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ATTACHMENT 1
SUPPORTING STATEMENT
New Source Performance Standards for Secondary Lead Smelters (40 CFR
TABLES 1, 2, and 3
Annual Respondent Burden and Cost of the NSPS for Secondary Lead Smelters – Years 1-3
TABLE 4
Summary of Annual Respondent Burden and Cost of the NSPS for Secondary Lead Smelters
TABLES 5, 6, and 7
Annual Agency Burden and Cost of the NSPS for Secondary Lead Smelters – Years 1-3
TABLE 8
Summary of Annual Agency Burden and Cost of the NSPS for Secondary Lead Smelters

ENT 1
ATEMENT
Lead Smelters (40 CFR Part 60, Subpart L)

Table 1: Annual Respondent Burden and Cost Year One – NSPS for Secondary Lead S
(A)
Person hours per
occurrence

4
2
2
2
2
2
24
24
2

ix. Central Data Exchange (CDX) and Compliance and Emissions Data Reporting Interface (CEDRI) e

x. Submit performance tests electronically to CDX/CEDRI

xi. Submit semiannual reports electronically to CDX/CEDRI

C. Gather Information
D. Write Reports
Subtotal for Reporting Requirements
4. Recordkeeping Requirements
A. Read and understand rule requirements
B. Plan activities
C. Implement activities
D. Time to record information:
i. Performance test results f
ii. Semiannual report f
E. Time to train personnel g
F. Time for audits h

0
Subtotal for Recordkeeping Requirements

TOTAL LABOR BURDEN AND COST
Capital and O&M Cost (see Section 6(b)(iii)) i
GRAND TOTAL (rounded) j
Assumptions:

Two of the 11 existing facilities currently subject to subpart L will undergo reconstruction during the 3-year reporting period. These recons
during the 3-year reporting period).
a

Facilities currently subject to NSPS Subpart L have previously demonstrated initial compliance.
Five percent of respondents (rounded to the nearest whole number) fail the compliance demonstration and will need to repeat the performan
e
The facilities subject to Subpart L are also regulated by NESHAP Subpart X, which already requires submission of performance tests using
with the EPA's electronic reporting requirements for performance tests and for CDX/CEDRI registration.
c

NESHAP Subpart X already requires retention of performance test and semiannual reports. The burden estimate assumes that the testing co
NESHAP Subpart X and NSPS Subpart L pollutants (i.e., no additional test reports for Subpart L compliance) and that the semiannual repor
semiannual reports for Subpart L compliance).
f

Subpart L does not impose any additional personnel training burden.

The NSPS General Provisions (40 CFR 60.8(g)) requires a test method performance audit during conduct of the performance test.

Facilities subject to Subpart L have already conducted initial performance tests for PM emissions and opacity.

Totals rounded to 3 significant figures. Figures may not sum exactly due to rounding.

NSPS for Secondary Lead Smelting Facilities (40 CFR Part 60, Subpart L)
(B)
(C)
(D)
(E)
(F)
No. of
PersonTechnical
Management
occurrence per hours per
Person person-hours
respondent per respondent Respondents hours per
per year a
per year
year
per year
year
(C=AxB)
(E=CxD)
(Ex0.05)
N/A
N/A

(G)
Clerical
person hours per
year
(Ex0.1)

(H)

Cost, $ b

1.8

3.6

$3,832

0
0
0
0
0
0
0
0

9
9
9
9
9
9
0
9

0
0
0
0
0
0
0
0

$0
$0
$0
$0
$0
$0
$0
$0

------------------------See 3B---------------------------------------------------See 3B---------------------------41

$3,832

------------------------See 3A---------------------------------------------------See 3B---------------------------------------------------See 3B----------------------------

N/A
N/A
0
9
0
------------------------See 3B----------------------------

0
0
41

$0
$0
$3,832
$0
$4,000

porting period. These reconstructed sources will be subject to new subpart La (i.e., only 9 facilities will be subject to subpart L

for Industrial Production Manager (https://www.bls.gov/oes/current/oes172112.htm); $45.77 per hour for Industrial Engineer
ccupations (https://www.bls.gov/oes/current/oes430000.htm). EPA increased the BLS rates by 110 percent to account for the

need to repeat the performance test.
n of performance tests using CDX/CEDRI. Therefore, no additional burden associated with the respondent's familiarization

e assumes that the testing contractor provides a single test report to the facility containing the results of the emissions tests for
nd that the semiannual report(s) incorporate both the NESHAP Subpart X and NSPS Subpart L information (i.e., no additional

e performance test.

