	SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants

(40 CFR part 61, subpart N) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection 

NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants
(40 CFR Part 61, Subpart N) (Renewal), EPA ICR 1081.09, OMB Control
Number 2060-0043

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Inorganic Arsenic Emissions from Glass Manufacturing Plants were
proposed on July 20, 1983 and promulgated on August 4, 1986.  The
standards were amended on both May 31, 1990 and

October 17, 2000.  These standards apply to each glass melting furnace
that uses commercial arsenic as a raw material.  These standards do not
apply to pot furnaces.  Also, re-bricking is not considered construction
or modification for the purposes of 40 CFR Section 61.05(a).  This
information is being collected to assure compliance with 40 CFR part 61,
subpart N.

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 will
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.

In the event that there is no such delegated authority, the reports are
sent directly to the United States Environmental Protection Agency (EPA)
regional office.

Based on consultation with industry representatives, there is an average
of one affected facility at each plant site and each plant site has only
one respondent (i.e., the owner/operator of the plant site).

Approximately sixteen respondents are currently subject to the
regulation, and it is estimated that no additional respondents per year
will become subject to the regulation over the next three years.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost: NESHAP for Inorganic Arsenic Emissions from
Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal),
attached.  The burden to the “Federal Government” is attributed
entirely to work performed by federal employees or government
contractors; this burden may be found in Table 2: Average Annual EPA
Burden: NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing
Plants (40 CFR Part 61, Subpart N) (Renewal), attached.    

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 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/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, arsenic emissions from glass
manufacturing plants cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP was promulgated for this source category at 40 CFR
part 61, subpart N.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure
compliance with the applicable regulations which 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 standards. 
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 standards 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.

The required semiannual reports are used to: 1) determine periods of
excess emissions;  2) identify problems at the facility; 3) verify
operation/maintenance procedures; 4) make compliance determinations.

3.  Non-duplication, Consultations, and Other Collection Criteria

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

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 its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or a 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 (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

For this information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR, and used several
different resources to obtain the most recent data available.  We
reviewed information available from the United States Census Bureau, the
Air Facility System (AFS), and websites covering inorganic arsenic
emissions from glass manufacturing.

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.  In this case, no comments were received.

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 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 (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
inorganic arsenic emissions from glass manufacturing plants.  The
Standard Industrial Classification (SIC) codes for the respondents
affected by the standards, which correspond to the North American
Industry Classification System (NAICS) codes, are listed below for
source category description.

Standard (40 CFRp 61, subpart N)	

SIC Codes	

NAICS Codes



Flat Glass Manufacturing	

3211	

327211



Glass Container Manufacturing	

3221	

327213



Other Pressed and Blown Glass and Glassware Manufacturing	

3229	

327212



Mineral Wool Manufacturing	

3296	

327993



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

All data in this ICR that are recorded and/or reported are required by
the NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing
Plants (40 CFR part 61, subpart N) (Renewal).

A source must make the following reports:

Notification Reports	

Standard Citation by Section



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)



Source status report	

61.10(a)



Notification of initial performance emissions test	

60.13(c), and 61.165(d)(2)



Report initial performance emissions test results	

61.13(f), and 61.165(d)(2)



Notification of physical or operational change	

61.15



Report of arsenic emission estimates	

61.165(d)(3)



Report of uncontrolled arsenic emission rates	

61.165(d)(4)



Request approval of control device bypass	

61.165(e)



Report of results of continuous monitoring system (CMS) evaluation	

61.165(f)(1)



Semiannual report of excess emissions (opacity)	

61.165(f)(2)



A source must keep the following records:

Recordkeeping



Record continuous opacity and temperature of gas entering control device


61.165(a)(1)



Records of emission test results and other data needed to determine
emissions	

61.13(g), and 61.165(a)(2)



Records of CMS performance evaluations	

61.165(a)(3)



