**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR**  **Part 61, Su bpart N)**  **(Renewal)**
**1. Identification of the Information Collection 1(a) Title**  **of the Information Collection** NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR P art 61, S ubpart N) (Renewal) , EPA I CR 1081. 10 , OMB Control Number 2060

- 0043 **1(b) Short Characterization/Abstract** The National Emission Stand ards for Hazardous Air Pollutants (NESHAP) for Inorganic Arsenic Emissions from Glass Manufacturing Plants were proposed on July 20, 1983 , and promulgated on August 4, 1986. The standards were amended on both May 31, 1990 and October 17, 2000. These standards appl y to each glass melting furnace that uses commercial Arsenic as a raw material. These standards do not apply to pot furnaces. Also, re

- bricking is not considered construction or modification for the purposes of 40 CFR Section 61.05(a). This information is being collected to assure compliance with 40 CFR part 61, subpart N. 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 sy stem is inoperative. These notifications, reports, and records are es sential in determining compliance, and are required of all sources subject to NESHAP. Any owner / operator subject to the provisions of this part will maintain a file of these measurements, and retain the file for at least two 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 directl y to the U

. S

. Environmental Protection Agency (EPA) reg ional office. Based on consultation with industry representatives during a previous renewal of this ICR , there is an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant sit e). Over the next three ye ars, an average of 16 respondents per ye ar will be subject to the standard, and no additional respondents per year will become subject to the standard. The Office of Management and Budget (OMB) approved the current Information Collection Request (I CR) without any “ Terms of Clearance. ”2

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by either F ederal employees or government contractors; this burden may be fo und below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (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 (HAP) . These standards are applicable to new or e x isting sources of (HAP) and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such reco rds; (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 accord ance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, arsenic emissions from glass manufacturing plants either cause or contribute to air pollution that may reason ably

be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 61, subpart N. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard s ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standards. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test, a record of the operating parameters under which compliance was achieved may be recorded and used to3

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 ensure that the pollution control devices are properl y installed an d operated, that leaks are being detected and repaired, and that 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 61, subpart N. **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 directl y 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 cop y of the report submitted to the state or a local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists. **3(b) Public N otice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (7 6 FR 269 00 ) on May 9 , 20 11 . No comments were received on the burden published in the Federal Regi ster

. **3(c) Consultations**
The Agency ’s industry

experts were consulted, and the Agency ’s internal data sources and projections of industry growth over the next three ye ars were considered during a previous renewal of this I CR. The primary source of info rmation as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, was the Online Tracking In formation Sy stem (OTIS) which is operated and maintained by the EPA Office of Compliance. OTI S is the EPA database fo r the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry was based on our consultations with the Agency ’s internal industry experts. We estimated that approximately 16 respondents would be subject to the standard over the three

- year period covered b y this I CR. Industry trade association 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 f or compliance4

purposes. For this renewal, we consulted with : 1) the Glass Industry Consulting Internation al , at (949) 493

- 7293 ; 2) the Glass Manufacturing Industry Council , at (614) 818

- 9423 : and 3) the National Glass Association at (866) 342

- 5642 . No comments were received on this I CR

. 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 f irst Federal Register n otice. 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 frequentl y, the proper operation and maintenance of control equipment and the p ossibility

of detecting violations would be less likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by

OMB at 5 CFR p art 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notification s for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar 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 th e appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five ye ars. 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.5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are glass manufacturing plants. The Standard Industrial Classification (SIC) codes for the respondents affected b y the standards, which correspond to the North American Industry Classificatio n Sy stem (NAI CS) codes, are listed below for glass manufacturing plants

.

