## 1 **SUPPORTING STATEMENT**

**NATIONAL EMISSION STANDARDS FOR SECONDARY LEAD SMELTING** 

**PART A**

**1**

**. IDENTIFICATION OF TH**  **E INFORMATION COLLEC TION**  (a ) Title and Number of the Information Collection. “National Emission Standards for Hazardous Air Pollutants (NESHAP) for Secondary Lead Smelting (40 CFR part 63, subpart X) ” (b ) Short Characterization. This ICR is prepared for a U.S. Environmental Protection Agency (EPA) rulemaking developed under authority of section 112 of the Clean Air Act (CAA). The rulemaking amends T itle 40, chapter I, part 63, subpart X, National Emission Standards for Hazardous Air Pollutants (NESHAP) for Secondary Lead Smelting, of the Code of Federal Re gulations (CFR). The previous NESHAP w as proposed on June 23, 1995, and promulgated on June 13, 1997. The revised NESHAP was proposed on May 19, 2011. The potential respondents are owners or operators of any existing or new affected source with secondary lead smelting operations. There are 1 6 facilities subject to the NESHAP. The NESHAP is applicable to the following processes at a secondary

lead smelter: blast, reverberatory, rotary, and electric smelting furnaces; refining kettles; agglomerating fur naces; dryers; process fugitive sources; and fugitive dust sources. The affected sources are those that meet the criteria established in §63.541 of the Secondary L ead Smelting NESHAP. The amendments reduce the emissions limits for lead. Specifically , sources are required to maintain the concentration of lead compounds in any process vent gas at or below 1.0 milligrams of lead per dry standard cubic meter (mg/dscm) (0.00043 grains of lead per dry standard cubic foot (gr/dscf) ), and they also are required to maintain the flow

- weighted average concentration of lead compounds in vent gases from a secondary lead facility

at or below 0.20 mg/dscm (0.000087 gr/dscf ). The amendments also establish emissions limits for total hydrocarbons (THC) and dioxins and furans (D/F) from furnace sources.

The final amendments include an emission limit for THC of 12 parts per million volume (expressed as propane) corrected to 4 percent carbon dioxide ( CO 2 

## ) for new and existing reverberatory

furnaces not collocated with a blas t furnace and reverberatory furnaces mixed with electric furnaces.

## 2

With regard to D/F, we are revising the previous NESHAP to include the following emissions limits for dioxins and furans:

 For reverberatory

furnaces not collocated with blast furnaces , and for reverberatory furnaces where the exhaust gases are mixed with electric furnaces , a limit of 0.20 nanograms per dry

standard cubic meter (ng/dscm) at 7 percent oxygen ( O 2 

## ) expressed on a toxic equivalency (TEQ) basis and 0.1 ng/dscm at 7 percent O 2 

## expressed on a TEQ basis for existing and new affected sources, respectively.

 For b last furnaces , a limit of 170 ng/dscm at 7 percent O 2 

## expressed on a TEQ basis and 10 ng/dscm at 7 percent O 2 

## expressed on a TEQ basis for existing and new sources, respectivel y.

 For c ollocated blast and reverberatory furnaces , a limit of 0.5 ng/dscm at 7 percent O 2 

## expressed on a TEQ basis for both new and existing sources.
To control fugitive lead emissions, we are finalizing amendments that require each facility to totall y enclose all sources of fugitive emissions (e.g., storage piles, material handling, battery breaking, dryers, and casting kettles) and operate the total enclosure s under negative pressure in addition to requiring facilities to implement comprehensiv e work practices designed to prevent the formation of fugitive dust. The work practices include pavement cleaning , vehicle washing , cleaning of all affected areas after accidental releases , inspection of the battery storage areas for broken batteries , performance of maintenance activities in a manner that minimizes fugitive lead dust emissions, and transport of lead bearing dust in closed systems. The requirements for full enclosure are new provisions under the final amendments.

The amendments to the rule eliminate the startup, shutdown, and malfunction (SSM) exemption, remove the SSM plan requirement, add provisions to provide an affirmative defense against civil penalties for exceedances of emission standards caused b y malfunctions, add a requirement f

or electronic submittal of performance test data, and correct editorial error s

. Recordkeeping for stack testing will be the same with the exception of records of the additional testing requirements for THC and D/F.

The final amendments for control of fugitive emissions that include work practices and enclosure standards have a compliance date of 2 years from the promulgation date which will allow the facility to construct any enclosures necessary to meet the new and revised requirements. The compliance date for the amendments for the revised stack lead emission limit and new THC and D/F emissions limits is 2 years from the date of promulgation. The compliance date for the revised SSM requirements is the date of promulgation. The final

amendments require stack testing for D/F every 5 years.

