SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT)
(Renewal), 

EPA ICR 2098.05, OMB Control Number 2060-0536.

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Magnesium Refining published at 40 CFR part 63, subpart TTTTT were
proposed on January 22, 2003, and promulgated on October 10, 2003. 
These regulations apply to existing facilities and new facilities that
perform primary magnesium refining where the total hazardous air
pollutants (HAPs) emitted are greater than, or equal to, 10 tons per
year for each HAP, or where the total HAPs emitted are greater than, or
equal to, 25 tons per year of any combination of HAPs.      New
facilities include those that commenced construction or reconstruction
after the date of the proposal.  This information is being collected to
ensure compliance with 40 CFR part 63, subpart TTTTT.

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

Any owner, or operator, subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
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 U.S. 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).

One source currently is subject to the standard, and it is estimated
that no additional sources per year will become subject to the
regulation in the next three years.

	The active (previous) Information Collection Request (ICR) had the
following Terms of Clearance (TOC): 

When this ICR is resubmitted for renewal, EPA is reminded that they
should include the name and contact information for consultations with
members of the public concerning the collection.

Due to consultations being conducted over three years prior to this ICR
renewal, the contact information is not currently available.  It should
be noted that this ICR renewal does not require consultations because:
1) the labor hour burden is less than 100,000 hours per year; and 2)
there have not been significant changes in the ICR burden.

The previous ICR incorrectly indicated that the affected public included
Federal government, state, local, or tribal government facilities,
while, in fact, the affected public includes only a single private
business.  This has been corrected in this ICR.

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost, NESHAP for Primary Magnesium Refining
(40 CFR Part 63, Subpart TTTTT) (Renewal).  The burden to the “Federal
Government” is attributed entirely to work performed by Federal
employees or government contractors; this burden may be found below in
Table 2: Average Annual EPA Burden, NESHAP for Primary Magnesium
Refining (40 CFR Part 63, Subpart TTTTT) (Renewal).  

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, or operator subject to any requirement of this Act to:

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

In the Administrator's judgment, hazardous air pollutant (HAP) emissions
from large household and commercial appliance surface coating facilities
cause, or contribute to, air pollution that may reasonably be
anticipated to endanger public health, or welfare.  Therefore, NESHAP
for this source category were promulgated at 40 CFR part 63, subpart
TTTTT.

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 also is
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standards. 
Continuous emission monitors are used to ensure compliance with the
standards at all times.

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 check if 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
also may 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.  Nonduplication, Consultations, and Other Collection Criteria

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

3(a)  Nonduplication

If the subject standards have not been delegated, the information is
sent to the appropriate EPA regional office.  Otherwise, the information
is sent directly to the delegated state or local agency.  If a state, or
local agency has adopted 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 Office of
Management and Budget (OMB)

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (74 FR 38004) on July 30, 2009. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

Any comments received since the last ICR renewal including those
submitted in response to the first Federal Register notice announcing
the renewal of this ICR have been reviewed.        In this case, no
comments were received.  During a previous renewal of this ICR, the
Agency’s industry experts were consulted.  The Agency’s internal
data sources and any projections of industry growth over the next three
years were considered.

The Agency’s primary source of information, as reported by industry,
is the Air Facility System (AFS), which is operated and maintained by
the EPA Office of Compliance.  AFS is the EPA database for the
collection, maintenance, and retrieval of all compliance data.  One
respondent is currently subject to the regulation, and our consultations
with Agency industry experts during a previous renewal regarding the
growth rate for the industry indicated that no additional respondents
will become subject to the regulation over the next three years.

Estimates of industry size, growth rate, and burden were developed with
extensive participation and consultation with primary magnesium refining
representatives during recent rulemaking for 40 CFR part 63, subpart
TTTTT.  EPA believes that these estimates remain valid, and are the best
information available.  The Agency currently collects the minimum amount
of information necessary to ensure compliance with the standard.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the required standards.
 Requirements for information gathering and 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

These reporting and recordkeeping requirements do not violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

 	These standards require affected facilities 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.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of noncompliance 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 (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

The reporting and recordkeeping requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested 

4(a)  Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are
primary magnesium refiners.  The United States 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 descriptions.

Standard	SIC Codes	NAICS Codes

40 CFR part 63, subpart TTTTT	3339	331419



4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 63, subpart TTTTT.