Occurrence and duration of startup, shutdown, and malfunction of furnace


61.165(a)(4)



Malfunction of air pollution control device	

61.5165(a)(5)



Periods when monitors are inoperative	

61.165(a)(6)



Maintenance and repair of control device, CMS or monitor	

61.165(a)(7)



Records of approved control device bypass	

61.165(b)



Semiannual records of uncontrolled arsenic emission rate	

61.165(c)



Records are required to be retained for two (2) years	

61.14(f)



Electronic Reporting

Currently, respondents are using monitoring equipment that automatically
records parameter data.  Although personnel at the affected facility
must evaluate the data, this internal automation has significantly
reduced the burden associated with monitoring and recordkeeping at the
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.

(ii)  Respondent Activities	

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate CMS for opacity, or for
pressure drop and liquid supply pressure for wet scrubber.



Perform initial performance test, Reference Methods 1, 2, 3, 5D, and 108
test, 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 automated monitoring equipment that
provides parameter data.  Although personnel at the sources 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,
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.

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.  The semiannual 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.  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 regional offices
and EPA headquarters. EPA and its delegated Authorities can edit, store,
retrieve and analyze the data.

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

5(c)  Small Entity Flexibility

A 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.  The number of small entities affected by this rule could
not be determined, based on review of the following sources: the
promulgated rule notice in the Federal Register (51 FR 27956) on August
4, 1986; the Inorganic Arsenic Emissions from Glass Manufacturing Plants
Background Information for Proposed Standards (1983); and a search of
publicly available current data sources.  Based on the Background
Information document, about 70 percent of glass plants are considered to
be small firms; however, arsenic usage by these small firms is not
known.

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 requirements the minimum 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
Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR part
61, subpart N) (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.  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 3,098
(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	$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 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)



Continuous Opacity Monitor	

N/A	

N/A	

$0	

$3,000	

16	

$48,000



Temperature Monitor	

N/A	

N/A	

$0	

$500	

16	

$8,000



Totals	

	

	

$0	

	

	

$56,000



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

The total operation and maintenance (O&M) costs for this ICR are
$56,000.  This is the total of column G.

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 $56,000 .

6(c)  Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is
estimated to be $4,009.

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) “2004
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden for NESHAP for Inorganic Arsenic Emissions from Glass
Manufacturing Plants (40 CFR part 61, subpart N) (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 sixteen existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject to the standard in the next three years.  The overall
average number of respondents, as shown in the table below, is 16 per
year.

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	

16	

0	

0	

16



2	

0	

16	

0	

0	

16



3	

0	

16	

0	

0	

16



Average	

0	

16	

0	

0	

16



As shown above, the average Number of Respondents over the three year
period of this ICR is 16.  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



Application of construction or modification	

0	

0	

N/A 	

0



Notification of anticipated startup	

0	

0	

N/A	

0



Notification of actual startup	

0	

0	

N/A	

0



Source status report	

0	

0	

N/A	

0



Notification of initial performance emission test	

0	

0	

N/A	

0



Notification of physical or operation change	

0	

0	

N/A	

0



Report of arsenic emission estimates	

15	

2	

N/A	

30



Report of uncontrolled arsenic emission rates	

15	

2	

N/A	

30



Request approval of control device bypass	

1	

1	

N/A	

1



Semiannual excess emissions (opacity)	

1	

2	

N/A	

2



	

	

	

Total	

63



The number of Total Annual Responses is 63.  The total annual labor
costs are $250,106.  Details regarding these estimates may be found in
Table 1: Annual Respondent Burden and Cost, NESHAP for Inorganic Arsenic
Emissions from Glass Manufacturing Plants (40 CFR part 61, subpart N)
(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.

