	 tc \l2 "SF SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NSPS for Glass Manufacturing Plants (40 CFR part 60, subpart CC)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Glass Manufacturing Plants (40 CFR part 60, subpart CC)
(Renewal),             

EPA ICR Number 1131.09, OMB Control Number 2060-0054

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for glass manufacturing
plants were proposed on June 15, 1979, promulgated on October 7, 1980,
and amended on both October 19, 1984, and October 17, 2000.  These
regulations apply to each glass melting furnace located at a glass
manufacturing plant that commenced construction or modification after
June 15, 1979.  This information is being collected to assure compliance
with 40 CFR part 60, subpart CC.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  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, or any period during which the
monitoring system is inoperative. Semiannual reports are also required. 
These notifications, reports, and records are essential in determining
compliance, and are required of all affected facilities subject to NSPS.

Any owner/operator subject to the provisions of this part shall 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 our consultations 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 41 respondents are currently subject to the regulation,
and it is estimated that no additional respondents per year will become
subject to the regulation in 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 (Renewal).  The burden to the “Federal
Government” is attributed entirely to work performed by federal
employees or government contractors, and may be found in Table 2:
Average Annual EPA Burden (Renewal).

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect:

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.

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, particulate matter emissions from glass
melting furnaces cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS were promulgated for this source category at 40 CFR
part 60, subpart CC.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with  the applicable regulations which where promulgated in
accordance with the Clean Air Act.     The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance 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 and leaks are being detected and repaired and the standard is
being met. The performance test may also be observed.

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

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

The requested recordkeeping and reporting are required under 40 CFR part
60,

subpart CC.

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 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

Information was previously reviewed from the United States Census
Bureau, the Air Facility System (AFS), and websites covering glass
manufacturing plants.  Approximately 41 respondents are currently
subject to the regulation, and it is estimated that no additional
respondents per year will become subject to the regulation in the next
three years.

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.

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance, and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

3(f)  Confidentiality

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

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
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 CFR Part 60, Subpart CC)	

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

In this ICR, all data recorded and/or reported are required by NSPS for
Glass Manufacturing Plants (40 CFR part 60, subpart CC) (Renewal).

A source must make the following reports:

Notifications	

Standard Citation by Section



Notification of construction/reconstruction	

60.7(a)(1)



Notification of actual startup.	

60.7(a)(3)



Notification of initial performance test	

60.8(d)



Initial performance test results	

60.8(a)



Demonstration of continuous monitoring system (CMS)	

60.7(a)(5)



Notification of physical or operational change	

60.6(a)(4)



Routine maintenance report	

60.292(e)(3)



Request for alternative CMS	

60.293(d)



Excess emissions report	

60.7(c), 60.293(c)(5)



A source must keep the following records:

Recordkeeping



Startup, shutdown, malfunction periods where the CMS is inoperative	

60.7(b)



Records are required to be retained for two years	

60.7(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.



Perform initial performance test, Reference Method 5 for particulate
matter concentration and Method 9 for opacity 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.



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



Transmit, or otherwise disclose the information.



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

5(a)  Agency Activities

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



Agency Activities



Observe 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.  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 five 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
proposed rule notice in the Federal Register (44 FR 34840) on June 15,
1979; the promulgated rule notice in the Federal Register (44 FR 66742)
on October 7, 1980; the Background Information and Draft Environmental
Impact Statement for Glass Manufacturing Plants Volume I (1979); and a
search of publicly available current data sources. 

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 NSPS for
Glass Manufacturing Plants (40 CFR part 60, subpart CC) (Renewal).

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 803
(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 NSPS 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 types 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 cost 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 Monitors	

$15,000	

0	

0	

$5,800	

41	

$237,800



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 $237,800.  This is the total of
column G.  

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 $17,907.

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: Average Annual EPA
Burden - NSPS for Glass Manufacturing Plants (40 CFR part 60, subpart
CC) (Renewal).

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 41 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject.  The overall average number of respondents, as shown in
the table below is 41 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	

(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	

41	

0	

0	

41



2	

0	

41	

0	

0	

41



3	

0	

41	

0	

0	

41



Average	

0	

41	

0	

0	

41



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

Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents  	

(C)

Number of Responses	

(D)

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

(E)

Total Annual  Responses 

E=(BxC)+D



Notification of construction/reconstruction or modification	

0	

1	

0	

0



Notification of actual startup	

0	

1	

0	

0



Notification of demonstration of CMS	

0	

1	

0	

0



Notification of physical or operation change	

0	

1	

0	

0



Notification of initial performance test	

0	

1	

0	

0



Request for alternative CMS	

0	

1	

0	

0



Routine maintenance report	

21	

1	

0	

21



Semiannual report of excess emissions	

41	

2	

0	

82



	

	

	

Total	

103



The number of Total Annual Responses is 103.  The total annual labor
costs are $64,801.  Details regarding these estimates may be found in
Table 1: Annual Respondent Burden and Cost - NSPS for Glass
Manufacturing Plants (40 CFR part 60, subpart CC) (Renewal).

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 annual labor costs are $64,801.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost -
NSPS for Glass Manufacturing Plants (40 CFR part 60, subpart CC)
(Renewal).  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 7
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $237,800.    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 426 labor hours at a cost of $17,907.  See Table 2:
Annual Agency Burden and Cost - NSPS for Glass Manufacturing Plants (40
CFR part 60, subpart CC) (Renewal).