## 3

The information collection requirements associated with the final amendments to the NESHAP are listed in Attachment 2

. **2. Need For and Use of the Collection**  (a ) Need/Authority for the Collection. Section 112 of the (CAA) requires EPA to establish NESHAP for both major and area sources of hazardous air pollutants (HAP ) that are listed for regulation under section 112(c) of the CAA . A major source is a stationary source that emits or has the potential to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a stationary source that is not a major source (i.e., an area source that does not emit and does not have the potential to emit more than 10 tpy of any single HAP and more than 25 tp y of any combination of HAP). For major sources, these technology

-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non
- air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. Section 112(d)(6) of the CAA requires EPA to review these technology

- based standards and to revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequentl y than every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source categories subject to certain CAA section 112(d) standards whether the emissions limitations provide an ample margin of safety to protect public health. For MACT standards for HAP “classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime excess cancer risks to the individ ual most exposed to emissions from a source in the category or subcategory

to less than 1

- in

- 1 million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to protect publi c health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA determines that the existing standards are sufficiently protective. EPA must also adopt more stringent standards, if necessary , to prevent an adverse environmental ef fect, but must consider cost, energy, safety, and other relevant factors in doing so. Certain records and reports are necessary for the Administrator to confirm the compliance status of sources subject to NESHAP, 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 specificall y authorized b y section 114 of the CAA (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 ye ars following the date of each occurrence, me asurement, maintenance, corrective action, report, or record.

## 4

(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 a nd 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 information collection requests ( IC Rs ) 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 IC R. (c) Consultations. The amendments were developed in consultation with the Association of Battery Recyclers (ABR) and various companies (including the Revere Smelting and Refining (RSR) Corporation and Exide Technologies, who own 9 of the 16 facilities and Johnson Controls, Inc., who is in the process of constructing a new secondary lead smelting facility) . 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 Organization**  **Telephone No.** Russell Kemp Environ Corp. 678

- 388

- 1654 Robert Steinwurtzel Baker and Hostetler 202

- 861

- 1708 Steve Arnold The Doe Run Company 573

- 626

- 3495 Mark Cummings Exide Technologies 678

- 566

- 9280 Mike Butkantz RSR Corp 626

- 937

- 3245 Keith McCoy Johnson Controls, Inc. 202

- 406

- 4068 (d ) Effects of Less Frequent Collection. If the relevant information was collected less frequently , the delegated permitting authority (State or EPA) will not be reasonabl y 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.

## 5

(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 b y 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 subpart X are owners or operators of any existing or new facility engaged in secondary

lead smelting

. Secondary lead smelting facilities are primarily classified under NAICS code s 331492 , Secondary L ead Smelting and Refining.

There are 16 facilities that will be subject to the final amendments to the NESHAP

. One

new secondary

lead smelting facility

is under cons truction at this time. No additional facilities are expected during the 3 -year period of this ICR. (b ) Information Requested. (i ) Data Items, Including Recordkeeping Requirements. Attachment 2 , Information Requirements, summarizes the data items, including recordkeeping and reporting requirements, for the Secondary

L ead Smelting source category

. The amendments to the NESHAP require that any performance tests performed after December 31, 2011 b e submitted electronicall y to EPA’s Central Data Exchange by using the Electronic Reporting Tool (ERT) for test methods that are compatible with ERT. This new requirement to submit the data to the ERT is in addition to the other existing submission requirements for this data. (ii) Respondent Activities. The respondent activities that will be required by the final amendments to the Secondary L ead Smelting NESHAP are identified in Tables 1

- 3 of Attachment 1 and are introduced in section 6(a).

EPA is including an estimate of the burden associated with performing an affirmative defense. EPA is providing this as an illustrative example of the potential additional administrative burden a source may incur to assert in an affirmative d efense in response to an action to enforce the standards set forth in the applicable subpart.

## 6

This illustrative estimate is not considered a duplicate estimate of cost under the General Duty to Minimize Emissions clause under 63.6(e)(1)(i), which states: “At all times, the owner and operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determining whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.” To provide the public with an estimate of the relative magnitude of the burden associated with an assertion of the affirmative defense position adopted by a source, EPA provi des an administrative adjustment to this ICR that estimates the costs of the notification, recordkeeping and reporting requirements associated with the assertion of the affirmative defense. EPA’s estimate for the required notification, reports and records , including the root cause anal ys is, associated with a single incident totals approximately $3,141 and is based on the time and effort required of a source to review relevant data, interview plant employees, and document the events surrounding a malfunctio n that has caused an exceedance of an emission limit. The estimate also includes time to produce and retain the records and reports for submission to EPA. EPA provides this illustrative estimate of this burden because these costs are only incurred if the re has been a violation and a source chooses to take advantage of the affirmative defense. Of the number of excess emission events reported by source operators, onl y a small number would be expected to result from a malfunction, and only a subset of exce ss emissions caused b y malfunctions would result in the source choosing to assert the affirmative defense. Thus we believe the number of instances in which source operators might be expected to avail themselves of the affirmative defense will be extremely small. For this reason, we estimate no more than 2 or 3 such occurrences for all sources within a given category over the 3

- ye ar period covered b y this ICR. For the purpose of this estimate, we are adding two instances of affirmative defense. We expect to gather information on such events in the future and will revise this estimate as better information becomes available.

**5. The Information Collected** 

**– Agency Activities, Collection Methodology, and**  **Information Management** (a ) Agency Activities. The Agenc y activities associated with the final amendments to the Secondary L ead Smelting NESHAP are provided in Tables 5

- 7 of Attachment 1 and are introduced in section 6(c).

