinations.

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA(s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA headquarters and
EPA regional offices.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

 The records required by this regulation must be retained by the
owner/operator for five years.

5(c)  Small Entity Flexibility

There are no small businesses, as defined by the Small Business
Administration (SBA), affected by this regulation.

5(d)  Collection Schedule

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

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 12,190
hours.  These hours are based on Agency studies and background documents
from the development of the regulation, Agency knowledge and experience
with the NESHAP program, the previously approved ICR, and any comments
received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$97.46   ($46.41 + 110%)

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, (Table 2. Civilian Workers, 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 type of industry costs associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitors and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous Monitoring Device	

(B)

Capital/

Startup Cost for One Respondent	

(C)

Number of New Respondents	

(D)

Total Capital/ Startup Cost

(B X C)	

(E)

Total Annual O&M Costs for Both Respondents	

(F)

Total Annualized Cost

Bag Leak detection system - continuous particulate matter sensor 	

$10,500	

0	

$0	

$9,500

	Flow monitors with high/low alarms	

$6,500	

0	

$0	

$9,500

	

Total Capital Cost/Total O&M Cost 	

	

	

$0	

$19,000

	

$19,000



There are no capital/startup costs for this ICR.  This cost is based on
the assumption that both existing plants have already purchased and
installed bag leak detector systems at baghouses and flow monitoring
systems and recorders.  The cost for monitors was provided to OAQPS by
vendors.  We have also assumed that no new plants will be constructed. 
This is the total of column D in the above table.  These costs are shown
on the OMB 83-I form in block 14(a), Total annualized capital/startup
costs.

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

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is estimated to be $19,000.  This is the total of column F in
the above table.  This cost is shown on the OMB 83-I form in block
14(c), Total annualized cost requested.  The numbers in block 14 of the
OMB 83-I form are rounded to show the cost in thousands of dollars.  The
figures on the OMB 83-I form reflect the rounding up of each cost
individually, so the total cost is $19,000 (rounded).

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are labor costs associated with analysis of
the reported information.  Respondents will bear the cost through permit
fees, for daily performance tests conducted at the plant by a certified
observer provided by the State enforcement agency.  EPA's overall
compliance and enforcement program includes activities such as the
examination of records maintained by the respondents, periodic
inspection of sources of emissions, and the publication and distribution
of collected information.

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

$2,611 (rounded).  This cost is based on the average hourly labor rate
as follows:

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

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

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

Based on our research for this ICR, approximately two respondents,
currently operating in the United States, are subject to the regulation.
 It is estimated that no new sources per year will become subject to the
standard in the next three years.

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

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	

Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

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

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

0	

2	

0	

0	

2



2	

0	

2	

0	

0	

2



3	

0	

2	

0	

0	

2



Average	

0	

2	

0	

0	

2

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

.

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

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

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

Total Annual Responses

E=(BxC)+D

Semiannual reports	2	2	0	4

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are 12,190.  The annual labor costs are not
shown on the OMB 83-I form.  Details regarding these estimates may be
found in Table 1. Annual Respondent Burden and Cost: NESHAP for Primary
Lead Smelters (40 CFR Part 63, Subpart TTT), attached.

There are no annualized capital/startup and O&M costs to the regulated
entities subject to the regulation.  This number is shown on the OMB
83-I form in block 14(c), Total annualized cost requested.  The cost
calculations are detailed in Section 6(b)(iii), Capital/Startup vs.
Operation and Maintenance (O&M) Costs.

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

6(e)  Bottom Line Burden Hours and Cost Tables

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

(i)  Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are 12,190 (rounded).  The annual labor
costs are not shown on the OMB 83-I form.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT),
attached.

There are no annualized capital/startup and O&M costs to the regulated
entities.  This number is shown on the OMB 83-I form in block 14(c),
Total annualized cost requested.  The cost calculations are detailed in
Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 64 labor hours at a cost of $2,611.  See Table 2. Annual
Agency Burden and Cost: NESHAP for Primary Lead Smelters (40 CFR Part
63, Subpart TTT), attached.

6(f)  Reasons for Change in Burden

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

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

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

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 3,048 (rounded) hours per
response.  Burden means the total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency.  This includes the time
needed to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.