6(f)  Reasons for Change in Burden

There is no change in the labor hours to the respondents in this ICR
compared to the previous ICR.  This is due to two considerations: 1) the
regulations have not changed over the past three years and are not
anticipated to change over the next three years; and 2) the growth rate
for respondents is very low, negative, or non-existent.  Therefore, the
labor hours in the previous ICR reflect the current burden to the
respondents and are reiterated in this ICR.  There is a minor change to
the cost figures, since the previous ICR rounded to the nearest $1,000;
this ICR presents a cost figure $200 less than the previous ICR due to
using the exact figure.

6(g)  Burden Statement

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

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

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2008-0377.  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-2008-0377 and OMB Control Number 2060-0054 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 - NSPS for Glass
Manufacturing Plants (40 CFR part 60, subpart CC) (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  	

	

	

	

	

	

	

	





     Initial performance test d	

160	

1	

160	

0	

0	

0	

0	

$0



     Repeat of performance test e	

160	

0.2	

32	

0	

0	

0	

0	

$0



  C.  Create Information	

Included in 3B	

	

	

	

	

	





  D.  Gather existing information	

Included in 3B	

	

	

	

	

	





  E.  Write report	

	

	

	

	

	

	

	





     Notification of construction/reconstruction or                     
 modification	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of actual startup f	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of demonstration of CMS	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of physical or operation change g	

2	

1	

2	

0	

0	

0	

0	

$0



     Notification of initial performance test	

2	

1	

2	

0	

0	

0	

0	

$0



     Performance test report	

Included in 3B	

	

	

	

	

	





     Demonstration of CMS	

Included in 3B	

	

	

	

	

	





     Request for alternative CMS	

4	

1	

4	

0	

0	

0	

0	

$0



     Routine maintenance report h	

2	

1	

2	

21	

42	

2.1	

4.2	

$3,899.20



     Semiannual report	

8	

2	

16	

41	

656	

32.8	

65.6	

$60,901.73



	SUBTOTAL Reporting



	

698	

34.9	

69.8	

$64,800.93



 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	

Included in 3E	

	

	

	

	

	





  F.  Train personnel	

N/A	

	

	

	

	

	

	





  G.  Audits	

N/A	











	SUBTOTAL Recordkeeping



	

0	

0	

0	

$0



Subtotal Labor Burden	

	

	

	

	

698	

34.90	

69.80	

$64,800.93



TOTAL LABOR  BURDEN AND COST 	

	

	

	

	

802.70	

$64,800.93 

Assumptions:

a  We have assumed that the average number of existing respondents is
41, and that no additional new sources will become subject to the rule
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 it will take one hour to read instructions as
part of their reporting requirements.

d  We have assumed that it will take 160 hours to complete a performance
test.

e  We have assumed that 20 percent will fail the performance tests.

f  We have assumed that it will take two hours to write notification of
actual startup report.

g  We have assumed that it will take two hours to write notification
report of physical or operation change.

h  We have assumed that 50 percent of respondents will submit routine
maintenance reports.



Table 2:  Average Annual EPA Burden -  NSPS for Glass Manufacturing
Plants (40 CFR part 60, subpart CC) (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 tests  	

	

	

	

	

	

	

	





      New or modified facility c	

40	

1	

40	

0	

0	

0	

0	

$0



Repeat performance test	

	

	

	

	

	

	

	





      New or modified facility c,d	

40	

0.2	

8	

0	

0	

0	

0	

$0



Report review	

	

	

	

	

	

	

	





      New or Modified Facility	

	

	

	

	

	

	

	





      Modification of construction/reconstruction or               
modification e	

2	

1	

2	

0	

0	

0	

0	

$0



      Notification of actual startup f	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Notification of demonstration of CMS f	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Notification of physical or operational change f	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Notification of initial performance test f	

0.5	

1.2	

0.6	

0	

0	

0	

0	

$0



      Review of performance test results g	

8	

1.2	

9.6	

0	

0	

0	

0	

$0



      Review demonstration of CMS 	

Included in review of performance test results	

	

	

	

	

	





      Review request for alternative CMS	

4	

1	

4	

0	

0	

0	

0	

$0



      Review of routine maintenance report h	

2	

1	

2	

21	

42	

2.1	

4.2	

$1,958.08



      Review of semiannual reports	

4	

2	

8	

41	

328	

16.4	

32.8	

$15,949.33



Subtotals Labor Burden and Cost	

	

	

	

	

370	

18.50	

37	

$17,907.41



TOTAL LABOR BURDEN AND COST 	

	

	

	

	

	

425.50	

	

$17,907.41



Assumptions:

a  We have assumed that the average number of existing respondents is
41, and that no additional new sources will become subject to the rule
over the three-year period of this ICR.

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) “2005 General Schedule” which excludes locality
rates of pay.

c  We have assumed that it will take 40 hours to participate with the
performance tests.

d  We have assumed that 20 percent of respondents will repeat
performance tests because of failure.

e  We have assumed that it will take two hours to review construction
report.

f  It will take each respondent 0.5 hours to review actual startup
report, CMS report, physical or operational change report, and initial
performance test report.

g  We have assumed that it will take eight hours to review performance
test results. 

h  We have assumed that 50 percent of respondents will submit routine
maintenance reports.

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