May 2021 BLS Wages
Technical
$45.77
Managerial
$56.62
Clerical
$20.88

Scalar to account for the benefit packages available to those employed by private indu

Description
National estimate for Industrial Engineers
National estimate for Industrial Production Manager
National avg for Office and Administrative Support Occupations

or the benefit packages available to those employed by private industry =

Link
https://www.bls.gov/oes/current/oes172112.htm
https://www.bls.gov/oes/current/oes113051.htm
https://www.bls.gov/oes/current/oes430000.htm

Wages for OMB Estimate
$96.12
$118.90
$43.85
110

Technical
Managerial
Clerical

$92.59
$135.18
$54.71

Table 2: Annual Respondent Burden and Cost Year Two – NSPS for Secondary Lead

Burden item
1. Applications
2. Surveys and Studies
3. Reporting Requirements
A. Read and understand rule requirements
B. Required activities
i. Notification of date of construction or reconstruction
ii. Notification of actual startup
iii. Notification of physical or operational change
iv. Notification of the anticipated date for conducting the opacity observations
v. Notification of performance test
vi. Conduct performance test c
vii. Repeat performance test d
viii. Semiannual report
ix. CDX and CEDRI e
x. Submit performance tests electronically to CDX/CEDRI
xi. Submit semiannual reports electronically to CDX/CEDRI
C. Gather Information
D. Write Reports
Subtotal for Reporting Requirements
4. Recordkeeping Requirements
A. Read and understand rule requirements
B. Plan activities
C. Implement activities
D. Time to record information:
i. Performance test results f
ii. Semiannual report f
E. Time to train personnel g
F. Time for audits h
Subtotal for Recordkeeping Requirements
TOTAL LABOR BURDEN AND COST
Capital and O&M Cost (see Section 6(b)(iii)) i
GRAND TOTAL (rounded) j
Assumptions:

Two of the 11 existing facilities currently subject to subpart L will undergo reconstruction during the 3-year reporting period. These reconst
during the 3-year reporting period).
a

May 2021 labor rates from the United States Department of Labor, Bureau of Labor Statistics: $56.62 per hour for Industrial Production M
(https://www.bls.gov/oes/current/oes172112.htm), and $20.88 per hour for Office and Administrative Support Occupations (https://www.bls
benefit packages available to those employed by private industry.
c
NESHAP Subpart X requires EPA Method 29 for the initial and annual emission tests for lead. The filter in the Method 29 sampling train c
Subpart La. The burden is for coordinating with the testing contractor to include the results of the PM analysis in the final test report. The bu
three tests).
b

Five percent of respondents (rounded to the nearest whole number) fail the compliance demonstration and will need to repeat the performan

The facilities subject to Subpart L are also regulated by NESHAP Subpart X, which already requires submission of performance tests using
the EPA's electronic reporting requirements for performance tests and for CDX/CEDRI registration.
e

Subpart L does not impose any additional personnel training burden.

The NSPS General Provisions (40 CFR 60.8(g)) requires a test method performance audit during conduct of the performance test.

The performance tests for PM cost approximately $300/test/respondent (the additional burden needed to gravimetrically analyze the filter of
facilities will conduct three PM tests per year (one for each type of furnace).
i

Totals rounded to 3 significant figures. Figures may not sum exactly due to rounding.

Year Two – NSPS for Secondary Lead Smelting Facilities (40 CFR Part 60, Subpart L)
(A)
(B)
(C)
(D)
(E)
(F)
No. of
PersonTechnical
Person Management
occurrence per hours per
Person hours per respondent per respondent Respondents hours per
person-hours
occurrence
per year a
per year
year
per year
year
(C=AxB)
(E=CxD)
(Ex0.05)
N/A
N/A
4

2
2
2
2
2
24
24
2
8
1
1

0
0
0
0
1
1
0.05
2
0
1
0

0
9
0
0
9
0
0
9
0
0
9
0
2
9
18
24
9
216
1.2
0
0
4
9
36
0
9
0
1
9
9
0
9
0
------------------------See 3B---------------------------------------------------See 3B----------------------------

(G)
Clerical
person hours per
year
(Ex0.1)

0
0
0
0
0.9
10.8
0
1.8
0
0.45
0

0
0
0
0
1.8
21.6
0
3.6
0
0.9
0

321
------------------------See 3A---------------------------------------------------See 3B---------------------------------------------------See 3B----------------------------

N/A
N/A
9

------------------------See 3B---------------------------0
321

e 3-year reporting period. These reconstructed sources will be subject to new subpart La (i.e., only 9 facilities will be subject to subpart L