## 7

(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 . EPA is the permitting authority until the State agency is delegated authority to implement the final amendments to the rule. Therefore, inf ormation contained in any report submitted to the Regional Administrator will be entered into the Air Facility S ys tem (AFS), which is operated and maintained b y EPA’s Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retriev al of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated authorities can edit, store, retrieve and anal yz e the data. (c) Small Entity Flexibility. The Small Business Administration defines a small entity engaging in secondary lead smelting operations as a firm having no more than 7 00 employees. 13 of the 16 facilities subject to the final amendments for the Secondary L ead Smelting source category do not meet the definition of a small entity. Three facilities are owned by small entities. Gopher Resources owns two facilities, and The Battery Recycl ing Company

owns one facility . Based on the definition, however, we estimate that the economic impacts to these entities will not be significant. One Gopher Resources facility is already

relativel y well controlled and therefore will not need to spend a s ignificant amount of capital on new control devices. The second Gopher Resources facility is currentl y undergoing an expansion that includes upgrades to their control devices and total enclosures and will therefore also not need to spend a significant

amount of capital on new control devices. The third facility owned b y The Battery Recycling Company will require some facility upgrades. However, the estimated construction and operating costs for these upgrades have not been determined to be significant base d on guidelines developed for the analysis. Therefore, we have determined that these amendments will not impose a significant impact on a substantial number of small entities. (d ) Collection Schedule. The specific frequency

for each information collection activity within this request is shown in Table s 1

- 3 of Attachment 1 for the Secondary L ead Smelting c ategory

. **6. Estimating the Burden and Cost of the Collection**  (a ) Estimating Respondent Burden.
The annual burden estimates for the final amendments to the Secondary L ead Smelting NESHAP are shown in Table s 1

- 3 of Attachment 1 . These numbers were derived from estimates

## 8

based on EPA’s experience with other standards. Burden estimates for the one new source are included in the estimate. (b ) Estimating R espondent Costs. (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 associated with Nonferrous Metal Prod uction and Processing were taken from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employ ment Statistics available at http://bls.gov/oes/current/naics4_331400.htm#43

- 0000

. Wages for technical labor are based on " Environmental Engineer ," with a total compensation of $ 38.10/hour. Wages for management labor are taken from " Engineering Managers ," with a total compensation of $5 0.65 /hour. Wages for clerical labor are based on " Secretaries, Except Legal, Medical, and Executive ," with a total compensation of $ 15.98 /hour. 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 hourl y wage rates used to represent respondent labor costs are: technical at $ 80.01 /hour, management at $ 106.37 /hour, and clerical at $ 33.56 /hour. (ii) Estimating Capital and Operations and Maintenance (O& M) Costs

. The capital costs associated with the NESHAP including monitoring s ys tem initial costs; one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and conducting stack testing. (iii) Capital/Startup vs. Operation and Maintenance (O& M) Costs. The estimated capital and O&M costs for the affected units for the first 3 years after promulgation are provided. For the 16 facilities, the total capital costs are $106,000. The total annualized capital and O&M costs are $1.33 million for an average of $440,000 per year. (iv) Affirmative Defense, Root Cause Analysis, and Malfunction Costs. EPA’s estimate for an affirmative defense and root cause anal ys is is based on general experience to calculate the time and effort required of a source to review relevant data, interview pla nt employees, and reconstruct the events prior to a malfunction in order to determine primary and contributing causes. The level of effort also includes time to produce and retain the report in document form so that the source will have it available shoul d EPA or state enforcement agencies ever request to review it. (c) Estimating Agency Burden and Cost. The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA’s overall compliance and enforcement program includes activities such as the

## 9

examination of records maintained by the respondents, periodic inspection of sources of emission, and the publication and distribution of collected information. The average annual Agency cost during the three years of the IC R is estimated to be $52,000. The Agency

labor rates are from the Office of Personnel Management (OPM) 2010 General Schedule, which excludes locality rates of pay . These rates can be obtained from Salary Table 2010

- GS available on the OPM website, http://www.opm.gov/oca/10tables/pdf/gs_h.pdf

. Managerial $62.27 (GS

- 13, Step 5, $38.92+ 60%) Technical $46.21 (GS

- 12, Step 1, $28.88+ 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)
These rates were increased by 60 percent to include fringe benefits and overhead. (d ) Estimating the Respondent Universe and Total Burden and Costs. There are 16 facilities that are subject to the revised Secondary L ead Smelting NESHAP

. One new source is expect ed to begin operation in the first year of the 3

- ye ar compliance period

. Over the 3

- ye ar period, it is estimated that these 16 facilities will have 114 responses for an average of 38 per year. (e) Bottom Line Burden Hours and Cost Tables. (i ) Respondent tally. The bottom line respondent burden hours and costs presented in Tables 1

- 3 of Attachment 1 are calculated b y adding person

- hours per year down each column for technical, managerial, and clerical staff, and b y adding down the cost column. The averag e annual burden for the recordkeeping and reporting requirements in the final amendments to subpart X for the 16 facilities that are subject to the Secondary L ead Smelting NESHAP is $790,00 0 . This includes 4,500 annual labor hours. (ii) The Agency tall

y. The average annual Federal Government cost is $52,000 for 1,150 hours for the final amendments to subpart X. The bottom line Agency burden hours and costs presented in Tables 5

- 7 of Attachment 1 are calculated by adding person

- hours per year down each column for technical, managerial, and clerical staff, and b y adding down the cost column. (iii) Variations in the annual bottom line. The total respondent costs for ye ars 1, 2, and 3 are $1.17 million, 0.75 million, and $0.45 million , respectivel y . The corresponding total respondent hours for years 1, 2, and 3 are 5,600 , 4,100 , and 3,800, respectively

. (f ) Reasons for Change in Burden. This section does not apply because this is a new ICR.

