2274ss01

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NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing and Secondary Nonferrous Metals Processing Area Sources (40 CFR part 63, subparts RRRRRR, SSSSSS, and TTTTTT) (Proposed Rule)

OMB: 2060-0606

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SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR CLAY CERAMICS MANUFACTURING, GLASS MANUFACTURING AND SECONDARY NONFERROUS METALS PROCESSING AREA SOURCES


PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

“National Emission Standards for Hazardous Air Pollutants (NESHAP) for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing Area Sources.” This is a new information collection request (ICR) and the EPA tracking number is 2274.01.

(b) Short Characterization.

This ICR covers information collection requirements in the proposed area source rules for Clay Ceramics Manufacturing (40 CFR part 63, subpart RRRRRR), Glass Manufacturing (40 CFR part 63, subpart SSSSSS), and Secondary Nonferrous Metals Processing (40 CFR part 63, subpart TTTTTT).

The potential respondents are owners or operators of any existing or new clay ceramics manufacturing facility, glass manufacturing facility, or secondary nonferrous metals processing facility that is an area source of hazardous air pollutants (HAP) emissions. There are an estimated 51 facilities subject to the NESHAP for the Clay Ceramics Manufacturing area source category, an estimated 21 facilities subject to the NESHAP for the Glass Manufacturing area source category, and an estimated 10 facilities subject to the NESHAP for the Secondary Nonferrous Metals Processing area source category. The affected source at a clay ceramics facility includes all kilns that fire glazed ceramic ware and all glaze spray booths that use an atomizing (spray) application technique. The affected sources at a glass manufacturing facility are the glass melting furnaces. The affected source at a secondary nonferrous metals processing facility is the collection of all furnace melting operations and crushing and screening operations (if applicable) located at a secondary nonferrous metals processing facility. Clay ceramics, glass manufacturing, and secondary nonferrous metals processing facilities are currently well-controlled in terms of urban metal HAP emissions as a result of State and national standards, permitting requirements, and/or management practices already taken by the industry to reduce urban metal HAP.

Under the proposed Clay Ceramics Manufacturing area source rule, affected sources will be subject to a series of management practices, including one which requires them to maintain the peak temperature of kilns that fire glazed ceramic ware at or below 1480°C (2700°F) and either use natural gas, or an equivalent clean-burning fuel, as the kiln fuel, except during periods of natural gas curtailment or supply interruption; alternatively, affected sources will have the option of using an electric-powered kiln. Affected sources will also be required to maintain annual wet glaze usage records to document whether the facility is above or below the 250 ton per year (tpy) threshold for wet glaze usage. Affected sources located at a facility that uses more than 250 tpy of wet glaze will be required to have one or more air pollution control devices (APCDs) on their glaze spray booths and operate and maintain them according to the equipment manufacturer’s specifications; alternatively, sources could use glazes containing less than 0.1 (weight) percent HAP metals. Affected sources located at a facility that uses 250 tpy or less of wet glaze will be required to employ waste minimization practices (e.g., high-volume, low-pressure (HVLP) spray guns); alternatively, sources could comply with one of the management practices listed for facilities above the 250 tpy threshold.

Proposed compliance requirements for clay ceramics facilities include conducting daily checks of the kiln peak firing temperature, conducting weekly control device inspections (for glaze spray booths at existing sources), conducting daily control device parameter checks or visible emissions (VE) tests (for glaze spray booths at new sources), complying with EPA-approved alternative monitoring requirements, and submitting initial notifications of applicability and compliance status. Existing and new sources will also be subject to requirements in the General Provisions (40 CFR part 63, subpart A), as specifically noted.

Under the proposed Glass Manufacturing area source rule, owners and operators of glass melting furnaces that produce at least 50 tpy of glass and use one or more HAP metal compounds as raw materials would be required to meet emission limits. Owners and operators of affected furnaces would be required to conduct a one-time performance test on each affected furnace to demonstrate compliance with the emission limits. However, if the furnace had been tested within the previous 5 years and the test demonstrated compliance with the emission limits in the proposed Glass Manufacturing area source rule, no additional testing would be required.

For any existing affected furnace that is controlled with an electrostatic precipitator (ESP), the proposed rule also would require monitoring of secondary voltage and electrical current to each field of the ESP. For any existing affected furnace that is controlled with a fabric filter, the proposed rule also would require monitoring of the fabric filter inlet temperature. The rule would require monitoring systems to measure the appropriate parameter at least every 15 minutes, and the average value would have to be recorded at least once every 8‑hour shift. For any new affected furnace controlled with an ESP, the owner or operator would have to install a continuous parameter monitoring system (CPMS) that continuously measures and records the secondary voltage and electrical current to each field of the ESP. For any new affected furnace controlled with a fabric filter, the owner or operator would have to install a bag leak detection system. Owners and operators of any affected existing or new furnaces also would be required to conduct annual inspections of furnace emission control devices and monitoring systems.

The proposed Glass Manufacturing area source rule would require affected facilities to submit an Initial Notification and a Notice of Compliance Status. Affected facilities also would be required to keep records of glass production and control device and monitoring system operation and maintenance activities.

Under the proposed Secondary Nonferrous Metals area source rule, affected sources will be required to install a capture system that collects the particulate and fumes released at each crushing and screening operation and duct those emissions to a particulate matter (PM) control device. Affected sources will also be required to install, operate, and maintain one or more fabric filter/cartridge collector baghouses on each furnace melting operation.