**Standard (40 CFR part**  **61, subpart N) SIC Codes**  **NAICS Codes** Flat Glass Manufacturing 3211 327211 Glass Container Manufacturing 3221 327213 Other Pressed and Blown Glass and Glassware Manufacturing 3229 327212
Mineral Wool Manufacturing 3296 327993 **4(b) Information Requested**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items**
In this ICR , all the data that are recorded or reported are required by the NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR P art 61, S ubpart N). A source must make the following reports:
**Notifications** Notification and application of construction or modification 61.06 , 61.07 Notification of anticipated date of initial startup 61.09(a)(1) Notification of actual startup 61.09(a)(2) Notification of initial performance emissions test 60.13(c), 61.165(d)(2)6 **Reports** Source status report 61.10(a) Report initial performance emissions test results 61.13(f), 61.165(d)(2) Report of arsenic emission estimates 61.165(d)(3) Report of uncontrolled arsenic emission rates 61.165(d)(4) Request approval of control device b ypass 61.165(e) Report of results of continuous monitoring sy stem (CMS) evaluation 61.165(f)(1) Semiannual report of excess emissions (opacity) 61.165(f)(2) A source must keep the following records: **Recordkeeping** Record continuous opacity and temperature of gas entering control device 61.165(a)(1)

Records of emission test results and other data needed to determine emissions 61.13(g), 61.165(a)(2)
Records of CMS performance evaluations 61.165(a)(3) Occurrence and duration of startup, shutdown, and malfunction of furnace 61.165(a)(4)
Malfunction of air pollution control device 61.5165(a)(5) Periods when monitors are inoperative 61.165(a)(6) Maintenance and repair of control device, CMS or monitor 61.165(a)(7) Records of approved control device b ypass 61.165(b) Semiannual records of uncontrolled arsenic emission rate 61.165(c) Records are required to be retained for two (2) years 61.14(f)
Electronic Reporting Currently , respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must evaluate the data, this internal automation has significantly reduced the burden associated with m onitoring and recordkeeping at the plant site. Also, regulatory

agencies , in cooperation with the respondents, continue to create7

reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems 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 wet scrubber. Perform initial performance test, Reference Methods 1, 2, 3, 5D, and 108 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently , sources are using automated monitoring equipment that provides parameter data in an automated way e.g., continuous parameter monitoring s ys tem . Although personnel at the sources still need to evaluate the data, this type of monitoring equipment has significantl y 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,8

storage, and distribution of the required infor mation. **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, anal yz e, and maintain data in the Online Information Tracking S ys tem (OTI S)

. **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to compl y with the emission standard, and note the operating conditions under which complia nce was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses OTI S 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 analyze the data. The records required b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility**
A m ajority

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. The number of small entities affected by this rule could not be determined, based on review of the following sources: the promulgated rule notice in the Federal Register (51 FR 27956 ) on August 4, 1986 ; the Inorganic Arsenic Emissions from Glass Manufacturing Plants Background Information for Proposed S tandards (1983); and a search of publicly available current data sources. Based on the Background Information document, about 70 percent of glass plants are considered to be small firms; however, arsenic usage b y these small firms is not known.9

Due to te chnical 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 requirements the minimum 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 frequenc y for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, S ubpart N) (Renewal). **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. 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 n ext three years from these recordkeeping and reporting requirements is estimated to be 3, 080 (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 previousl y approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rates are from the U

. S

. Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2. Civilian Workers, by O ccupational and Industry group. ” The rates are from C olumn 1,10

“ Total comp ensation. ” 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 ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation**  **and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

Continuous Opacity Monitor N/A N/A $0 $3,000 16 $48,000

Tem perature Monitor N/A N/A $0 $500 16 $8,000

Totals $0 $56,000 The total capital/startup costs for this I CR are zero. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $56,000. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the IC R is estimated to be $56,000. **6(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 activ ities 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 estimat ed to be11

$4, 457

. This cost is based on the average hourl y labor rate as follows:

