SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Area Sources: Polyvinyl Chloride and Copolymer Production, Primary 

Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals--Zinc, 

Cadmium, and Beryllium (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Area Sources: Polyvinyl Chloride and Copolymer Production, Primary Copper 

Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals--Zinc, Cadmium, and 

Beryllium (Renewal), EPA ICR Number 2240.04, OMB Control Number 2060-0596.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area 

Sources: Polyvinyl Chloride (PVC) and Copolymer Production, Primary Copper Smelting, 

Secondary Copper Smelting, and Primary Nonferrous Metals--Zinc, Cadmium, and Beryllium

were proposed on October 6, 2006, and promulgated on January 23, 2007. These regulations 

apply to new or existing polyvinyl chloride and copolymer production, (subpart DDDDDD), 

new and existing primary copper smelters (subpart EEEEEE), new secondary copper smelters

(subpart FFFFFF), and new or existing primary zinc production facilities (subpart GGGGGG) 

that are an area source of hazardous air pollutant (HAP) emissions. 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, subparts DDDDDD, EEEEEE, 

FFFFFF, and GGGGGG. 

The 2007 final area source rules for PVC and copolymer production in 40 CFR part 63, 

subpart DDDDDD, and primary beryllium production facilities (part of the primary nonferrous 

metals category) in sections 63.11165 and 63.11166 of 40 CFR part 63, subpart GGGGGG do 

not impose any new information collection burden. New and existing PVC and copolymer 

plants that are area sources are required to comply with the same testing, monitoring, 

recordkeeping, and reporting requirements as those in the National Emission Standard for 

Vinyl Chloride (40 CFR part 61, subpart F). The Office of Management and Budget (OMB) 

has previously approved the information collection requirements in 40 CFR part 61, subpart F 

(OMB control number 2060-0071, EPA ICR number 0186.10). New and existing primary 

beryllium production facilities that are area sources are required to comply with the same testing, 

monitoring, recordkeeping, and reporting requirements as those in the National Emission 

Standard for Beryllium (40 CFR part 61, subpart C). OMB has previously approved the 

information collection requirements in 40 CFR part 61, subpart C (OMB control number 2060-

0092, EPA ICR number 0193.08). Additionally, sources under subpart DDDDDD are also 

subject to the NESHAP for PVC and Copolymers Production promulgated on April 17, 2012; 

the burdens associated with the 2012 rule is covered under EPA ICR number 2454.01 for the 

two area sources. 
2

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 U. S.

Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of one 

affected facility at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of five respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. Of these

five facilities, three are primary copper smelters and two are primary zinc smelters.

OMB approved the currently active ICR without any “Terms of Clearance.”

None of the facilities in the United States are owned by state, local, tribal or the Federal 

government. They are all privately-owned, for-profit businesses. The burden to the “Affected 

Public” may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for 

Area Sources: PVC and Copolymer Production, Primary Copper Smelting, Secondary Copper 

Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium (Renewal). The 

burden to the Federal government is attributed entirely to work performed by either Federal 

employees or government contractors and may be found below in Table 2: Average Annual EPA 

Burden and Cost –NESHAP for Area Sources: PVC and Copolymer Production, Primary Copper 

Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and 

Beryllium (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: 
3

(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 PVC and copolymer, primary 

copper smelters, secondary copper smelters, and primary zinc production facilities 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, subparts DDDDDD, EEEEEE, FFFFFF, and GGGGGG.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance 

with the applicable regulations which where 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 standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 standards are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subparts

DDDDDD, EEEEEE, FFFFFF, and GGGGGG.
4

3(a) Non-duplication

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, duplication does not exist.

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 (77 FR 63813) on October 17, 2012. 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 EPA's Office of Compliance. OTIS is EPA’s 

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 and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) the American Zinc Association (AZA), at 

(202) 367-1151, and 2) the International Copper Association, Ltd., at (212) 251-7200. 

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.
5

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 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 (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting 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 under subpart 

DDDDDD are owners or operators of new and existing PVC and copolymers that are area 

sources of HAP. The North American Industry Classification System (NAICS) code 325211 

for (Facilities that Polymerize Vinyl Chloride Monomer to Produce PVC and/or Copolymers 

Products).

The respondents to the recordkeeping and reporting requirements under subpart EEEEEE 

are owners or operators of new and existing primary copper smelters that are area sources of 

HAP. The United States Standard Industrial Classification (SIC) code for the respondents 

affected by the standards is SIC 3331, which corresponds to the North American Industry 

Classification System (NAICS) code 331411 for Primary Smelting and Refining of Copper. 