For a new or existing affected source with a crushing or screening operation, the proposed rule would require a daily visual inspection, including airflow verification, of the associated capture device. For an existing affected source with furnace melting operations, the proposed rule would require a daily visible emissions check or a daily visual bag inspection of each baghouse. For a new affected source with furnace melting operations, the proposed rule would require owners and operators to install, operate, and maintain a bag leak detection system for each baghouse used to comply with the standards. Owners and operators of any new affected source would also be required to conduct a daily check of each bag leak detection system. The proposed rule would also require affected facilities to submit initial notifications of applicability and compliance status. Existing and new sources will also be subject to requirements in the General Provisions (40 CFR part 63, subpart A), as specifically noted.

The proposed information collection requirements for existing and new sources in the Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing source categories are listed in Attachments 1A, 1B, and 1C.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both major and area sources of HAP that are listed for regulation under CAA section 112(c). An area source is a stationary source that is not a major source (i.e., an area source does not emit and does not have the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any combination of HAP). Requirements for area sources in CAA sections 112(c)(3) and 112(k) direct EPA to (1) identify at least 30 air toxics that present the greatest potential health threat in the largest number of urban areas and (2) to identify sufficient area source categories to ensure that sources representing 90 percent or more of the of the emissions of the 30 “listed” HAP are subject to regulation. EPA implements these requirements through the Integrated Urban Air Toxics Strategy (64 FR 38715, July 19, 1999). EPA added Glass Manufacturing and Secondary Nonferrous Metals to the Integrated Urban Air Toxics Strategy area source category list on June 26, 2002 (67 FR 43112) and added Clay Products Manufacturing on November 22, 2002 (67 FR 70428). The Clay Products Manufacturing area source category was later split into the two categories of Brick and Structural Clay Products (BSCP) Manufacturing and Clay Ceramics Manufacturing to better match the categories already scheduled to be regulated by major source NESHAP. The Clay Ceramics Manufacturing area source category is being addressed in the area source rule currently being proposed, while the BSCP Manufacturing area source category will be addressed in a future action. The initial listing of the Clay Ceramics Manufacturing area source category was based on emissions of chromium, manganese, nickel, and lead, while the initial listing of the Glass Manufacturing area source category was based on emissions of arsenic, cadmium, chromium, lead, manganese, and nickel. The initial listing of the Secondary Nonferrous Metals Processing area source category was based on emissions of arsenic, chromium, lead, manganese, mercury, and nickel. Each of these HAP metals is on the list of 30 HAP identified in the 1999 strategy.

Under CAA section 112(d)(5), EPA may elect to promulgate HAP standards for area sources based on the use of generally available control technology (GACT) or management practices used by the sources. EPA can consider costs and economic impacts in determining GACT, which is particularly important when developing regulations for source categories that may have few establishments and many small businesses, or when determining whether additional control is needed for sources that are already well-controlled as a result of other air emissions standards.

Certain records and reports are necessary for the Administrator to confirm the compliance status of area sources, identify any new or reconstructed sources subject to the standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority (State agency or Regional Administrator if there is no delegated State agency) to ensure that the standards and other requirements are being achieved. Based on review of the recorded information at the site and the reported information, the delegated permitting authority can identify facilities that may not be in compliance and decide which facilities, records, or processes may need inspection.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of EPA’s ongoing ICRs revealed no duplication of information-gathering efforts.

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

This section is not applicable because this is a rule-related ICR.

(c) Consultations.

The proposed rules were developed in consultation with individual companies, State agencies, and trade associations. The non-EPA persons consulted on the information collection activities are identified in Table 1.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact

Applicable subpart

Organization

Telephone number

Greg Andrews

Subpart RRRRRR

R.T. Vanderbilt Co., Ceramic Manufacturers of America (CerMA)

(203) 853-1400

Eric Astrachan

Tile Council of North America (TCNA)

(864) 646-8453

Todd Barson

Ferro Corp., CerMA

(216) 750-6432

Mike Cassidy

Kohler Co.

(920) 457-4441, ext. 77263

Bob Hurt

Dal-Tile Corp.

(214) 309-4891

Myra Warne

Society of Glass and Ceramic Decorators, CerMA

(740) 588-9882

Steve Wiederwax

American Marazzi Tile, Inc.

(972) 226-0110

John Brown

Subpart SSSSSS









Glass Manufacturing Industry Council (GMIC)

(614) 818-9423

Marshall Bullard

Automotive Components Holdings


Joe Kane

Corning Inc.

(607) 974-9000

Kurt Kissling

Pepper Hamilton LLP

(313) 393-7313

Patricia Pride

PPG Industries, Inc.

(412) 492-5278

Phil Ross

Glass Packaging Institute (GPI)

(949) 493-7293

Pamela Rygalski

Pilkington NA

(910) 276-5630

Michael Turnbull

Guardian Industries

(248) 340-2227

John Bullock

Subpart TTTTTT

International Precious Metals Institute

(203) 784-3181

Merideth Curren

Pease & Curren, Inc.

(401) 739-6350

Roger Fumey

Atlas Pacific Corporation

(909) 421-1200

Christopher Kiser

Magretech, Inc.

(216) 518-9165

James Mallory

Non-Ferrous Founders’ Society

(847) 299-0950

George Phillips

Sipi Metals Corp.

(773) 276-0070

Charles Tatakis

Metalor Technologies USA Refining Corp.

(508) 699-8800, ext. 224


(d) Effects of Less Frequent Collection.

If the relevant information were collected less frequently, the delegated permitting authority (State or EPA) would not be reasonably assured that a facility is in compliance with the standards.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f) Confidentiality.