(i) Respondent Tally

The total annual labor costs are $250,106.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost,
Annual Respondent Burden and Cost, NESHAP for Inorganic Arsenic
Emissions from Glass Manufacturing Plants (40 CFR part 61, subpart N)
(Renewal), attached.  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 49 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $56,000.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 99 labor hours at a cost of $4,009.  See Table 2: Annual
Agency Burden and Cost, NESHAP for Inorganic Arsenic Emissions from
Glass Manufacturing Plants (40 CFR part 61, subpart N) (Renewal),
attached.

6(f)  Reasons for Change in Burden

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

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 49 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-2008-0375.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents 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 Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center 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, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2008-0375 and OMB Control Number 2060-0043 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 Inorganic
Arsenic Emissions from Glass Manufacturing Plants (CFR part 61, subpart
N) (Renewal)

	Burden item	

(A)

Technical

Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical

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 c	

1	

1	

1	

0	

0	

0  	

0	

$0



  B.  Required Activities	

N/A	

	

	

	

	

	

	





           Initial performance emission tests d	

80	

1	

80	

0	

0	

0	

0	

$0



           Repeat of performance emission tests	

80	

0.2	

16	

0	

0	

0	

0	

$0



  C.  Create information	

Included in 3B	

	

	

	

	

	





  D.  Gather existing information	

Included in 3B	

	

	

	

	

	





  E.  Write report	

	

	

	

	

	

	

	





       Application of construction or modification	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of anticipated startup	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of actual startup	

2	

1	

2	

0	

0	

0	

0	

$0



       Source status report	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of initial performance emission          test	

2	

1	

2	

0	

0	

0	

0	

$0



       Report of initial performance emission test  	

Included in 3B	

	

	

	

	

	





       Notification of physical or operation change	

2	

1	

2	

0	

0	

0	

0	

$0



       Report results of continuous monitoring                system
(CMS) evaluation	

Included in 3B	

	

	

	

	

	





       Report of arsenic emission estimates e	

16	

2	

32	

15	

480	

24	

48	

$44,562



       Report of uncontrolled arsenic emission f                rates	

8	

2	

16	

15	

240	

12	

24	

$22,281



       Request approval of control device bypass g	

6	

1	

6	

1	

6	

0.3	

0.6	

$557



       Semiannual excess emissions (opacity) h	

16	

2	

32	

1	

32	

1.6	

3.2	

$2,971

SUBTOTAL Reporting



	758	37.9	75.8	$70,371



4.  Recordkeeping Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

Included in 3A	

	

	

	

	

	





  B.  Plan activities	

Included in 3B	

	

	

	

	

	





  C.  Implement activities	

Included in 3B	

	

	

	

	

	





  D.  Develop record system	

N/A	

	

	

	

	

	

	





  E.  Time to enter information i	

40	

1	

40	

16	

656	

32.8	

65.6	

$60,902



          Record continuous opacity and                             
temperature of gas entering control device	

Included in 4E	

	

	

	

	

	





          Records of emission test results	

Included in 4E	

	

	

	

	

	





          Records of CMS performance evaluations	

Included in 4E	

	

	

	

	

	





          Occurrence and duration of startup,                      
shutdown, and malfunction of furnace	

Included in 4E	

	

	

	

	

	





          Records of malfunction of control device	

Included in 4E	

	

	

	

	

	





          Periods when monitors are inoperative	

Included in 4E	

	

	

	

	

	





          Maintain and repair of control device,                   CMS,
or monitors	

Included in 4E	

	

	

	

	

	





          Records of approved control device                      
bypass	

Included in 4E	

	

	

	

	

	





          Semiannual records of uncontrolled j                arsenic
emission rate	

40	

2	

80	

16	

1,280	

64	

128	

$118,833



  F.  Time to train personnel	

N/A	

	

	

	

	

	

	





  G.  Time for audits	

N/A	

	

	

	

	

	

	



SUBTOTAL Recordkeeping



	1936	96.80	193.60	$179,735



Subtotal Labor Burden	

	

	

	

	

2,694	

134.70	

269.40	

$250,106



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

3,098.10	

$250,106



Assumptions:

a  We have assumed that there are sixteen existing sources, and that no
additional new sources will become subject to the rule over the next
three years.