62 per hour for Industrial Production Manager (https://www.bls.gov/oes/current/oes172112.htm); $45.77 per hour for Industrial Engineer
Support Occupations (https://www.bls.gov/oes/current/oes430000.htm). EPA increased the BLS rates by 110 percent to account for the

filter in the Method 29 sampling train can be analyzed to obtain the PM measurements needed to demonstrate compliance with NSPS
analysis in the final test report. The burden estimate assumes that facilities will test the blast, reverberatory, and pot furnaces separately (i.e.,

on and will need to repeat the performance test.

submission of performance tests using CDX/CEDRI. Therefore, no additional burden associated with the respondent's familiarization with

den estimate assumes that the testing contractor provides a single test report to the facility containing the results of the emissions tests for
mpliance) and that the semiannual report(s) incorporate both the NESHAP Subpart X and NSPS Subpart L information (i.e., no additional

nduct of the performance test.

d to gravimetrically analyze the filter of EPA Method 29, which is required by NESHAP Subpart X). The burden estimate assumes that

(H)

Cost, $ b
May 2021 BLS Wages
Technical
$45.77
Managerial
$56.62
Clerical
$20.88
$0

Scalar to account for the benefit packages available to those employe
$0
$0
$0
$0
$1,916
$22,993
$0
$3,832
$0
$958
$0

$29,699

$0
$0
$29,699
$8,100
$38,000

will be subject to subpart L

our for Industrial Engineer
percent to account for the

compliance with NSPS
nd pot furnaces separately (i.e.,

9
9
18
9
-

ondent's familiarization with

s of the emissions tests for
mation (i.e., no additional

en estimate assumes that

Description
National estimate for Industrial Engineers
National estimate for Industrial Production Manager
National avg for Office and Administrative Support Occupations

or the benefit packages available to those employed by private industry =

Link
https://www.bls.gov/oes/current/oes172112.htm
https://www.bls.gov/oes/current/oes113051.htm
https://www.bls.gov/oes/current/oes430000.htm

Wages for OMB Estimate
$96.12
$118.90
$43.85
110

Technical
Managerial
Clerical

$92.59
$135.18
$54.71

Table 3: Annual Respondent Burden and Cost Year Three – NSPS for Secondary Lead
(A)
Person hours per
occurrence

4
2
2
2
2
2

vi. Conduct performance test c

vii. Repeat performance test d

viii. Semiannual report

ix. CDX and CEDRI

x. Submit performance tests electronically to CDX/CEDRI
xi. Submit semiannual reports electronically to CDX/CEDRI
C. Gather Information
D. Write Reports f

1
1

Subtotal for Reporting Requirements
4. Recordkeeping Requirements
A. Read and understand rule requirements
B. Plan activities
C. Implement activities
D. Time to record information:
i. Performance test results f
ii. Semiannual report f
E. Time to train personnel g
F. Time for audits h

0
Subtotal for Recordkeeping Requirements

TOTAL LABOR BURDEN AND COST
Capital and O&M Cost (see Section 6(b)(iii)) i
GRAND TOTAL (rounded) j
Assumptions:

Two of the 11 existing facilities currently subject to subpart L will undergo reconstruction during the 3-year reporting period. These reconst
during the 3-year reporting period).
a

NESHAP Subpart X requires EPA Method 29 for the initial and annual emission tests for lead. The filter in the Method 29 sampling train c
Subpart La. The burden is for coordinating with the testing contractor to include the results of the PM analysis in the final test report. The bu
(i.e., three tests).
c

Five percent of respondents (rounded to the nearest whole number) fail the compliance demonstration and will need to repeat the performan

The facilities subject to Subpart L are also regulated by NESHAP Subpart X, which already requires submission of performance tests using
with the EPA's electronic reporting requirements for performance tests and for CDX/CEDRI registration.
e

Subpart L does not impose any additional personnel training.

The NSPS General Provisions (40 CFR 60.8(g)) requires a test method performance audit during conduct of the performance test.

Totals rounded to 3 significant figures. Figures may not sum exactly due to rounding.