The respondents to the recordkeeping and reporting requirements under subpart FFFFFF 
6

are owners or operators of new secondary copper smelters that are area sources of HAP. 

The SIC codes for the respondents affected by the standards are SIC 3341 and 3399, which 

corresponds to NAICS 331423 for Secondary Smelting, Refining, and Alloying of Copper. 

The respondents to the recordkeeping and reporting requirements under subpart 

GGGGGG are owners of operators of new and existing primary zinc smelters that are area 

sources of HAP. The SIC code for the respondents affected by the standards is SIC 3339, which 

corresponds to NAICS 331419 for Primary Smelting and Refining of Nonferrous Metal (except 

copper and aluminum). 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Area 

Sources: Polyvinyl Chloride and Copolymer Production, Primary Copper Smelting, Secondary 

Copper Smelting, and Primary Nonferrous Metals--Zinc, Cadmium, and Beryllium. 

A source must make the following reports:

Notifications

Notification of applicability 40 CFR 63.9(a)(2)

Notification of construction/ reconstruction 40 CFR 63.9(b)(5)

Notification of special compliance requirements 40 CFR 63.9(d)

Notification of performance test 40 CFR 63.9(c)

Notification of opacity/VE observations 40 CFR 63.9(f)

Additional CMS notifications 40 CFR 63.9(g)

Notification of compliance status 40 CFR 63.9(h)

Notification of changes in information 40 CFR 63.9(j)

Reports

Monthly emissions summary or quarterly report 63.11147(b), 63.11148(b)

Reports of deviation 63.11162(h)

Semiannual monitoring reports 63.11162(i)

Initial /repeat performance tests 40 CFR 63.7(e)(1)

40 CFR 63.6(h)(7)

A source must keep the following records:
7

Recordkeeping

Baghouse and monitoring information (COMS for sintering machine) 40 CFR 63.10

Information to demonstrate compliance: Continuous PM sampler and 

calculations of daily average emissions or COMS or BLDS (for 

existing sources) or PM CEMS and calculations of daily average 

emissions (new sources)

40 CFR 63.10

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 reduced the burden associated with monitoring and recordkeeping at a plant site

significantly. 

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 opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Adjust the existing ways to comply with any previously applicable instructions and 
8

Respondent Activities

requirements.

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

Observe initial performance tests and repeat performance tests if necessary.

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. 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 
9

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. 

Both 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

A majority of the respondents are large entities (i.e., large businesses). However, 

the impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: 

Polyvinyl Chloride and Copolymer Production, Primary Copper Smelting, Secondary Copper 

Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium (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 each of the subparts 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. Wherever appropriate, specific tasks 

and major assumptions have been identified. Responses to this information collection are 

mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond 

to, a collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 46 (Total Labor Hours from Table 1

below). 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.
10

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83 + 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2012, “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 only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

The only type of industry costs associated with the information collection activity in the 

regulations is labor costs. There are no capital/startup or operation and maintenance costs.

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 

$622. 

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

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 are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 
11

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 Area 

Sources: Polyvinyl Chloride and Copolymer Production, Primary Copper Smelting, Secondary 

Copper Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium (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 

five existing respondents will be subject to the standard. Of the five respondents, we estimate 

that there are three primary copper smelters and two primary zinc smelters. There are no 

existing secondary copper smelters in the U.S. It is estimated that no additional respondents per 

year will become subject. However, two respondents per year will effect process changes that 

necessitate initial applicability and compliance status reports. The overall average number of 

respondents, as shown in the table below is five per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

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 2 5 0 2 5

2 2 5 0 2 5

3 2 5 0 2 5

Average 2 5 0 2 5

1

New respondent 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 five. 

The total number of annual responses per year is calculated using the following table: 
12

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

Write Report

 Monitor per Title V permit 5 0 0 0

 Notification of initial applicability 2 1 0 2

 Initial/repeat performance tests 5 0 0 0

 Notification of initial compliance status 2 1 0 2

 Reports per Title V permit 5 0 0 0

Total Number of Annual Responses Total 4

The number of Total Annual Responses is 4.

The total annual labor costs are $4,454. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost –NESHAP for Area Sources: Polyvinyl 

Chloride and Copolymer Production, Primary Copper Smelting, Secondary Copper Smelting, 

and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium (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 46 hours at a cost of $4,454. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost –NESHAP for 

Area Sources: Polyvinyl Chloride and Copolymer Production, Primary Copper Smelting, 

Secondary Copper Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium 

(Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection 

of information is estimated to average 12 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are zero. 

