1856ss10

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal), EPA ICR Number 1856.10, OMB Control Number 2060-0414.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Primary Lead Smelters were proposed on April 17, 1998, promulgated on June 4, 1999, and amended on November 15, 2011. This amendment updates requirements to reduce the risks associated with this source category to acceptable levels, by adjusting the cap to 1.2 tons per year (TPY) for the furnace area stack and refining operations stacks and by updating work practice standards to minimize fugitive dust emissions. Additionally, this amendment eliminates the SSM exemption, updates the language in the regulation, and requires stack testing for lead compounds on a quarterly basis. These regulations apply to existing and new facilities engaged in producing lead metal from ore concentrates. The category includes, but is not limited to, the following smelting processes: Sintering, reduction, preliminary treatment, refining and casting operations, process fugitive sources, and fugitive dust sources. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart TTT.

In general, all NESHAP 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. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.

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

Over the next three years, we don’t expect an existing respondent to be subject to the rule. However, we calculated the burden for implementation of the rule, which is still effective, based on the assumption of an average of one respondent per year. We also assumed that no additional respondents per year will become subject to the standard. We expect that if a new primary lead smelting is built in the future it would meet NSPS Subpart TTT applicability and become subject to this rule.

The Office of Management and Budget (OMB) approved the currently active ICR without any ‘Terms of Clearance.”

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

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

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

In the Administrator's judgment, HAP emissions from facilities engaged in primary lead processing cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart TTT.

2(b) Practical Utility/Users of the Data

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

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

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

The required quarterly 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

3(a) Nonduplication

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

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

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this ICR, we contacted both the Doe Run Company at (314) 453-7100 and the Missouri Department of Natural Resources at (800) 361-4827.

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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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 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 (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 or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities engaged in primary lead processing. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 3339, which corresponds to the North American Industry Classification System (NAICS) 331410 for Lead Smelting and Refining, Primary.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT).

A source must make the following reports:

Notifications
Initial notification requirements	63.9(b)(1)
Notification of compliance status when a source becomes subject to the standard	63.9(h)
Notification that source is subject to special compliance requirements, if applicable	63.9(d)
Notification of performance test	63.7(b), 63.9(e)
Rescheduled of performance test	63.7(b)(2)
Demonstration of continuous monitoring system	63.9(g)
Change in information already provided	63.9(j)
Request for an extension of compliance with relevant standard	63.9(c)

Reports
Application for approval of the construction or reconstruction of a new major affected source, or reconstruction of a major affected source	63.5(6)(d)
Performance test results	63.10(d)(2)
Report of opacity and visible emission observations	63.9(f)
Startup, shutdown and malfunction plan	63.6(e)(3)
Periodic startup, shutdown and malfunction reports	63.10(d)(5)(i)
Notification of compliance status	63.9(h)
SOP for baghouses and fugitive dust control	63.1548(b)
Progress reports for compliance extension (if applicable)	63.6(i)
Report of quarterly compliance tests	63.1546 (a)
Semiannual reports	63.1549(e)

A source must keep the following records:

Recordkeeping
Startup, shutdown and malfunction plan	63.6(e)(3)
All reports and notifications	63.10(b)(1)
Records of startup, shut-down, and malfunction of process equipment	63.10(b)(2)(i), (iv), (v)
Records of malfunctions of air pollution control equipment	63.10(b)(2)(ii)
Any applicability determination that demonstrates why owner or operator believes source(s) is/are unaffected	63.10(b)(3)
Records of maintenance of air pollution control equipment	63.10(b)(2)(iii)
Records of flow monitoring system performance evaluations, malfunctions, calibrations, and adjustments	63.10(b)(2)(vi), (vii), (viii), (ix), (x), (xi), 63.10(c)
Documentation required for waiver of recordkeeping or reporting requirements (if applicable)	63.10(b)(2)(xii)
Documentation of initial notifications	63.10(b)(2)(xiv)
Production records of the weight and lead content of unrefined lead, copper matte, and copper speiss	63.1549(b)(1)
Records of bag leak detection system output	63.1549(b)(2)
Records of bag leak detection system alarms and corrective actions	63.1549(b)(3)
Records of fugitive dust control activities	63.1549(b)(4)
Records of baghouse inspections and maintenance	63.1549(b)(5)
Records of doorway in-draft checks	63.1549(b)(6)
Records of flow monitoring system output (if applicable)	63.1549(b)(7)
Records of damper position checks (if applicable)	63.1549(b)(8)
Five-year retention of records	63.10(b)(1), 63.1549(b)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a 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 lead, opacity, or for pressure drop and liquid supply pressure for baghouse or equivalent control device.

Perform initial performance test, Reference Method 1; 2, 2F, 2G; 3, 3A, 3B; 4; 12 or 29 tests, 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.

Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring system. 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.

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

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 Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance. OTIS 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 OTIS 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

There are no small businesses, as defined by the Small Business Administration (SBA), affected by this regulation. The SBA defines a small entity engaging in primary lead processing operations as a firm having no more than 500 to 1,000 employees (depending on the size definition for the affected NAICS code). The sole facility subject to the rule does not meet the definition of a small entity.