## 10

(g ) Burden Statement The average annual respondent burden for the final amendments to the Secondary L ead Smelting NESHAP is estimated at 100 hours per facility

. Burden means the total time, effort, or financial resources expended b y 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 disclos ing 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 Office of Management and Budget ( OMB ) contro l 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 for 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 No. EPA

- HQ

- OAR

- 2011

- 0344 , which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room B

- 102, 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 el ectronically . When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17 th 

## Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number ( EPA

- HQ

- OAR

- 2011

- 0344 ) in any correspondence.

## 11

**PART B** This section is not applicable because statistical methods are not used in data collection associated with the final rule.

## 12 

# ATTACHMENT 1 **Burden Estimate Tables 1**

**– 8** 

Table s 1

– 3: Annual Respondent Burden and Cost of Recordkeeping and Reporting

Requirements for the Secondary L ead Smelters NESHAP

- Years 1

– 3

Table 4: Summary

of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Second ary Lead Smelters NESHAP

Table s 5

– 7: Annual Designated Administrator Burden and Cost of Recordkeeping and

Reporting Requirements for the Secondary L ead Smelters NESHAP

- Year s 1

- 3

Table 8: Summary

of Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary Lead Smelters NESHAP

## 13



# Table 1

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting**  **Requirements for the Secondary Lead Smelters NESHAP** 

**- Year 1** 

**Burden Item (A)** 

**Respondent Hours per**  **Occurrence (Technical**  **hours) (B)** 

**Stack Testing**  **Cost Per Occurrenc** 
**e (C)**  **Other Non**

  ** Labor** **Costs Per Occurrenc** 
**e (D)** 

**Number of Occurrence**  **s Per Respondent**  **Per Year**  **(E)**

**Technical Hours per**  **Responden t Per Year**  **(A X D) (F)** 

**Number of Respondent**  **s Per Year (G)** 

**Technica l Hours**  **per Year (E X F)**  **(H)**

**Clerical Hours**  **per Year**  **(G X 0.1)**  **(I) Managemen**  **t Hours per Year**  **(G X .05) (J)** 

**Total Labor**  **Costs Per Year**  **(K)**

**Total Non**

  ** La** **bor Costs Per Year**  **[(B+C)xDxF] (L)** 

**Total Number**  **of Response**  **s per Year (D X F)** **F o** **o t** **n o** **t e** **s**

1. Applications NA 2. Surveys and Studies NA 3. Reporting Requirements A. Read Rule 20 $0 $0 1 20 16 320 32 16 $28,379 $0 0 B. Required Activities 1. THC testing 10 $4,700 $0 1 10 34 340 34 17 $30,153 $159,800 0 2. Dioxin/Furan testing 10 $19,300 $0 1 10 23 230 23 12 $20,397 $443,900 0 3. Lead testing 10 $10,000 $0 1 10 0 0 0 0 $0 $0 0 4. Differential pressure monitor 2 $0 $2,300 1 2 46 92 9 5 $8,159 $105,800 0 5. Differential pressure monitor (annual O&M) 2 $0 $230 1 2 46 92 9 5 $8,159 $10,580 0 6. Inspection and repair enclosure 24 $0 $0 1 24 16 384 38 19 $34,055 $0 0 7. Inspect battery storage areas 24 $0 $0 1 24 16 384 38 19 $34,055 $0 0 C. Create Information Inc. in 3B D. Gather Information Inc. in 3E E. Report Preparation 1. Annual report 10 $0 $0 1 10 16 160 16 8 $14,189 $0 16

## 14



# Table 1

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting**  **Requirements for the Secondary Lead Smelters NESHAP** 

**- Year 1** 

**Burden Item (A)** 

**Respondent Hours per**  **Occurrence (Technical**  **hours) (B)** 

**Stack Testing**  **Cost Per Occurrenc** 
**e (C)**  **Other Non**

  ** Labor** **Costs Per Occurrenc** 
**e (D)** 

**Number of Occurrence**  **s Per Respondent**  **Per Year**  **(E)**

**Technical Hours per**  **Responden t Per Year**  **(A X D) (F)** 

**Number of Respondent**  **s Per Year (G)** 

**Technica l Hours**  **per Year (E X F)**  **(H)**

**Clerical Hours**  **per Year**  **(G X 0.1)**  **(I) Managemen**  **t Hours per Year**  **(G X .05) (J)** 

**Total Labor**  **Costs Per Year**  **(K)**

**Total Non**

  ** La** **bor Costs Per Year**  **[(B+C)xDxF] (L)** 

**Total Number**  **of Response**  **s per Year (D X F)** **F o** **o t** **n o** **t e** **s**

2. Differential pressure monitoring report 10 $0 $0 1 10 16 160 16 8 $14,189 $0 16 3. Develop SOP for work practices 40 $0 $0 1 40 16 640 64 32 $56,758 $0 16 4. Affirmative defense 30 $0 $0 1 30 1 30 3 2 $3,141 $0 1 **Reporting Subtotal**  2802 280 140 $251,634 $720,080 48 4. Recordkeeping Requirements A. Read Instructions Inc. in 3A B. Implements Activities NA C. Develop Record System NA D. Record information 1. Records of fugitives 1 $0 $0 12 14 16 224 22 11 $19,865 $0 0 2. Records of flow weighted average for lead standard 1 $0 $0 1 1 16 16 2 1 $1,419 $0 0 3. Records of continuous pressure monitors 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 4. Records of power outages 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 5. Records of facility enclosure inspections 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0