All information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart B--Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under proposed Subparts RRRRRR are owners or operators of any existing or new clay ceramics manufacturing facility that is an area source of HAP emissions. The North American Industry Classification System (NAICS) codes for clay ceramics manufacturing are 327111, 327112, and 327122. There are an estimated 51 facilities subject to the NESHAP for the Clay Ceramics Manufacturing area source category; no new clay ceramics area sources are expected during the 3­year period of this ICR.

Potential respondents under proposed Subpart SSSSSS are owners or operators of any existing or new glass manufacturing facility that is an area source of HAP emissions. The NAICS codes for glass manufacturing are 327211, 327212, and 327213. There are an estimated 21 facilities subject to the NESHAP for the Glass Manufacturing area source category; no new glass area sources are expected to be affected sources during the 3­year period of this ICR.

Potential respondents under proposed Subpart TTTTTT are owners or operators of any existing or new secondary nonferrous metals processing facility that is an area source of HAP emissions and emits arsenic, chromium, lead, manganese, or nickel. The NAICS code for secondary nonferrous metals processing is 331492. This area source category was originally established under SIC code 3341, a broader classification which included brass and bronze ingot makers. The corresponding NAICS code for brass and bronze ingot makers is 331423. There are an estimated 10 facilities subject to the NESHAP for the Secondary Nonferrous Metals Processing area source category; no new secondary nonferrous metals area sources are expected during the 3-year period of this ICR.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachments 1A,,1B, and 1C, Information Requirements, summarize the proposed data items, including recordkeeping and reporting requirements, for the Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing area source categories.

(ii) Respondent Activities. The respondent activities required by the proposed Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing rules are identified in Tables 2A, 2B, and 2C and are introduced in section 6(a).

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

(a) Agency Activities.

The Agency activities associated with the proposed Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing rules are provided in Tables 3A, 3B, and 3C and are introduced in section 6(c).

(b) Collection Methodology and Management.

Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authority. The notifications of compliance status and monitoring records required under the proposed rules are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. EPA is the permitting authority until the State agency is delegated authority to implement the final rules. Therefore, information contained in the reports submitted to the Regional Administrator will be entered into the Air Facility System (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.

(c) Small Entity Flexibility.

The Small Business Administration defines a small entity as a firm having no more than 500 to 750 employees for Clay Ceramics Manufacturing, less than 750 to 1,000 employees for Glass Manufacturing, and less than 750 employees for Secondary Nonferrous Metals Processing depending on the size definition for the affected NAICS code. There will not be adverse impacts on any small entities in the Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing area source categories. The proposed Clay Ceramics Manufacturing rule does not create any new requirements or burdens for existing sources other than minimal notification requirements. The proposed Glass Manufacturing rule would require additional costs for 21 glass manufacturing facilities, but only 6 facilities would be required to install control devices and incur costs beyond those associated with annual inspections of control devices; none of these facilities are small businesses. The proposed Secondary Nonferrous Metals Processing rule does not create any new requirements or burdens for existing sources other than minimal notification requirements.

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is shown in Tables 2A, 2B, and 2C for the Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing area source categories.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the proposed Clay Ceramics NESHAP, Glass Manufacturing NESHAP, and Secondary Nonferrous Metals Processing NESHAP are shown in Tables 2A, 2B, and 2C. These numbers were derived from estimates based on EPA’s experience with other standards. No burden estimates are provided for new area sources because no new facilities are expected to become affected sources during the 3­year period of this ICR.

(b) Estimating Respondent Costs.

The information collection activities for the proposed Clay Ceramics NESHAP, Glass Manufacturing NESHAP, and Secondary Nonferrous Metals Processing NESHAP are presented in Tables 2A, 2B, and 2C. Because the data are already collected by respondents as required by the existing permit requirements, no respondent development costs are associated with the information collection activities.

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private industry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, December 2005, “Table 2. Civilian Workers, by occupational and industry group” available at http://www.bls.gov/news.release/ecec.t02.htm. Wages for occupational groups are used as the basis for the labor rates with a total compensation of $41.89/hour for technical, $48.09/hour for managerial, and $20.86/hour for clerical. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $87.98, management at $100.98, and clerical at $43.80.

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. Although the proposed Clay Ceramics NESHAP includes requirements for facilities to install and operate new control devices, HVLP spray equipment, and monitoring systems, it has been determined that existing clay ceramics facilities are already in compliance with the requirements of the proposed NESHAP. Capital and O&M costs were not estimated for new sources because no new sources are expected during the next 3-year period. Therefore, no (zero) capital and O&M costs are associated with the proposed Clay Ceramics NESHAP during the 3-year period of this ICR.

The capital costs associated with the information collection requirements of the proposed Glass Manufacturing NESHAP would include the costs to purchase and install monitoring systems, conduct performance tests, and purchase file cabinets for keeping records. Monitoring systems would need to be installed on six existing furnaces that would be subject to the rule and would require emission controls to meet the emission limits. We estimate that four of the new control systems would be electrostatic precipitators (ESPs) and would require systems to monitor secondary voltage and electrical current to each field of the ESP. We estimate that fabric filters would be installed on the other two existing furnaces that would need emission controls to meet the standard; for the fabric filters, systems for monitoring inlet temperature would be required. The proposed rule would require a one-time performance test on each affected furnace. However, this requirement would be waived if the furnace had been tested within the previous 5 years, and the test demonstrated compliance with the emission limit in the proposed Glass Manufacturing Area Source NESHAP. We assumed that performance tests would be required on 15 of the 27 affected existing furnaces. The O&M costs associated with the proposed Glass Manufacturing NESHAP include the costs of conducting annual inspections of control systems on affected sources. It is assumed that these control device inspections would be conducted on each of the 27 affected furnaces annually. The average annual O&M/Capital costs described above total $32,003.