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 14
13

labor hours at a cost of $622. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Area Sources: Polyvinyl Chloride and Copolymer Production, Primary Copper 

Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and 

Beryllium (Renewal).

6(f) Reasons for Change in Burden

There is no change in labor hours in this ICR compared to the previous ICR. This is due 

to two considerations. First, the regulations have not changed over the past three years and are 

not anticipated to change over the next three years. Secondly, the growth rate for the industry is 

very low, negative or non-existent, so there is no significant change in the overall burden. 

However, there is an increase in labor costs from the most recently approved ICR due to an 

adjustment in labor rates. This ICR uses updated labor rates from the Bureau of Labor Statistics 

to calculate burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 12 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-2012-0702. 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 
14

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2012-0702 and OMB Control Number 2060-0596 in any 

correspondence. 

Part B of the Supporting Statement

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

information.
15

 Table 1: Annual Respondent Burden and Cost –NESHAP for Area Sources: Polyvinyl Chloride and Copolymer Production, 

Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium

 (Renewal)

Burden item

(A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(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. Surveys and studies N/A

3. Reporting requirements

 a. Read instructions d8 1 8 2 16 0.8 1.6 $1,781.65 

 b. Required activities

 Monitor per Title V permit c2 1 2 0 0 0 0 $0

 Initial/repeat performance tests e4 1 4 0 0 0 0 $0

 Initial notification of applicability 4 1 4 2 8 0.4 0.8 $890.83

 Initial notification of compliance status f8 1 8 2 16 0.8 1.6 $1,781.65 

 Reports per Title V permit c2 1 2 0 0 0 0 $0

 c. Create information See 3B

 d. Gather existing information See 3B

 e. Write report See 3B

Subtotal for Reporting Requirements 46 $4,454.13

4 Recordkeeping requirements

 a. Read instructions See 3A

 b. Plan activities See 3A

 c. Implement activities See 3A

 d. Record all data required by Title V permit c0.25 1 0.25 0 0 0 0 $0
16

Burden item

(A) 

Person hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per year 

(Ex0.1)

(H) 

Total 

Cost per 

Year, $b

 e. Time to transmit or disclose information c0.25 1 0.25 0 0 0 0 $0

 f. Time to train personnel 4 1 4 0 0 0 0 $0

 g. Time for audits N/A

Subtotal for Recordkeeping Requirements 0

TOTAL LABOR BURDEN AND COST (rounded) 46 $4,454 

Assumptions:

a

 We have assumed that the average number of respondents potentially subject to this rule is five. Each year two respondents are anticipated to effect process changes 

requiring notification to the Agency regarding applicability and compliance status. There will be no additional new sources over the three-year period of this ICR.

b

 This ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, 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.

c

 We have assumed that no hours or costs are associated with this burden item because existing plants are already complying with the requirement in their Title V operating 

permit.

d

 We have assumed that it will take eight hours for each respondent to read instructions.

e We have assumed that an existing facility may certify initial compliance based on previous PM test; no new test is required.

f We have assumed that it will take eight hours for each respondent to complete the initial notification of compliance status report.
17

 Table 2: Average Annual EPA Burden and Cost –NESHAP for Area Sources: Polyvinyl Chloride and Copolymer Production,

 Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous Metals—Zinc, Cadmium, and Beryllium

 (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) 

Respondents 

per year a

(E) 

Technical 

personhours 

per year 

(CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G)

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

Total Cost 

per Year, $b

Report review

 Initial notification of applicability c2 1 2 2 4 0.2 0.4 $207.29

 Initial notification of compliance status c4 1 4 2 8 0.4 0.8 $414.60 

Subtotals Labor Burden and cost 12 0.6 1.2 $621.89 

TOTAL ANNUAL BURDEN AND COST (rounded) 14 $622 

Assumptions:

a

 We have assumed that the average number of respondents potentially subject to this rule will be five. Each year two respondents are anticipated to effect process 

changes requiring notification to the Agency regarding applicability and compliance status. They are all area sources. There will be no additional new sources over 

the three-year period of this ICR.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 

Managerial rate (GS-13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (GS-6, Step 3, $15.63 x 1.6). These rates are 

from the Office of Personnel Management (OPM) 2012 General Schedule, which excludes locality rates of pay.

c

 We have assumed that it will take each respondent 2 hours to review the initial notification of applicability report.

d

 We have assumed that it will take each respondent 4 hours to review the initial notification of compliance status report.