(G)
Clerical
person hours per
year
(Ex0.1)

(H)

Cost, $ b

0
0
0
0
1

0
0
0
0
2

9
9
9
9
9

0
0
0
0
18

0
0
0
0
0.9

0
0
0
0
1.8

$0
$0
$0
$0
$1,916

216

10.8

21.6

$22,993

0.05

1.2

1.8

3.6

$3,832
$0

0.45
0

0.9
0

$958
$0

1
0

1
9
9
0
9
0
------------------------See 3B---------------------------------------------------See 3B----------------------------

321

$29,699

------------------------See 3A---------------------------------------------------See 3B---------------------------------------------------See 3B----------------------------

N/A
N/A
0
9
0
------------------------See 3B----------------------------

0
0
321

$0
$0
$29,699
$8,100
$38,000

orting period. These reconstructed sources will be subject to new subpart La (i.e., only 9 facilities will be subject to subpart L

Method 29 sampling train can be analyzed to obtain the PM measurements needed to demonstrate compliance with NSPS
the final test report. The burden estimate assumes that facilities will test the blast, reverberatory, and pot furnaces separately

need to repeat the performance test.

n of performance tests using CDX/CEDRI. Therefore, no additional burden associated with the respondent's familiarization

e performance test.

etrically analyze the filter of EPA Method 29, which is required by NESHAP Subpart X). The burden estimate assumes that

May 2021 BLS Wages
Technical
$45.77
Managerial
$56.62
Clerical
$20.88
Scalar to account for the benefit packages available to those employed by private industry =

Description
National estimate for Industrial Engineers
National estimate for Industrial Production Manager
National avg for Office and Administrative Support Occupations

or the benefit packages available to those employed by private industry =

Link
https://www.bls.gov/oes/current/oes172112.htm
https://www.bls.gov/oes/current/oes113051.htm
https://www.bls.gov/oes/current/oes430000.htm

Wages for OMB Estimate
$96.12
$118.90
$43.85
110

Technical
Managerial
Clerical

$92.59
$135.18
$54.71

Table 4: Summary of Annual Respondent Burden and Cost of the NSPS for Secondary Lead Smelters (40 CFR Part 60,

Year
1
2
3
Total
Average

Technical Hours
36
279
279
594
198

Management
Hours
2
14
14
30
10

Clerical Hours
4
28
28
59
20

Total Labor Hours
41
321
321
683
228

Labor Costs
$3,832
$29,699
$29,699
$63,230
$21,100

Lead Smelters (40 CFR Part 60, Subpart L)
Non-Labor
(Capital/Startup and
O&M) Costs
$0
$8,100
$8,100
$16,200
$5,400

Total Costs
$4,000
$38,000
$38,000
$80,000
$27,000

Table 5: Average Annual EPA Burden and Cost Year One – NSPS for Secondary Lead S

Activity
1. Read and understand rule requirements
2. Review incoming notifications
i. Notification of date of construction or reconstruction
ii. Notification of actual startup
iii. Notification of physical or operational change
iv. Notification of the anticipated date for conducting the opacity observations
v. Notification of performance test
vi. Performance test results
vii. Semiannual reports
TOTAL LABOR BURDEN AND COST (rounded) c

(A)
EPA Hours
per
occurrence

(B)
No of
occurrences
per year

1
1
1
1
1
4
4

0
0
0
0
0
0
0

Assumptions:

Two of the 11 existing facilities currently subject to subpart L will undergo reconstruction during the 3-year reporting period. These recons
be subject to subpart L during the 3-year reporting period).
a

This cost is based on the following labor rates which have been increased by 60 percent to account for the benefit packages available to gov
$28.34 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2022 General Schedule”, which excludes locality ra
b

Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

S for Secondary Lead Smelters (40 CFR Part 60, Subpart L)
(C)

(D)

(E)
Technical
hours per
year
(E=CxD)
36

(F)
Managerial
hours per
year
(E x 0.05)
1.8

(G)
Clerical
hours per
year
(E x 0.1)
3.6

EPA hours
per year
(C=AxB)
4

Facilities per
year a

0
0
0
0
0
0
0

9
9
9
9
9
9
9

0
0
0
0
0
0
0

0
0
0
0
0
0
0
41

0
0
0
0
0
0
0

(H)
Total Cost per
Year b
$2,114.35
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$2,200

porting period. These reconstructed sources will be subject to new subpart La (i.e., only 9 facilities will

fit packages available to government employees: $70.56 Managerial rate, $52.37 Technical rate, and
”, which excludes locality rates of pay.