Although the proposed Secondary Nonferrous Metals Processing NESHAP includes requirements for facilities to install and operate new capture devices, control devices, and monitoring systems, it has been determined that existing secondary nonferrous metals facilities are already in compliance with the requirements of the proposed NESHAP. Capital and O&M costs were not estimated for new sources because no new sources are expected during the next 3-year period. Therefore, no (zero) capital and O&M costs are associated with the proposed Secondary Nonferrous Metals Processing NESHAP during the 3-year period of this ICR.

(iii) Annualizing Capital Costs. No capital costs are associated with the proposed Clay Ceramics NESHAP or the proposed Secondary Nonferrous Metals Processing NESHAP. Therefore, no (zero) annualized capital costs are associated with the proposed Clay Ceramics NESHAP or the proposed Secondary Nonferrous Metals Processing NESHAP during the 3-year period of this ICR. For the proposed Glass Manufacturing NESHAP, the annualized capital costs include the costs for monitoring systems, performance tests, and file cabinets.

(c) Estimating Agency Burden and Cost.

Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 63 NESHAP General Provisions, no operational costs would be incurred by the Federal Government. Publication and distribution of the information are part of the Compliance Data System, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sources that is part of EPA’s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs that the Federal government would incur are user costs associated with the analysis of the reported information, as presented in Tables 3A,3B, and 3C for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing.

The Agency labor rates are from the Office of Personnel Management (OPM) 2006 General Schedule which excludes locality rates of pay. These rates can be obtained from Salary Table 2006-GS available on the OPM website, http://www.opm.gov/oca/06tables/html/gs_h.asp. The government employee labor rates are $14.35/hour for clerical (GS-6, Step 3), $26.53 for technical (GS-12, Step 1), and $35.75/hr for management (GS-13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates used to represent Agency labor costs are: clerical at $22.96; technical at $42.45, and management at $57.20.

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

There are an estimated 51 existing facilities subject to the Clay Ceramics Manufacturing area source NESHAP. No new sources are expected during the next 3 years. Consequently, the average number of Clay Ceramics respondents during the 3-year period of this ICR is 17. There are an estimated 21 existing glass manufacturing area source facilities that would be subject to the proposed rule, and none of the new glass manufacturing facilities expected to begin operations during the next 3 years are expected to be subject to the rule. Therefore, the average number of Glass Manufacturing respondents during the 3-year period of this ICR is seven. There are an estimated 10 existing facilities subject to the Secondary Nonferrous Metals Processing area source NESHAP. No new sources are expected during the next 3 years. Consequently, the average number of Secondary Nonferrous Metals respondents during the 3-year period is 3.

The only components of the total annual responses attributable to this ICR for the Clay Ceramics NESHAP and the Secondary Nonferrous Metals Processing NESHAP are one-time initial notifications of applicability and compliance status for each existing facility. For the proposed Glass Manufacturing NESHAP, the components of the total annual responses attributable to this ICR are one-time initial notifications and one-time notifications of compliance status for the 21 facilities that would be subject to the rule.

The number of total annual responses for proposed subpart RRRRRR is estimated as: 34 (17 annual average respondents × 2 notifications). The number of total annual responses for proposed subpart SSSSSS is estimated as: 14 (7 annual average respondents for initial notifications + 7 annual average respondents for notifications of compliance status). The number of total annual responses for proposed subpart TTTTTT is estimated as: 6 (3 annual average respondents × 2 notifications).

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in Tables 2A, 2B, and 2C are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column.

The average annual burden for the monitoring, recordkeeping, and reporting requirements in proposed subpart RRRRRR for the 51 existing facilities subject to the Clay Ceramics Manufacturing area source NESHAP is 196 person-hours, with an annual average cost of $16,560 and no capital and O&M costs.

The average annual burden for the monitoring, recordkeeping, and reporting requirements in proposed subpart SSSSSS for the 21 existing glass manufacturing area sources is 1,072 person-hours, with an annual average cost of $90,790 and capital and O&M costs of $32,003.

The average annual burden for the monitoring, recordkeeping, and reporting requirements in proposed part TTTTTT for the 10 existing facilities subject to the Secondary Nonferrous Metals Processing area source NESHAP is 15 person-hours, with an annual average cost of $1,299 and no capital and O&M costs.

The total annual burden for the three source categories is 1,283 hours at $108,649, with capital and O&M costs of $32,003.

(ii) The Agency tally. The average annual Federal Government cost is $4,856 for 117 hours for proposed subpart RRRRRR, $3,261 for 67 hours for proposed subpart SSSSSS, and $318 for 7 hours for proposed subpart TTTTTT. The total annual Federal Government cost associated with the three proposed rules is $8,435 for 191 total annual hours. The bottom line Agency burden hours and costs presented in Tables 3A, 3B, and 3C for the three proposed rules are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column.

(iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated.

(f) Reasons for Change in Burden.

This section does not apply because this is a new ICR.

(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 6 hours per response for clay ceramics manufacturing area sources, 77 hours per response for glass manufacturing area sources, and 3 hours per response secondary nonferrous metals processing area sources.