## 15



# Table 1

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting**  **Requirements for the Secondary Lead Smelters NESHAP** 

**- Year 1** 

**Burden Item (A)** 

**Respondent Hours per**  **Occurrence (Technical**  **hours) (B)** 

**Stack Testing**  **Cost Per Occurrenc** 
**e (C)**  **Other Non**

  ** Labor** **Costs Per Occurrenc** 
**e (D)** 

**Number of Occurrence**  **s Per Respondent**  **Per Year**  **(E)**

**Technical Hours per**  **Responden t Per Year**  **(A X D) (F)** 

**Number of Respondent**  **s Per Year (G)** 

**Technica l Hours**  **per Year (E X F)**  **(H)**

**Clerical Hours**  **per Year**  **(G X 0.1)**  **(I) Managemen**  **t Hours per Year**  **(G X .05) (J)** 

**Total Labor**  **Costs Per Year**  **(K)**

**Total Non**

  ** La** **bor Costs Per Year**  **[(B+C)xDxF] (L)** 

**Total Number**  **of Response**  **s per Year (D X F)** **F o** **o t** **n o** **t e** **s**

6. Records of startup and shutdown 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 7. Records of malfunctions 2 $0 $0 6 12 16 192 19 10 $17,027 $0 0 8. Records of actions taken during malfunctions 1 $0 $0 6 6 16 96 10 5 $8,514 $0 0 9. Records for BLDS 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 10. Records of furnace inspection 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 11. Records of recovery of plastic battery casing material 1 $0 $0 6 6 16 96 10 5 $8,514 $0 0 E. Personnel Training 20 $0 $0 1 20 16 320 32 16 $28,379 $0 0 F. Time for Audits NA **Recordkeeping Subtotal**  2096 210 105 $185,880 $0 0 **TOTAL** 4898 490 245 $437,514 $720,080 48

Summary of Respondent Burden Total Hours Labor Non

Labor Total
5,633 $437,514 $720,08 0 $1,157,59

4 Initial Capital and Startup $105,80 0 Annualized Capital/Start

- up and O & M $720,08 0

## 16



# Table 2

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary**  **Lead Smelters NESHAP**

**- Year 2** 

Burden Item (A)

Respondent Hours per Occurrence (Technical hours) (B)

Stack Testing Cost Per Occurrence (C)

Other Non

Labor Costs Per Occurrence (D)

Number of Occurrences Per Respondent Per Year (E)

Technical Hours per Respondent Per Year (A X D) (F)

Number of Respondents Per Year (G)

Technical Hours per Year (E X F) (H)

Clerical Hours per Yea r (G X 0.1) (I) Management Hours per Year (G X .05) (J)

Total Labor Costs Per Year (K)

Total Non

Labor Costs Per Year [(B+C)xDxF] (L)

Total Number of Responses per Year (D X F)Footnotes

1. Applications NA 2. Surveys and Studies NA 3. Reporting Requirements A. Read Rule 20 $0 $0 1 20 0 0 0 0 $0 $0 0 B. Required Activities 1. THC testing 10 $4,700 $0 1 10 34 340 34 17 $30,153 $159,800 0 2. Dioxin/Furan testing 10 $19,300 $0 1 10 0 0 0 0 $0 $0 0 3. Lead testing 10 $10,000 $0 1 10 26 260 26 13 $23,058 $260,000 0 4. Differential pressure monitor 2 $0 $2,300 1 2 0 0 0 0 $0 $0 0 5. Differential pressure monitor (annual O&M) 2 $0 $230 1 2 46 92 9 5 $8,159 $10,580 0 6. Inspection and repair enclosure 20 $0 $0 1 24 16 384 38 19 $34,055 $0 0 7. Inspect battery storage areas 20 $0 $0 1 24 16 384 38 19 $34,055 $0 0 C. Create Information Inc. in 3B D. Gather Information Inc. in 3E E. Report Preparation 1. Annual report 10 $0 $0 1 10 16 160 16 8 $14,189 $0 16 2. Differential pressure monitoring report 10 $0 $0 1 10 16 160 16 8 $14,189 $0 16 3. Develop SOP for work practices 40 $0 $0 1 40 0 0 0 0 $0 $0 0 4. Affirmative defense 30 $0 $0 1 30 1 30 3 2 $3,141 $0 1 **Reporting Subtotal** 1810 181 91 $160,999 $430,380 33

## 17



# Table 2

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary**  **Lead Smelters NESHAP**

**- Year 2** 

Burden Item (A)

Respondent Hours per Occurrence (Technical hours) (B)