2022 ICR Wages
Technical
$52.37
Managerial
$70.56
Clerical
$28.34

Table 6: Average Annual EPA Burden and Cost Year Two – NSPS for Secondary Le
(A)
EPA Hours
per
occurrence
Activity
1. Read and understand rule requirements
2. Review incoming notifications
i. Notification of date of construction or reconstruction
ii. Notification of actual startup
iii. Notification of physical or operational change
iv. Notification of the anticipated date for conducting the opacity observations
v. Notification of performance test
vi. Performance test results
vii. Semiannual reports
TOTAL LABOR BURDEN AND COST (rounded) c

4
1
1
1
1
1
4
4

Assumptions:

Two of the 11 existing facilities currently subject to subpart L will undergo reconstruction during the 3-year reporting period. These re
be subject to subpart L during the 3-year reporting period).
a

This cost is based on the following labor rates which have been increased by 60 percent to account for the benefit packages available to
$28.34 Clerical rate. These rates are from the Office of Personnel Management (OPM) “2022 General Schedule”, which excludes localit
b

Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Two – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L)
(B)
No of
occurrences
per year

(C)

(D)

(E)
Technical
hours per
year
(E=CxD)
0

(F)
Managerial
hours per
year
(E x 0.05)
0

(G)
Clerical
hours per
year
(E x 0.1)
0

Facilities per
year a

EPA hours
per year
(C=AxB)
0

0
0
0
0
1
1
2

0
0
0
0
1
4
8

9
9
9
9
9
9
9

0
0
0
0
9
36
72

0
0
0
0
0.45
1.8
3.6
135

0
0
0
0
0.9
3.6
7.2

(H)
Total Cost per
Year b
$0.00
$0.00
$0.00
$0.00
$0.00
$528.59
$2,114.35
$4,228.70
$6,900

ng the 3-year reporting period. These reconstructed sources will be subject to new subpart La (i.e., only 9 facilities will

unt for the benefit packages available to government employees: $70.56 Managerial rate, $52.37 Technical rate, and
neral Schedule”, which excludes locality rates of pay.

2022 ICR Wages
$52.37
Technical
$70.56
Managerial
$28.34
Clerical

Table 7: Average Annual EPA Burden and Cost Year Three – NSPS for Secondary L
(A)
EPA Hours per
occurrence
Activity
1. Read and understand rule requirements
2. Review incoming notifications
i. Notification of date of construction or reconstruction
ii. Notification of actual startup
iii. Notification of physical or operational change
iv. Notification of the anticipated date for conducting the opacity observations
v. Notification of performance test
vi. Performance test results
vii. Semiannual reports
TOTAL LABOR BURDEN AND COST (rounded) c

4
1
1
1
1
1
4
4

Assumptions:

Two of the 11 existing facilities currently subject to subpart L will undergo reconstruction during the 3-year reporting period. These re
subject to subpart L during the 3-year reporting period).
a

Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

hree – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L)
(B)
No of
occurrences
per year

(C)

(D)

(E)
Technical
hours per
year
(E=CxD)
0

(F)
Managerial
hours per
year
(E x 0.05)
0

(G)
Clerical
hours per
year
(E x 0.1)
0

Facilities per
year a

EPA hours
per year
(C=AxB)
0

0
0
0
0
1
1
2

0
0
0
0
1
4
8

9
9
9
9
9
9
9

0
0
0
0
9
36
72

0
0
0
0
0.45
1.8
3.6
135

0
0
0
0
0.9
3.6
7.2

(H)
Total Cost per
Year b
$0.00
$0.00
$0.00
$0.00
$0.00
$528.59
$2,114.35
$4,228.70
$6,900

the 3-year reporting period. These reconstructed sources will be subject to new subpart La (i.e., only 9 facilities will be

for the benefit packages available to government employees: $70.56 Managerial rate, $52.37 Technical rate, and
ral Schedule”, which excludes locality rates of pay.

2022 ICR Wages
$52.37
Technical
$70.56
Managerial
$28.34
Clerical

Table 8: Summary of Annual Agency Burden and Cost of the NSPS for Secondary Lead Smelters (40
CFR Part 60, Subpart L)
Year
1
2
3
Total
Average

Technical
Hours
36
117
117
270
90

Management
Clerical Hours Total Hours
Hours
2
4
41
6
12
135
6
12
135
14
27
311
5
9
104

Labor Costs
$2,200
$6,900
$6,900
$16,000
$5,300

Non-Labor
Costs
$0
$0
$0
$0
$0

dary Lead Smelters (40
Total Costs
$2,200
$6,900
$6,900
$16,000
$5,300

Semiannual training and certification =

2,044 $/yr

Base Cost Year =
Average Chem Eng Plant Cost Index =
Cost Year =
Average Chem Eng Plant Cost Index =

2009
521.9
2020
596.2

Semiannual training and certification =

2,335 $/yr

(2009 $)

(2020 $)