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 currently valid OMB control number. The OMB control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

To comment on the Agency’s need for this information the accuracy of the provided burden estimates, and any suggestions for minimizing respondent burden, including through the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Nos. EPA-HQ-OAR-2006-0424 (Clay Ceramics), EPA-HQ-OAR-2006-0360 (Glass), and EPA-HQ-OAR-2005-0116 (Secondary Nonferrous Metals) which are available for online viewing at http://www.regulations.gov, or in person viewing at the Air and Radiation 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 Air Docket is (202) 566-1927. An electronic version of the public docket is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in one of the Docket ID Numbers identified above. 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 relevant Docket ID Number (EPA-HQ-OAR-2006-0424, EPA-HQ-OAR-2006-0360, or EPA-HQ-OAR-2005-0116) and OMB Control Number 2060-NEW in any correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection associated with the proposed rules.

TABLE 2A. ANNUAL RESPONDENT BURDEN AND COST--NESHAP FOR CLAY CERAMICS MANUFACTURING AREA SOURCES

Burden item

(A) Person-hours per occurrence

(B) No. of occurrences per respondent

(C) Person-hours per respondent (C=A*B)

(D) Respondents per yeara

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

(F) Management person-hours per year

(E*0.05)

(G) Clerical person-hours per year (E*0.1)

(H) Costb, $

1. Applications

N/A








2. Surveys and Studies

N/A








3. Acquisition, Installation, and Utilization of Technology

and Systems

N/A








4. Reporting Requirements









A. Read instructions

4

1

4

17

68

3.4

6.8

$6,624

B. Required activities









Initial notification of applicability

2

1

2

17

34

1.7

3.4

$3,312

Notification of compliance status

4

1

4

17

68

3.4

6.8

$6,624

C. Create information

See 4B








D. Gather existing information

See 4B








E. Write report

See 4B








5. Recordkeeping Requirements









A. Read instructions

See 4A








B. Plan activities

See 4A








C. Implement activities

See 4A








D. Record datac

N/A








E. Time to transmit or disclose informationc

N/A








F. Time to train personnelc

N/A








G. Time for auditsc

N/A








TOTAL LABOR BURDEN AND COST


196 hours

$16,560

N/A = not applicable.

a There are an estimated 51 existing clay ceramics facilities subject to the area source NESHAP. No new sources are projected during the 3-year term of this ICR. Therefore, the average number of respondents per year is 17 (51÷3=17).

b This ICR uses the following labor rates: $100.98 for managerial labor, $87.98 for technical labor, and $43.80 for clerical labor. These rates are from the U.S. 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% to account for the benefit packages available to those employed by private industry.

c No hours or costs are associated with this item because the rule imposes no additional burden for that item.

TABLE 2B. ANNUAL RESPONDENT BURDEN AND COST--NESHAP FOR GLASS MANUFACTURING AREA SOURCES

Burden item

(A) Person-hours per occurrence

(B) No. of occurrences per respondent

(C) Person-hours per respondent (C=A*B)

(D) Respondents per year

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

(F) Management person-hours per year

(E*0.05)

(G) Clerical person-hours per year (E*0.1)

(H) Cost, $a


1. Applications

N/A









2. Surveys and Studies

N/A









3. Acquis., Install., and Util. of Technology and Systems

N/A









4. Reporting Requirements










A. Read instructionsb

2

1

2.0

7.0

14.0

0.7

1.4

$1,364


B. Required activities










Initial notification of applicabilityc

2

1

2.0

7.0

14.0

0.7

1.4

$1,364


Notification of compliance statusd

4

1

4.0

7.0

28.0

1.4

2.8

$2,727




C. Create information

See 4B









D. Gather existing information

See 4B









E. Write report

See 4B









5. Recordkeeping Requirements










A. Read instructionse

2

1

2.0

7.0

14.0

0.7

1.4

$1,364


B. Plan activities

See 5E









C. Implement activities

See 5E









D. Record dataf

0.1

1,095

109.5

7.0

766.5

38.3

76.7

$74,664


E. Time to transmit or disclose informationg

0.25

3.3

0.8

14.0

11.6

0.6

1.2

$1,125

1

2.0

7.0

14.0

0.7

1.4

$1,364

F. Time to train personnelh

12

1

12.0

7.0

84.0

4.2

8.4

$8,182


G. Time for audits

N/A









TOTAL LABOR BURDEN AND COST


1,072 hours

$90,790


TOTAL NUMBER OF ANNUAL RESPONSESi

14



ANNUAL CAPITAL COSTS




Performance testsj


$43,700


Monitoring equipmentk


$15,173


File cabinetsl


$1,645


Total annual capital


$60,518


ANNUALIZED CAPITAL COSTSm




Performance tests (5 yr life, 7% interest; CRF =0.2439)


$10,658


Monitoring equipment 10 yr life, 7% interest; CRF =0.1424)


$2,160


File cabinets (15 yr life, 7% interest; CRF =0.1098)


$181


Total annualized capital


$12,999


TOTAL ANNUAL COSTS (O&M)n


$19,004


TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs)


$32,003


N/A = not applicable.

a This ICR uses the following labor rates: $100.98 for managerial labor, $87.98 for technical labor, and $43.80 for clerical labor. These rates are from the U.S. 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% to account for the benefit packages available to those employed by private industry.

b There are an estimated 21 existing glass manufacturing facilities that use HAP metals and no new facilities are expected; the average number expected to read the rule during the 3-yr ICR clearance period is 21/3 = 7.

c Each of the 21 existing noted above would be required to submit an Initial Notification.