5(d) Collection Schedule

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

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 6,265 (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 $128.02 ($60.98 + 110%)

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. In a new primary lead smelting facility becomes subject to the rule, the rule requires the installation of a lead continuous emission monitor once EPA has approved the CEMS specifications. Since the Agency has not approve the specification yet and a new facility is not foreseen in the near future, we are unable to come up with capital/startup cost and operation and maintenance cost estimate at this time. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

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

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&M1	(G) Total O&M, (E X F)
Bag Leak detection system - continuous particulate matter sensor	$10,500	0	$0	$6,500	1	$6,500
Flow monitors with high/low alarms	$6,500	0	$0	$6,500	1	$6,500
Method 12 Performance Tests2	N/A			$156,000	1	$156,000
TOTAL			$0			$169,000

¹Assumption: $500 per year per monitoring system per baghouse; we assume the respondent has 13 baghouses.

²Assumption: $13,000 per test per stack, 12 tests per year across 3 stacks.

The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $169,000. 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 $169,000.

6(c) Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is estimated to be $2,826.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (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 one existing respondent 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 one per year.

The number of respondents is calculated using the following table that 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.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is one.

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
Quarterly Reports	1	4	0	4
Semiannual Reports	1	2	0	2
			Total	6

The number of Total Annual Responses is 6.

The total annual labor costs are $613,379. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (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 hours are 6,265. Details regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,044 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $169,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 0 labor hours at a cost of $2,826. See Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal).

6(f) Reasons for Change in Burden

There is an overall decrease in the respondent and Agency burden and cost from the OMB Inventory of Approved Burdens. The currently approved burden is the cumulative burden and cost from EPA ICR Number 1856.06 (existing rule) and EPA ICR Number 1856.08 (2011 amendment). In this ICR renewal, we have combined the two ICRs to reflect current rule requirements and removed duplicate items. In addition, this ICR renewal reflects a decrease in the number of respondents from two to one since EPA ICR Number 1856.06. We have assumed that there are an estimated one respondent subject to NSPS Subpart TTT since rule is still in effect. These changes result in an apparent decrease in labor hours and costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1,044 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-2014-0068. 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-2014-0068 and OMB Control Number 2060-0414 in any correspondence.

Part B of the Supporting Statement

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

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

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Read instructions	2	1	2	0	0	0	0	$0
B. Required activities:
i. Initial Performance tests: c	8	1	8	0	0	0	0	$0
ii. Monitoring of operations and equipment: d
- Implement baghouses SOP	13.4	365	4,891	1	4,891	244.55	489.1	$550,667.91
- Quarterly compliance stack tests for lead compounds
Main stack	8	4	32	1	32	1.6	3.2	$3,602.82
Furnace area stack	8	4	32	1	32	1.6	3.2	$3,602.82
Refining building stack	8	4	32	1	32	1.6	3.2	$3,602.82
D. Gather Existing Information	See 4B and 5E
E. Write report a, c
i. Notification of compliance status	2	1	2	0	0	0	0	$0
ii. Notification of actual startup	2	1	2	0	0	0	0	$0
iii. Notification of construction/ reconstruction a	2	1	2	0	0	0	0	$0
iv. Notification of Performance Test	2	1	2	0	0	0	0	$0
v. Notification of actual startup	2	1	2	0	0	0	0	$0
vi. Reports of performancetest results	4	1	4	0	0	0	0	$0
vii. Operation and maintenance reports	10	1	10	0	0	0	0	$0
viii. Semi-annual reports e	16	2	32	1	32	1.6	3.2	$3,602.82
ix. Notification of physical/operational changes f	2	1	2	0	0	0	0	$0
x. Submit quarterly reports	16	4	64	1	64	3.2	6.4	$7,205.63
Subtotal for Reporting Requirements					5,845			$572,284.80
5. Recordkeeping Requirements
A. Read instructions	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system	N/A
E. Time to enter and transmit information:	1	365	365	1	365	18.25	36.5	$41,094.62
- Records of operating parameters
- Records of compliance inspections
- Records of performance tests
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					420			$41,094.62
TOTAL LABOR BURDEN AND COST
(rounded):					6,265			$613,379

Assumptions:

^a We have assumed that there are an estimated one respondent which is subject to NSPS Subpart TTT since it is still in effect. We have assumed that there will be no new net growth for this industry over the three year period of this ICR.

^b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.

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

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

^e We have assumed that sources are continuing to submit semiannual reports.

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

Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal)

Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Initial notification	2	1	2	0	0	0	0	$0
Notification of performance test	0.5	4	2	1	2	0.1	0.2	$104.68
Notification of physical or Operational changes c	4	1	4	0	0	0	0	$0
Semi-annual reports	10	2	20	1	20	1	2	$1,046.80
Review quarterly test results	8	4	32	1	32	1.6	3.2	$1,674.88
TOTAL ANNUAL BURDEN AND COST
(rounded):					62			$2,826

Assumptions:

^a We have assumed that there is approximately one respondents currently operating in the United States since the NSPS Subpart TTT rule is still in effect. It is estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector.

^b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.90, Technical rate of $46.67, and Clerical rate of $25.25. These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay.

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