A source must make the following reports:

Notifications

Initial notification	63.9930(a), 63.5(d), 63.9(b)

Notification of compliance status	63.9930(a), 63.4710(c), 63.9(h)

Notification of construction or reconstruction	63.9930(a), 63.5

Notification of actual startup	63.9930(a), 63.9(b)

Notification of performance test	63.9930(a), 63.7(b), 63.8(e), 63.9(e)



Notification Reports

Semiannual report	63.9931(a), (b)

Excess emissions report	63.9931(a), (b)

Report of performance test	63.9930(e)

Startup, shutdown, malfunction report	63.9931(c), 63.6(e)(3),
63.10(d)(5)



	A source must keep the following records:

Recordkeeping

Five year retention of records	63.9933(b), 63.10(b)

Copies of notifications and reports	63.9932(a)(1)

Startup, shutdown, and malfunction plan/records	63.9932(a)(2), 63.6(e)

Documentation of performance tests and opacity observations
63.9932(a)(3), 63.10(b)

Records required to demonstrate continuous compliance	63.9932(b)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., inlet and outlet
concentrations when determining percent efficiency.  Although personnel
at the source still need to evaluate the data, this type of monitoring
equipment has significantly reduced the burden associated with
monitoring and recordkeeping.  In addition, some regulatory agencies are
setting up electronic reporting systems to allow sources to report
electronically which reduces the reporting burden.  However, electronic
reporting systems still are not widely used by the regulatory agencies. 
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 compliance monitoring system
(CMS) for pressure drop or for liquid flow rate for wet scrubber.

Perform initial performance test, Reference Method 1, 2, 2F, 2G, 3, 3A,
3B, 4, 5, 5D, 18, 23, 25D, 26, 26A, 201, 201A, 301, 303, 303A, 304,
304A, 304B, 305, 306, 306A, 306B, 307, 308, 310A, 310B, 310C, 311, 312A,
312B, 312C, 313A, 313B, 315, 316, 318, 319, 320, or 321 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,
excess emissions reports, startup, shutdown, malfunction plan, and
quality control plan for CMS 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 the EPA Office of Compliance.  AFS is the EPA
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 or
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.  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 below in Table 1: Annual Respondent Burden and
Cost, NESHAP for Primary Magnesium Refining (40 CFR part 63, subpart
TTTTT) (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 611
hours (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	$100.99 ($48.09 + 110%)

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 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 and Operations and Maintenance Costs

This section covers the costs associated with all types of continuous
monitoring equipment, e.g., continuous emissions monitoring systems
(CEMS) and continuous parameter monitors.  The types of industry costs
associated with the information collection activity 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 incurred 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.

Capital/Startup vs. Operating 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)

CEM	$16,000	0	$0	$1,200	1	$1,200



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

 

The total Operating and Maintenance (O&M) Costs for this ICR are $1,200.
 This is the total of column G.

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 $1,200.  The continuous monitoring costs that are
included in this section consist only of those capital/startup and O&M
costs that a source incurs as a result of the standard.  Some continuous
monitoring costs may not be included in this section.  For instance, if
a particular industry typically utilizes a control device that must have
a continuous monitor (e.g., temperature, pressure drop, etc.) to
function properly, and the recordation of additional measurements beyond
the minimum are required by the standard, then there is no
capital/startup or O&M cost, but there is a labor cost to record the
additional readings.  Such a cost would not appear in this section, but
in the industry burden Section 6(d) below.

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 $7,354.  See below Table 2 in Section 6(e).

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

	Managerial	$57.20  (GS-13, Step 5, $35.75 x 1.6)

	Technical	$42.45  (GS-12, Step 1, $26.53 x 1.6)

	Clerical	$22.96  (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule”, which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: “Average Annual EPA
Burden and Cost, NESHAP for Primary Magnesium Refining (40 CFR part 63,
subpart TTTTT) (Renewal).”

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

Based on our research for this ICR, there is one existing source
currently subject to the standard.  It is estimated that no additional
sources will become subject to the regulation 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	1	0	0	1

2	0	1	0	0	1

3	0	1	0	0	1

Average	0	1	0	0	1

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

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is one (1).

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

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

Total Annual Responses 

E=(BxC)+D

Initial notification	0	1	0	0

Notification of compliance status	0.33	1	0	0.33

Notification of construction/reconstruction	0	1	0	0

Notification of actual startup 	0	1	0	0

Notification of performance test 	0.33	1	0	0.33

Report of performance test	0.33	1	0	0.33

Semiannual report 	1	2	0	2

Startup, shutdown, malfunction report	1	1	0	1



	Total	4



The number of Total Annual Responses is 4.

Note that the total annual capital and O&M costs to the regulated entity
are $1,200.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents appear below.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 153
hours per response.