d The estimated 21 existing plants that use HAP compounds as raw materials and would be required to submit Notifications of Compliance Status, for an average of 21/3 = 7 per year for the 3-yr ICR compliance period.

e The estimated 21 existing plants would be required to keep records of the notifications and other records, or an average of 21/3 = 7 per year during the 3-yr ICR compliance period.

f For each of the 27 affected furnaces, temperature or current and voltage would be recorded once every 8-hr shift, 365 days per year, or 3x365= 1,095 occurrences per year; it is assumed that 20 of the furnaces have automatic recording systems and records would be recorded manually for 7 of the furnaces.

g Transmittals would include Initial Notifications for 21 plants and Notifications of Compliance Status for 21 plants, for an average of (21+21)/3 = 14 for each year of the 3-yr ICR clearance period.

h Training would be required for one person at each of the 21 affected plants or an average of 21/3=7 per year over the3-yr clearance period.

i The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 4E.

j Assumes emission tests would be conducted on 5 furnace control systems or 5/3 = 1.7 affected sources per year using Method 5 at an average cost of $8,740 per test.

k Monitoring equipment would be needed for the 6 new emission control systems: 4 systems for monitoring ESP voltage and current at $9,570 per system, and 2 systems for monitoring fabric filter inlet temperature at $3,620 per system; an average of 2 systems would be installed per year during the 3-yr ICR clearance period.

l Assumes one standard four-drawer file cabinet for each of the 21 facilities, or an average of 21/3=7 per year required to maintain records at a cost of $235 per cabinet.

m Annualized costs are calculated by multiplying the capital recovery factor (CRF) by the capital cost. CRF=(i)*(1+i)^t/((1+i)^t-1) where i = interest rate (%) and t = equipment life (years).

n Costs of annual inspections of control device, assuming 8 hr per inspection for each of the 27 affected furnaces.


















TABLE 2C. ANNUAL RESPONDENT BURDEN AND COST--NESHAP FOR SECONDARY NONFERROUS METALS PROCESSING AREA SOURCES

Burden item

(A) Person-hours per occurrence

(B) No. of occurrences per respondent

(C) Person-hours per respondent (C=A*B)

(D) Respondents per yeara

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

(F) Management person-hours per year

(E*0.05)

(G) Clerical person-hours per year (E*0.1)

(H) Costb, $

1. Applications

N/A








2. Surveys and Studies

N/A








3. Acquisition, Installation, and Utilization of Technology

and Systems

N/A








4. Reporting Requirements









A. Read instructions

2

1

2

3

7

0.3

0.7

$649

B. Required activities









Initial notification of applicability

1

1

1

3

3

0.2

0.3

$325

Notification of compliance status

1

1

1

3

3

0.2

0.3

$325

C. Create information

See 4B








D. Gather existing information

See 4B








E. Write report

See 4B








5. Recordkeeping Requirements









A. Read instructions

See 4A








B. Plan activities

See 4A








C. Implement activities

See 4A








D. Record datac

N/A








E. Time to transmit or disclose informationc

N/A








F. Time to train personnelc

N/A








G. Time for auditsc

N/A








TOTAL LABOR BURDEN AND COST


15 hours

$1,299

N/A = not applicable.

a There are an estimated 10 existing secondary nonferrous metals processing facilities subject to the area source NESHAP. No new sources are projected during the 3-year term of this ICR. Therefore, the average number of respondents per year is 3 (10÷3=3).

b This ICR uses the following labor rates: $100.98 for managerial labor, $87.98 for technical labor, and $43.80 for clerical labor. These rates are from the U.S. 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% to account for the benefit packages available to those employed by private industry.

c No hours or costs are associated with this item because the rule imposes no additional burden for that item.

TABLE 3A. ANNUAL BURDEN AND COST TO THE AGENCY--NESHAP FOR CLAY CERAMICS MANUFACTURING AREA SOURCES

Burden item

(A) Person-hours per occurrence

(B) Occurrences per respondent

(C) Facilities per year a

(D) Technical person-hours/year (D=A*B*C)

(E) Management person-hours/year (E=0.05*D)

(F) Clerical person-hours/year (F=0.1*D)

(G) Costb, $

Report Review:








Initial notification of applicability

2

1

17

34

1.7

3.4

$1,619

Notification of compliance status

4

1

17

68

3.4

6.8

$3,237

TOTAL BURDEN AND COST




117 hours

$4,856

a There are an estimated 51 existing clay ceramics manufacturing facilities subject to the area source NESHAP. No new sources are projected during the 3-year term of this ICR. Therefore, the average number of respondents per year is 17 (51÷3=17). No travel is expected.

b This ICR uses the following average hourly labor rates: $57.20 for managerial (GS-13, Step 5, $35.75 x 1.6), $42.45 (GS-12, Step 1, $26.53 x 1.6) for technical and $22.96 (GS-6, Step 3, $14.35 x 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) 2006 General Schedule, which excludes locality rates of pay.