Managerial $ 62.27 (GS

- 13, Step 5, $3 8.92 + 60% ) Technical $4 6.21 (GS

- 12, Step 1, $2 8.88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $1 5.63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 11 General Schedule which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government emplo ye es. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 16 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject to the standard in the next three years. The ov erall average number of respondents, as shown in the table below , is 16 per ye ar. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records but Do Not Submit Reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 16 0 0 16 2 0 16 0 0 16 3 0 16 0 0 16 Average 0 16 0 0 16 As shown above, the average ‘ Number of Respondents ’ over the three ye ar period of this ICR is 16. The total number of annual responses per ye ar 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
Application of construction or modification 0 0 N/A 0 Notification of anticipated startup 0 0 N/A 0 Notification of actual startup 0 0 N/A 0 Source status report 0 0 N/A 0 Notification of initial performance emission test 0 0 N/A 0 Notification of physical or operation change 0 0 N/A 0 Report of arsenic emission estimates 15 2 N/A 30 Report of uncontrolled arsenic emission rates 15 2 N/A 30 Request approval of control device bypass 1 1 N/A 1 Semiannual excess emissions (opacity) 1 2 N/A 2 Total 63 The number of Total Annual Responses is 63. The total annual labor costs are $ 295,094

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal). **6(e) Bottom Line Burden Hours 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, respectivel y , and summarized below. **(i) Respondent Tally** The estimated annual burden is 3080 hours and $ 295,094 in labor costs

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR P art 61, Subpart N) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 49 hours per response.13

The total annual capital/startup and O&M costs to the regulated entity are $56,00 0. 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 99 labor hours at a cost of $ 4, 457 . See below Table 2 : Average Annual EPA Burden and Cost

- NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal). **6(f) Reasons for Change in Burden**
There is a decrease in the labor hours to the respondents in this I CR compared to the previous I CR. This is due to a calculation error in the burden estimate for the previous ICR.
There is an increase in the total respondent and Agency costs as currently identified in the OMB Inventory of approved Burdens . This increase is not due to any program changes. The change in cost estimated reflects updated labor rates available from the Bureau of Labor Statistics. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 49 hours per response. “ Burden ” means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 ’ s 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0 245

. 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 the14

contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52 . Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0 245 an d OMB Control Number 2060

- 0043 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 Inorganic Arsenic Emissions**  **from Glass Manufacturing Plants (CFR**  **P art**  **61, S**  **ubpart N)**  **(Renewal) Burden item**  **(A) Technical**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Technical Person** 
**** **hours per respondent**  **per year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hou r**  **s per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total person**  **** **hours per year**  **(I)**

**Total Cost per**  **year b** 

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read Instructions c 1 1 1 0 0 0 0 0 $0 B. Required Activities N/A Initial performance
emission tests d 80 1 80 0 0 0 0 0 $0 Repeat of performance emission tests 80 0.2 16 0 0 0 0 0 $0 C. Create information Included in 3B D. Gather existing information Included in 3B E. Write report Application of construction or modification 2 1 2 0 0 0 0 0 $0 Notification of anticipated startup 2 1 2 0 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 0 $0 Source status report 2 1 2 0 0 0 0 0 $0 Notification of initial performance emission test 2 1 2 0 0 0 0 0 $0 Report of initial performance emission test Included in 3B Notification of physical or operation change 2 1 2 0 0 0 0 0 $0 Report results of continuous monitoring system (CMS) evaluation Included in 3B16

**Table 1: Annual Respondent Burden and Cost**
**- NESHAP for Inorganic Arsenic Emissions**  **from Glass Manufacturing Plants (CFR**  **P art**  **61, S**  **ubpart N)**  **(Renewal) Burden item**  **(A) Technical**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Technical Person** 
**** **hours per respondent**  **per year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hou r**  **s per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total person**  **** **hours per year**  **(I)**

**Total Cost per**  **year b** 

Report of arsenic emission estimates e 16 2 32 15 480 24 48 552 $52,892 Report of uncontrolled arsenic emission rates f 8 2 16 15 240 12 24 276 $26,446 Request approval of control device bypass g 6 1 6 1 6 0.3 0.6 6.9 $661 Semiannual excess
emissions (opacity) h 16 2 32 1 32 1.6 3.2 36.8 $3,526 **Subtotal for Reporting Requirements**  871.7 4. Recordkeeping Requirements A. Read instructions Included in 3A B. Plan activities Included in 3B C. Implement activities Included in 3B D. Develop record system N/A E. Time to enter information i 40 1 40 16 640 32 64 736 $70,523 Record continuous opacity and temperature of gas entering control device Included in 4E
Records of emission test results Included in 4E Records of CMS performance evaluations Included in 4E Occurrence and duration of startup, shutdown, and malfunction of furnace Included in 4E
Records of malfunction of control device Included in 4E17