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

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
OECA-2005-0046, which is available for public viewing at the Enforcement
and Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Avenue, N.W.,
Washington, D.C.  The EPA Docket Center Public Reading Room is open from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.
 The telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center Docket is (202) 566-1752.  An electronic version of
the public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket.  Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select (search,( then key in the
Docket ID Number identified above.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number OECA-2005-0046
and OMB Control Number 2060-0414 in any correspondence.

Part B of the Supporting Statement

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

Table 1.  Annual Respondent Burden and Cost:  NESHAP for Primary Lead
Smelters (40 CFR Part 63, Subpart TTT)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Acquisition, Installation,         and Utilization of  Technology
and  Systems	

N/A	

	

	

	

	

	

	





4.  Reporting Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

1	

1	

1	

0	

0.0	

0.0	

0.0	

$0.00



  B.  Required activities:	

	

	

	

	

	

	

	





   i.  Initial Performance tests:  c    	

8	

1	

8	

0	

0.0	

0.0	

0.0	

$0.00



   ii.  Monitoring of operations          and equipment:  d	

	

	

	

	

	

	

	





     -  Implement baghouses SOP	13.4	365	4,891	2	9,782.0	489.1	978.2	

     $908,141.32



     -  Annual compliance stack            test for lead compounds  e	

8	

1	

8	

3	

24.0	

1.2	

2.4	

$2,228.11



D.  Gather Existing Information	

Included in 4B and 5E	

	

	

	

	

	





E.  Write report   a, c 	

	

	

	

	

	

	

	





   i.  Notification of compliance        status 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   ii.  Notification of actual                startup	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   iii.  Notification of                         construction/
reconstruction   a	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   iv.  Notification of                         Performance Test 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   v.  Notification of actual                startup	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   vi.  Reports of performance           test results	

4	

1	

4	

0	

0.0	

0.0	

0.0	

$0.00



   vii.  Operation and                         maintenance reports 	

10	

1	

10	

0	

0.0	

0.0	

0.0	

$0.00



    viii.  Semi-annual reports   e      	

16	

2	

32	

2	

64	

3.2	

6.4	

$5,941.44



    ix.  Notification of   f

    physical/operational changes

	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



5.  Recordkeeping Requirements	

	

	

	

	

	

	

	





 A.  Read instructions	

Included in 4A	

	

	

	

	

	





 B.  Plan activities	

Included in 4B	

	

	

	

	

	



 

C.  Implement activities	

Included in 4B	

	

	

	

	

	





D.  Develop record system	

N/A









E.  Time to enter and transmit    information:

    -   Records of  operating                parameters 

    -   Records of compliance              inspections 

    -   Records of performance            tests 	

1	

365	

365	

2	

730.0	

36.5	

73.0	

                                $67,771.74



F.  Time to train personnel	

N/A	

	

	

	

	

	

	





G. Time for audits	

N/A	

	

	











TOTAL LABOR  BURDEN AND COST  	

	

	

	

	

10,600.0	

530.0	

1,060.0	

$984,082.80



TOTAL LABOR HOURS (Rounded)	

	

	

	

	

12,190	

$984,083



Assumptions:

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

b   This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, (Table 2. Civilian Workers, 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.

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

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

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

f   We are assuming that sources will not be changing operating
parameters even when sources may purchased new equipment.

Table 2.  Annual Burden and Cost for The Federal Government: 

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

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year  a

	

(E)

Technical

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  Notifications   c       	

2	

1	

2	

0	

0	

0	

0	

$0.00



Reports of performance test       results   c	

8	

3	

2	

0	

0	

0	

0	

$0.00



Notification of physical or          Operational changes c	

4	

1	

2	

0	

0	

0	

0	

$0.00



Semi-annual  reports   d	

10	

2	

20	

2	

40	

2.0	

4.0	        $1,864.84



Review annual test results   d	8	1	8	2	16	0.8	1.6	

$745.94



Subtotal Burden and Cost	

	

	

	

	

56	

2.8	

5.6	

     $2,610.78



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	64	

          $2,611



Assumptions:

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

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

c   We have assumed that all existing sources are in compliance with the
initial rule requirements. 

d   Although the semi-annual reports will include the annual stack test
results, we have accounted its burden separately since it will only
occur once a year.  

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