TABLE 3B. ANNUAL BURDEN AND COST TO THE AGENCY--NESHAP FOR GLASS MANUFACTURING AREA SOURCES

Burden item

(A) Person-hours per occurrence

(B) Occurrences per respondent

(C) EPA person-hours/year (C=A*B)

(D) Facilities per year

(E) Technical person-hours/year (E=C*D)

(F) Management person-hours/year (F=0.05*E)

(G) Clerical person-hours/year (G=0.1*E)

(H) Costa, $

Attend performance testb

16

1

16.0

1.0

16.0

0.8

1.6

$762

Report Review:









Initial notification of applicabilityc

2

1

2.0

7.0

14.0

0.7

1.4

$666

Notification of performance testd









Notification of compliance statuse

4

1

4.0

7.0

28.0

1.4

2.8

$1,333

TOTAL BURDEN AND COST (SALARY)





58.0

2.9

5.8

$2,761

Travel expenses for tests attendedf


$500

TOTAL BURDEN AND COST


67 hours

$3,261

a This ICR uses the following average hourly labor rates: $57.20 for managerial (GS-13, Step 5, $35.75 x 1.6), $42.45 (GS-12, Step 1, $26.53 x 1.6) for technical and $22.96 (GS‑6, Step 3, $14.35 x 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) 2006 General Schedule, which excludes locality rates of pay.

b Assumes Agency personnel will attend the performance test for one affected source per year.

c Assumes 21 existing and no new plants will complete Initial Notifications for an average of 21/3 = 7 per year during each year of the 3-yr ICR clearance period.

d Not required

e Assumes 21 existing facilities will submit Notifications of Compliance Status for an average of 21/3 = 7 per year of the 3-yr ICR clearance period.

f Assumes Agency personnel (1 person) will spend 2 days per plant, at $50 per diem per day, and $400 transportation expense per round trip to attend performance tests.




















TABLE 3C. ANNUAL BURDEN AND COST TO THE AGENCY--NESHAP FOR SECONDARY NONFERROUS METALS PROCESSING AREA SOURCES

Burden item

(A) Person-hours per occurrence

(B) Occurrences per respondent

(C) Facilities per year a

(D) Technical person-hours/year (D=A*B*C)

(E) Management person-hours/year (E=0.05*D)

(F) Clerical person-hours/year (F=0.1*D)

(G) Costb, $

Report Review:








Initial notification of applicability

1

1

3

3

0.2

0.3

$159

Notification of compliance status

1

1

3

3

0.2

0.3

$159

TOTAL BURDEN AND COST




7 hours

$318

a There are an estimated 10 existing secondary nonferrous metals processing facilities subject to the area source NESHAP. No new sources are projected during the 3-year term of this ICR. Therefore, the average number of respondents per year is 3 (10÷3=3). No travel is expected.

b This ICR uses the following average hourly labor rates: $57.20 for managerial (GS-13, Step 5, $35.75 x 1.6), $42.45 (GS-12, Step 1, $26.53 x 1.6) for technical and $22.96 (GS-6, Step 3, $14.35 x 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) 2006 General Schedule, which excludes locality rates of pay.

ATTACHMENT 1A. INFORMATION REQUIREMENTS--NESHAP FOR CLAY CERAMICS MANUFACTURING AREA SOURCES

Requirement

Citation for existing sources

Citation for new sources

General Provisions citation

Monitoring




Kiln peak temperature

§63.11440(a)

§63.11440(a)

NA

APCD parameter check

NA

§63.11440(b)(1)

NA

Visible emissions test

NA

§63.11440(b)(2)

NA

APCD inspection

§63.11440(c)(1)

NA

NA

Alternative monitoring technique

Table 1 to subpart RRRRRR / §63.11440(c)(2)

Table 1 to subpart RRRRRR / §63.11440(b)(3)

40 CFR 63.8(f)

Notifications




Notification of applicability

Table 1 to subpart RRRRRR / §63.11442(a)

Table 1 to subpart RRRRRR / §63.11442(a)

40 CFR 63.9(a)(2)

Notification of construction/reconstruction

NA

NA

40 CFR 63.9(b)(5)

Notification of special compliance requirements

Table 1 to subpart RRRRRR

Table 1 to subpart RRRRRR

40 CFR 63.9(d)

Notification of performance test

NA

NA

40 CFR 63.9(e)

Notification of opacity/VE observations

NA

NA

40 CFR 63.9(f)

Additional CMS notifications

NA

NA

40 CFR 63.9(g)

Notification of compliance status

Table 1 to subpart RRRRRR / §63.11442(b)

Table 1 to subpart RRRRRR / §63.11442(b)

40 CFR 63.9(h)

Notification of changes in information

Table 1 to subpart RRRRRR

Table 1 to subpart RRRRRR

40 CFR 63.9(j)

Plans




SSM plan

NA

NA

40 CFR 63.6(e)(3)

Performance test plan

NA

NA

40 CFR 63.7(c)(2)

CMS quality control plan

NA

NA

40 CFR 63.8(d)

CMS performance evaluation test plan

NA

NA

40 CFR 63.8(e)(3)

Records




Records of notifications

Table 1 to subpart RRRRRR / 63.11443(a)(1)

Table 1 to subpart RRRRRR / 63.11443(a)(1)

40 CFR 63.10

Monitoring/inspection information

Table 1 to subpart RRRRRR / 63.11443(a)(2)

Table 1 to subpart RRRRRR / 63.11443(a)(2)

40 CFR 63.10

Reports




Reports of deviation

NA

NA

NA

Semiannual monitoring reports

NA

NA

NA

Initial/repeat performance tests

NA

NA

40 CFR 63.7(e)(1) /

40 CFR 63.6(h)(7)

Quality assurance test plan

NA

NA

40 CFR 63.7(c)

CMS performance evaluation/report

NA

NA

40 CFR 63.8(e)(5)

SSM reports

NA

NA

40 CFR 63.6(e)(3)

Excess emissions reports

NA

NA

40 CFR 63.10(e)(3)


ATTACHMENT 1B. INFORMATION REQUIREMENTS--NESHAP FOR GLASS MANUFACTURING AREA SOURCES

Requirement

Citation for existing sources

Citation for new sources

Part 63 General Provisions citation

Monitoring




Furnace ESP secondary voltage and current

§63.11454(b)