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 it will take one hour to read instructions.

d  We have assumed that it will take eighty hours to complete
performance test.

e  We have assumed that fifteen respondents will write report of arsenic
emission estimates on a semiannual basis.

f  We have assumed that fifteen respondents will write report of
uncontrolled arsenic emission rates on a semiannual basis.

g  We have assumed that one respondent will write report requesting
approval of control device bypass once a year.

h  We have assumed that one respondent will write an excess emissions
report semiannually.

i  It will take each respondent forty hours to enter information.

j  It will take each respondent forty hours twice a year to record
uncontrolled arsenic emission rate.

Table 2:  Average Annual EPA Burden - NESHAP for Inorganic Arsenic
Emissions from Glass manufacturing Plants (CFR part 61, subpart N)
(Renewal)

	Burden item	

(A)

Technical

Person

Hours Per

Occurrence	

(B)   

Number  of

Occurrences

Per Year	

(C)

Technical

Person Hours Per Plant Per

Year

(C=AxB)	

(D)

Plants Per  Year a	

(E)

Technical Hours 

Per Year

(E=CxD)	

(F)

Management   Hours Per Year

(F=0.05xE)	

(G)

Clerical

Hours Per

Year

(G=0.1xE)	

(H)

Total

Cost, 

Per Yearb





Initial performance test	

	

	

	

	

	

	

	





     New facility c	

24	

1	

24	

0	

0	

0	

0	

$0



Repeat performance test	

	

	

	

	

	

	

	





     New facility d	

24	

0.2	

4.8	

0	

0	

0	

0	

$0



Review reports      	

	

	

	

	

	

	

	





     New facility	

	

	

	

	

	

	

	





          Construction or modification application	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Notification of anticipated startup	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Notification of actual startup	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Source status report	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Notification of initial performance emissions test	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Report of initial performance emissions test results	

8	

1	

8	

0	

0	

0	

0	

$0



          Notification of physical or operational     change	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Notification of emissions test	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



          Report results of CMS evaluation	

8	

1	

8	

0	

0	

0	

0	

$0



     Existing facility	

	

	

	

	

	

	

	





          Report of arsenic emission estimates rates e	

4	

1	

4	

15	

60   	

3	

6	

$2,797



          Reports of uncontrolled arsenic emission f rates	

8	

1	

8	

1	

8	

0.4	

0.8	

$373



          Semiannual excess emissions g	

6	

2	

12	

1	

12	

0.6	

1.2	

$559



          Request approval of control device bypass h	

6	

1	

6	

1	

6	

0.3 	

0.6	

$280



 Subtotals Labor Burden and Cost	

	

	

	

	

86	

4.3	

8.6	

$4,009



TOTAL LABOR BURDEN AND COST 	

	

	

	

	

	

98.90	

	

$4,009.00



Assumptions:

a  We have assumed that there are sixteen existing sources, and that no
additional new sources will become subject to the rule 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: $56.02 for Managerial (GS-13, Step 5, $35.01 x 1.6), $41.57
for Technical (GS-12, Step 1, $25.98 x 1.6) and $22.50 Clerical (GS-6,
Step 3, $14.06 x 1.6).  These rates are from the Office of Personnel
Management (OPM) “2004 General Schedule” which excludes locality
rates of pay.

c  We have assumed that it will take twenty four hours to perform
initial performance test.

d  We have assumed that it will take twenty four hours to repeat
performance test.						

e  We have assumed that fifteen respondents will be required to review
the report of arsenic emission estimates rates once a year.

f   We have assumed that it will take eight hours to review reports of
uncontrolled arsenic emission rates once a year.

g  It is required that excess emissions reports are reviewed on a
semiannual basis.

h  We have assumed that one respondent will review a report requesting
approval of control device bypass once a year.

 PAGE  12 