Stack Testing Cost Per Occurrence (C)

Other Non

Labor Costs Per Occurrence (D)

Number of Occurrences Per Respondent Per Year (E)

Technical Hours per Respondent Per Year (A X D) (F)

Number of Respondents Per Year (G)

Technical Hours per Year (E X F) (H)

Clerical Hours per Yea r (G X 0.1) (I) Management Hours per Year (G X .05) (J)

Total Labor Costs Per Year (K)

Total Non

Labor Costs Per Year [(B+C)xDxF] (L)

Total Number of Responses per Year (D X F)Footnotes

4. Recordkeeping Requirements A. Read Instructions Inc. in 3A B. Implements Activities NA C. Develop Record System NA D. Record information 1. Records of fugitives 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 2. Records of flow weighted average for lead standard 1 $0 $0 1 1 16 16 2 1 $1,419 $0 0 3. Records of continuous pressure monitors 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 4. Records of power outages 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 5. Records of facility enclosure inspections 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 6. Records of startup and shutdown 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 7. Records of malfunctions 2 $0 $0 6 12 16 192 19 10 $17,027 $0 0 8. Records of actions taken during malfunctions 1 $0 $0 6 6 16 96 10 5 $8,514 $0 0 9. Records for BLDS 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 10. Records of furnace inspection 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 11. Records of recovery of plastic battery casing material 1 $0 $0 6 6 16 96 10 5 $8,514 $0 0 E. Personnel Training 8 $0 $0 1 8 0 0 0 0 $0 $0 0

## 18



# Table 2

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary**  **Lead Smelters NESHAP**

**- Year 2** 

Burden Item (A)

Respondent Hours per Occurrence (Technical hours) (B)

Stack Testing Cost Per Occurrence (C)

Other Non

Labor Costs Per Occurrence (D)

Number of Occurrences Per Respondent Per Year (E)

Technical Hours per Respondent Per Year (A X D) (F)

Number of Respondents Per Year (G)

Technical Hours per Year (E X F) (H)

Clerical Hours per Yea r (G X 0.1) (I) Management Hours per Year (G X .05) (J)

Total Labor Costs Per Year (K)

Total Non

Labor Costs Per Year [(B+C)xDxF] (L)

Total Number of Responses per Year (D X F)Footnotes

F. Time for Audits NA **Recordkeeping Subtotal**  1744 174 87 $154,663 $0 0 **TOTAL** 3554 355 178 $315,662 $430,380 33 **Total Hours**  **Labor Non** 
**** **Labor Total**  **Summary**

**of Respondent Burden** 4,087 $315,662 $430,380 $746,042 **Initial Capital and Startup** $0 **An nualized Capital/Start** 
**- up and O &**  **M** $430,380

## 19



# Table 3

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary Lead**  **Smelters NESHAP**

**- Year 3** 

**Burden Item (A)**  **Respondent Hours per**  **Occurrence (Technical**  **hours) (B)** 

**Stack Testing**  **Cost Per**  **Occurre**
**nce (C)** 

**Other Non** 

**** **Labor Costs**  **Per Occurre** 
**nce (D)**  **Number of**  **Occurre nces Per**  **Respond ent Per**  **Year (E)** 

**Technic al Hours**  **per Respon**  **dent Per Year**  **(A X D) (F)** 

**N umber**  **of Respond**  **ents Per Year**  **(G)**

**Techni cal**  **Hours per**  **Year (E X F)**  **(H)**

**Clerical Hours**  **per Year (G X 0.1)**  **(I)**

**Managem ent Hours**  **per Year (G X .05)**  **(J)**

**Total Labor Costs Per**  **Year (K)** 

**Total Non** 

**** **Labor Costs Per**  **Year [(B+C)xD**  **xF] (L)** 

**Total Numb**  **er of Respo** 
**nses pe**  **r Year**  **(D X F) F** **o o** **t n** **o t** **e s** 

1. Applications NA 2. Surveys and Studies NA 3. Reporting Requirements A. Read Rule 20 $0 $0 1 20 0 0 0 0 $0 $0 0 B. Required Activities 1. THC testing 10 $4,700 $0 1 10 34 340 34 17 $30,153 $159,800 0 2. Dioxin/Furan testing 10 $19,300 $0 1 10 0 0 0 0 $0 $0 0 3. Lead testing 10 $10,000 $0 1 10 0 0 0 0 $0 $0 0 4. Differential pressure monitor 2 $0 $2,300 1 2 0 0 0 0 $0 $0 0 5. Differential pressure monitor (annual O&M) 2 $0 $230 1 2 46 92 9 5 $8,159 $10,580 0 6. Inspection and repair enclosure 20 $0 $0 1 24 16 384 38 19 $34,055 $0 0 7. Inspect battery storage areas 20 $0 $0 1 24 16 384 38 19 $34,055 $0 0 8. HEPA filter monitor Initial capital 2 $0 $32,759 1 2 0 0 0 0 $0 $0 0 Annual (O&M) 2 $0 $4,665 1 2 0 0 0 0 $0 $0 0 C. Create Information Inc. in 3B D. Gather Information Inc. in 3E E. Report Preparation 1. Annual report 10 $0 $0 1 10 16 160 16 8 $14,189 $0 16 2. Differential pressure monitoring report 10 $0 $0 1 10 16 160 16 8 $14,189 $0 16 3. Develop SOP for work practices 40 $0 $0 1 40 0 0 0 0 $0 $0 0 4. Affirmative defense 30 $0 $0 1 30 1 30 3 2 $3,141 $0 1 **Reporting Subtotal** 1550 155 78 $137,941 $170,380 33 4. Recordkeeping Requirements A. Read Instructions Inc. in 3A B. Implements Activities NA