§63.11454(d)

N/A

Furnace fabric filter inlet temperature

§63.11454(c)

§63.11454(e)

N/A

Notifications




Notification of applicability

§63.11456(a)

§63.11456(a)

40 CFR 63.9(b)

Notification of construction/reconstruction

N/A

N/A

40 CFR 63.9(b)(5)

Notification of special compliance requirements

N/A

N/A

40 CFR 63.9(d)

Notification of performance test

N/A

N/A

40 CFR 63.9(e)

Notification of opacity/VE observations

N/A

N/A

40 CFR 63.9(f)

Additional CMS notifications

N/A

N/A

40 CFR 63.9(g)

Notification of compliance status

§63.11456(b)

§63.11456(b)

40 CFR 63.9(h)

Notification of changes in information

N/A

N/A

40 CFR 63.9(j)

Plans




SSM plan

N/A

N/A

40 CFR 63.6(e)(3)

Performance test plan

N/A

N/A

40 CFR 63.7(c)(2)

CMS quality control plan

N/A

N/A

40 CFR 63.8(d)

CMS performance evaluation test plan

N/A

N/A

40 CFR 63.8(e)(3)

Records




Records of notifications

§63.11457(a)(1)

§63.11457(a)(1)

40 CFR 63.10

Records of startups, shutdowns and malfunctions

§63.11457(a)(2)

§63.11457(a)(2)

40 CFR 63.10

Records that demonstrate continuous compliance

§63.11457(a)(4)

§63.11457(a)(4)

40 CFR 63.10

Records of glass production

§63.11457(a)(5)

§63.11457(a)(5)

40 CFR 63.10

Monitoring/inspection information

§63.11457(a)(6) - (9)

§63.11457(a)(6) - (9)

40 CFR 63.10

Reports




Reports of deviation

N/A

N/A

N/A

Semiannual monitoring reports

N/A

N/A

N/A

Initial/repeat performance tests

N/A

N/A

40 CFR 63.7(e)(1) /

40 CFR 63.6(h)(7)

Quality assurance test plan

N/A

N/A

40 CFR 63.7(c)

CMS performance evaluation/report

N/A

N/A

40 CFR 63.8(e)(5)

SSM reports

N/A

N/A

40 CFR 63.6(e)(3)

Excess emissions reports

N/A

N/A

40 CFR 63.10(e)(3)








ATTACHMENT 1C. INFORMATION REQUIREMENTS--NESHAP FOR SECONDARY NONFERROUS METALS PROCESSING AREA SOURCES

Requirement

Citation for existing sources

Citation for new sources

General Provisions citation

Monitoring




Visual inspection of capture device

§63.11466(a)

§63.11466(a)

NA

Visible emissions check

§63.11466(b)

NA

NA

Visual bag inspection

§63.11466(b)

NA

NA

Bag leak detection system

NA

§63.11466(c)

NA

Notifications




Notification of applicability

Table 1 to subpart TTTTTT / §63.11469(a)

Table 1 to subpart TTTTTT / §63.11469(a)

40 CFR 63.9(a)(2)

Notification of construction/reconstruction

NA

NA

40 CFR 63.9(b)(5)

Notification of special compliance requirements

Table 1 to subpart TTTTTT

Table 1 to subpart TTTTTT

40 CFR 63.9(d)

Notification of performance test

NA

NA

40 CFR 63.9(e)

Notification of opacity/VE observations

NA

NA

40 CFR 63.9(f)

Additional CMS notifications

NA

NA

40 CFR 63.9(g)

Notification of compliance status

Table 1 to subpart TTTTTT / §63.11469(b)

Table 1 to subpart TTTTTT / §63.11469(b)

40 CFR 63.9(h)

Notification of changes in information

Table 1 to subpart TTTTTT

Table 1 to subpart TTTTTT

40 CFR 63.9(j)

Plans




SSM plan

NA

NA

40 CFR 63.6(e)(3)

Performance test plan

NA

NA

40 CFR 63.7(c)(2)

CMS quality control plan

NA

NA

40 CFR 63.8(d)

CMS performance evaluation test plan

NA

NA

40 CFR 63.8(e)(3)

Records




Records of notifications

Table 1 to subpart TTTTTT / §63.11470(a)(1)

Table 1 to subpart TTTTTT / §63.11470(a)(1)

40 CFR 63.10

Monitoring/inspection information

Table 1 to subpart TTTTTT / §63.11470(a)(2)

Table 1 to subpart TTTTTT / §63.11470(a)(2)

40 CFR 63.10

Reports




Reports of deviation

NA

NA

NA

Semiannual monitoring reports

NA

NA

NA

Initial/repeat performance tests

NA

NA

40 CFR 63.7(e)(1) /

40 CFR 63.6(h)(7)

Quality assurance test plan

NA

NA

40 CFR 63.7(c)

CMS performance evaluation/report

NA

NA

40 CFR 63.8(e)(5)

SSM reports

NA

NA

40 CFR 63.6(e)(3)

Excess emissions reports

NA

NA

40 CFR 63.10(e)(3)


15


File Typeapplication/msword
File TitleSUPPORTING STATEMENT
AuthorMarvin Branscome
Last Modified Byckerwin
File Modified2007-08-03
File Created2007-08-03

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