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

Details regarding these estimates may be found in below Table 1:
“Annual Respondent Burden and Cost, NESHAP for Primary Magnesium
Refining (40 CFR part 63, subpart TTTTT) (Renewal).”  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 153 hours per response.

The total annual capital and O&M costs to the regulated entity are
$1,200.  These costs 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 178 labor hours at a cost of $7,354.  See below Table 2:
Average Annual EPA Burden and Cost, NESHAP for Primary Magnesium
Refining (40 CFR part 63, subpart TTTTT) (Renewal).

6(f)  Reasons for Change in Burden

	

The changes in burden from the most recently approved ICR are due to an
adjustment.  Calculation errors in the previous ICR were corrected,
resulting in a small decrease in the respondent burden hours and cost
and an increase to the calculated Agency burden hours and cost.  

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 153 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 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–2009–0522.  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 Avenue, NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1752.  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–2009–0522 and OMB Control Number 2060-0536 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
Magnesium Refining (40 CFR part 63, subpart TTTTT) (Renewal)

Burden Item	

(A) Person-hours per occurrence	

(B) 

Number of occurrences per year	

(C) Person-hrs. per respondent per year

 (C=A*B)	

(D) Respondents per year 	

(E) Technical person-hrs. per year (E=C*D)	

(F) Management person-hrs. per year 

(F=E*0.05)	

(G) Clerical person-hrs. per year (G=E*0.1)	

(H) 

Annual costs ($)

1. Reporting requirements

	a. Read rule and instructions	4	1	4	1	4	0.2	0.4	390

b. Process/review information	4	4	16	1	16	0.8	1.6	1,558

c. Write reports

	i. Initial notification	2	1	2	0	0	0	0	0

ii. Notification of compliance status	2	1	2	0.33	0.66	0.03	0.07	64

iii. Notification of construction/reconstruction	2	1	2	0	0	0	0	0

iv. Notification of actual startup	2	1	2	0	0	0	0	0

v. Notification of performance test	2	1.2	2.4	0.331	0.79	0.04	0.08	77

vi. Report of performance test	180	1.2	216	0.331	71.28	3.56	7.13	6,942

vii. Semiannual report	10	2	20	1	20	1	2	1,948

viii. Startup, shutdown, malfunction report	4	1	4	1	4	0.2	0.4	390

Subtotal Reporting



	134	11,369

2. Recordkeeping requirements

	a. Read rule and instructions	4	1	4	1	4	0.2	0.4	390

b. Plan activities	12	1	12	1	12	0.6	1.2	1,169

c. Implement activities	12	1	12	1	12	0.6	1.2	1,169

d. Time to train personnel	10	1	10	1	10	0.5	1	974

e. Time to enter information	-	-	-	-	-	-	-	-

f. Store, file, and maintain records	1	365	365	1	365	18.25	36.5	35,551

g. Retrieve records/reports	1	12	12	1	12	0.6	1.2	1,169

Subtotal Recordkeeping



	477	40,422

Total Burden (Hrs) and Costs

	

	

	611	$51,791



Table 2:  Average Annual EPA Burden, NESHAP for Primary Magnesium
Refining (40 CFR part 63, subpart TTTTT) (Renewal)

Burden Item	(A)

Person-hours 

per 

occurrence	(B)

Number of occurrences per year	(C)

Number of respondents	(D)

Technical person-hours per year

(D=A*B*C)	(E)

Management person-hours per year

(E=D*0.05)	(F)

Clerical person-hours per year

(F=D*0.1)	(G)

Annual costs 

($)

1. Initial performance test	24	1	0.33	7.92	0.4	0.79	377

2. Repeat performance test	24	0.2	0.33	1.58	0.08	0.16	75

3. Report review 







	  a) Initial notification	8	1	0	0	0	0	0

b) Notification of performance test	8	1.2	0.33	3.17	0.16	0.32	151

c) Notification of compliance status	8	1	0.33	2.64	0.13	0.26	125

d) Notification of construction/reconstruction	8	1	0	0	0	0	0

e)  Notification of actual startup	8	1	0	0	0	0	0

f) Report of performance test	8	1.2	0.33	3.17	0.16	0.32	151

g) Semiannual report	16	4	2	128	6.4	12.8	6,094

h) Startup, shutdown,          malfunction report	8	1	1	8	0.4	0.8	381

Total Burden (Hrs) and Costs



178	$7,354



 Performance test repeated once in three years.

 Includes Method 23 test.

 Includes inspection of unpaved areas.

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