## 20



# Table 3

**- Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary Lead**  **Smelters NESHAP**

**- Year 3** 

**Burden Item (A)**  **Respondent Hours per**  **Occurrence (Technical**  **hours) (B)** 

**Stack Testing**  **Cost Per**  **Occurre**
**nce (C)** 

**Other Non** 

**** **Labor Costs**  **Per Occurre** 
**nce (D)**  **Number of**  **Occurre nces Per**  **Respond ent Per**  **Year (E)** 

**Technic al Hours**  **per Respon**  **dent Per Year**  **(A X D) (F)** 

**N umber**  **of Respond**  **ents Per Year**  **(G)**

**Techni cal**  **Hours per**  **Year (E X F)**  **(H)**

**Clerical Hours**  **per Year (G X 0.1)**  **(I)**

**Managem ent Hours**  **per Year (G X .05)**  **(J)**

**Total Labor Costs Per**  **Year (K)** 

**Total Non** 

**** **Labor Costs Per**  **Year [(B+C)xD**  **xF] (L)** 

**Total Numb**  **er of Respo** 
**nses pe**  **r Year**  **(D X F) F** **o o** **t n** **o t** **e s** 

C. Develop Record System NA D. Record information 1. Records of fugitives 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 2. Records of flow weighted average for lead standard 1 $0 $0 1 1 16 16 2 1 $1,419 $0 0 3. Records of continuous pressure monitors 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 4. Records of power outages 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 5. Records of facility enclosure inspections 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 6. Records of startup and shutdown 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 7. Records of malfunctions 2 $0 $0 6 12 16 192 19 10 $17,027 $0 0 8. Records of actions taken during malfunctions 1 $0 $0 6 6 16 96 10 5 $8,514 $0 0 9. Records for BLDS 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 10. Records of furnace inspection 1 $0 $0 12 12 16 192 19 10 $17,027 $0 0 11. Records of recovery of plastic battery casing material 1 $0 $0 6 6 16 96 10 5 $8,514 $0 0 E. Personnel Training 8 $0 $0 1 8 0 0 0 0 $0 $0 0 F. Time for Audits NA **Recordkeeping Subtotal** 1744 174 87 $154,663 $0 0 **TOTAL** 3294 329 165 $292,604 $170,380 33 **Total Hours**  **Labor Non** 
**- Labor**  **Total**
**Summary**

**of Respondent Burden** 3,788 $292,604 $170,380 $462,98 4 **Initial Capital and Startup** $0 **An nualized Capital/Start** 
**- up and O &**  **M** $170,380

## 21



# Table 4

**- Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for**  **the Secondary Lead Smelters NESHAP**

**Year Technical** 

**Hours Clerical** 

**Hours Management** 

**Hours Total** 

**Labor Hours**  **Labor Costs Non** 

**- Labor**  **(Annualized Capital/Startup and**  **O&M) Costs Total Costs**  1 4,898 490 245 5,633 $437,514 $720,080 $1,157,594 2 3,554 355 178 4,087 $315,662 $430,380 $746,042 3 3,294 329 165 3,788 $292,604 $170,380 $462,984 Total 11,746 1,175 587 13,508 $1,045,780 $1,320,840 $2,366,620 Average 3,915 392 196 4,503 $348,593 $440,280 $788,873

## 22

**Table 5**
**- An**  **nual Designated A dministrator Burden and Cost of Recordkeeping and Reporting Requirements for the**  **Secondary**

**Lead Smelters NESHA P** 
**- Year 1** 

**(A )**  **(B) (C)**  **(D) (E)**  **(F) F** **o o** **t n** **o t** **e s** 

**Burden Item Number of**  **Occurrences Per Year**  **EPA**

**Hours Per**  **Occurrence Tech** 

**Hours Per Year**  **(C=A xB)**  **Ma nagement** 

**Hours Per Year (D=Cx0.05)**  **Clerical**

**Hours Per Year**  **(E=Cx0.1) EPA** 

**Cost Per**  **Year (**  **a,b)** 1. Applications not applicable 2. Read and Understand Rule Requirements 20 40 800 40 80 $41,458 a 3. Required Activities A. Observe stack tests 7 48 336 17 34 $17,412 b B. Excess emissions

-- Enforcement Activities 3 24 72 4 7 $3,731 c C. Create Information not applicable D. Gather Information not applicable E. Report Reviews 1. Review work practice SOP 16 10 160 8 16 $8,292 2. Review different presure monitoring report 16 3 48 2 5 $2,487 3. Review annual compliance report 16 10 160 8 16 $8,292 d F. Prepare annual summary report 1 64 64 3 6 $3,317 e

**TOTA L**  1640 82 164 $84,989



### FOOTNOTES
a Number of occurences is the number of states where affected sources will exist and each EPA Region (10 states + 10 EPA region s = 20 respondents). b Assumes EPA personnel attend 20 percent of the stack tests

. c Assume 10 percent of the facilities will exceed emissions. d Only hours to review new requirements.
e Using four hours per state to write annual summary report.

## 23

**Table 6**
**- An**  **nual Designated A dministrator Burden and Cost of Recordkeeping and Reporting**  **Requirements for the Secondary** 

**Lead Smelters NESHA P** 
**- Year 1** 

**(A )**  **(B) (C)**  **(D) (E)**  **(F) F** **o o** **t n** **o t** **e s** 

**Burden Item Number of**  **Occurrences Per Year**  **EPA**

**Hours Per**  **Occurrence Tech** 

**Hours Per Year**  **(C=A xB)**  **Ma nagement** 

**Hours Per Year (D=Cx0.05)**  **Clerical**

**Hours Per Year**  **(E=Cx0.1) EPA** 

**Cost Per**  **Year (**  **a,b)** 1. Applications not applicable 2. Read and Understand Rule Requirements 0 40 0 0 0 $0 a 3. Required Activities A. Observe stack tests 7 48 336 17 34 $17,412 b B. Excess emissions

-- Enforcement Activities 3 24 72 4 7 $3,731 c C. Create Information not applicable D. Gather Information not applicable E. Report Reviews 1. Review work practice SOP 0 10 0 0 0 $0 2. Review different presure monitoring report 16 3 48 2 5 $2,487 3. Review annual compliance report 16 10 160 8 16 $8,292 d F. Prepare annual summary report 1 64 64 3 6 $3,317 e

**TOTA L**  680 34 68 $35,239



### FOOTNOTES
a Number of occurences is the number of states where affected sources will exist and each EPA Region (10 states + 10 EPA region s = 20 respondents). b Assumes EPA personnel attend 20 percent of the stack tests.
c Assume 10 percent of the facilities will exceed emissions. d Only hours to review new requirements.
e Using four hours per state to write annual summary report.

## 24

**Table 7**
**- An**  **nual Designated A dministrator B**  **urden and Cost of Recordkeeping and Reporting Requirements for the Secondary** 

**Lead Smelters NESHA P** 
**- Year 1** 

**(A )**  **(B) (C)**  **(D) (E)**  **(F) F** **o o** **t n** **o t** **e s** 

**Burden Item Number of**  **Occurrences Per Year**  **EPA**

**Hours Per**  **Occurrence Tech** 

**Hours Per Year**  **(C=A xB)**  **Ma nagement** 

**Hours Per Year (D=Cx0.05)**  **Clerical**

**Hours Per Year**  **(E=Cx0.1) EPA** 

**Cost Per**  **Year (a**  **,b)** 1. Applications not applicable 2. Read and Understand Rule Requirements 0 40 0 0 0 $0 a 3. Required Activities A. Observe stack tests 7 48 336 17 34 $17,412 b B. Excess emissions

-- Enforcement Activities 3 24 72 4 7 $3,731 c C. Create Information not applicable D. Gather Information not applicable E. Report Reviews 1. Review work practice SOP 0 10 0 0 0 $0 2. Review different presure monitoring report 16 3 48 2 5 $2,487 3. Review annual compliance report 16 10 160 8 16 $8,292 d F. Prepare annual summary report 1 64 64 3 6 $3,317 e

**TOTA L**  680 34 68 $35,239



### FOOTNOTES
a Number of occurences is the number of states where affected sources will exist and each EPA Region (10 states + 10 EPA region s = 20 respondents). b Assumes EPA personnel attend 20 percent of the stack tests.
c Assume 10 percent of the facilities will exceed emissions. d Only hours to review new requirements.
e Using four hours per state to write annual summary report.

## 25

**Table 8**
**- Summary** 

**of A nnual Designated A** **dministrator Burden and Cost of Recordkeeping and Reporting Requirements for the Secondary**  **Lead Smelters NESHA P** 

**Year Technical** 

**Hours Management Hours**  **Clerical Hours Total Hours**  **Labor Costs Non** 

**- Labor**  **Costs Total**  **Costs** 1 1,640 82 164 1,886 $84,989 $0 $84,989 2 680 34 68 782 $35,239 $0 $35,239 3 680 34 68 782 $35,239 $0 $35,239 Total 3,000 150 300 3,450 $155,467 $0 $155,467 Average 1,000 50 100 1,150 $51,822 $0 $51,822

## 26

**ATTACHMENT 2** 

**. INFORMATION REQUIREMENTS** 

**-- --** **AMENDMENTS TO SECONDARY LEAD SMELTING**  **NESHAP**

**Requirement Citation for existing sources**  **Citation for new sources General Provisions citation**  Emission limits for vents §63.54 3 §63.54 3 Standards for Fugitive Emissions §63.54 5 §63.54 5 Monitoring §63.54 8 §63.54 8 N/A Notifications §63.54 9 §63.54 9 63.9 Recordkeeping and reporting requirements §63.5 50 §63.5 50
Reports of malfunctions that result in an exceedances of the standard for the purpose of affirmative defense §63.5 52 §63.5 52

Records §63.541 §63.541 63.10 Reports §63.541 §63.541 63.10