**Table 1: Annual Respondent Burden and Cost**
**- NESHAP for Inorganic Arsenic Emissions**  **from Glass Manufacturing Plants (CFR**  **P art**  **61, S**  **ubpart N)**  **(Renewal) Burden item**  **(A) Technical**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Technical Person** 
**** **hours per respondent**  **per year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hou r**  **s per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total person**  **** **hours per year**  **(I)**

**Total Cost per**  **year b** 

Periods when monitors are inoperative Included in 4E Maintain and repair of co ntrol device, CMS, or mo nitors Included in 4E
Records of approved control device bypass Included in 4E Semiannual records of uncontrolled arsenic emission rate j 40 2 80 16 1,280 64 128 1,472 $141,046 F. Time to train personnel N/A G. Time for audits N/A **Subtotal for Recordkeeping Requirements**  2, 208 **Total Reporting and Recordkeeping**  2,678 134 268 3, 079.7 $295,094 **TOTAL LABOR BURDEN**  **AND COST (rounded) 3,080**  **$295,094**

**Assu mptions:**  a We have assumed that there are sixteen existing sources, and that no additional new sources will become subject to the rule over the next three years. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, Septem ber , 20 11 , “ Table 2 : Civilian Workers, by O ccupational and I ndustry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. c We have assumed that it will take one hour to read instructions. d We have a ssumed that it will take eighty hours to complete performance test. e We have assumed that fifteen respondents will write report of arsenic emission estimates on a semiannual basis. f We have assumed that fifteen respondents will write report of uncontro lled arsenic emission rates on a semiannual basis.18

g We have assumed that one respondent will write report requesting approval of control device bypass once a year. h We have assumed that one respondent will write an excess emissions rep ort semiannually. i It will take each respondent forty hours to enter information. j It will take each respondent forty hours twice a year to record uncontrolled arsenic emission rate.19

**Table 2: Average Annual EPA Burden and Cost** 
**- NESHAP for Inorganic Arsenic Emissions from Glass**  **M anufacturing Plants (CFR**  **P art 61,**  **Subpart N)**  **(Renewal)**
**Burden Item (A)**  **Technical Person** 
**** **hours per occurrence**  **(B)**

**No. of occurrences**  **per year (C)** 

**Technical Person** 
**** **hours per Plant per**  **year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hou r**  **s per year**  **(E=CxD) (F)** 

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total Cost per**  **year b** 

Initial performance test New facility c 24 1 24 0 0 0 0 $0 Repeat performance test New facility d 24 0.2 4.8 0 0 0 0 $0 Revie w reports New facility Construction or mo dification application 0.5 1 0.5 0 0 0 0 $0 Notification of anticipated startup 0.5 1 0.5 0 0 0 0 $0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $0 Source status report 0.5 1 0.5 0 0 0 0 $0 Notification of initial performance emissions test 0.5 1 0.5 0 0 0 0 $0 Report of initial performance emissions test results 8 1 8 0 0 0 0 $0
Notification of physical or operational change 0.5 1 0.5 0 0 0 0 $0 Notification of emissions test 0.5 1 0.5 0 0 0 0 $0 Report results of CMS evaluation 8 1 8 0 0 0 0 $0 Existing facility Report of arsenic 4 1 4 15 60 3 6 $3,10920

**Table 2: Average Annual EPA Burden and Cost** 
**- NESHAP for Inorganic Arsenic Emissions from Glass**  **M anufacturing Plants (CFR**  **P art 61,**  **Subpart N)**  **(Renewal)**
**Burden Item (A)**  **Technical Person** 
**** **hours per occurrence**  **(B)**

**No. of occurrences**  **per year (C)** 

**Technical Person** 
**** **hours per Plant per**  **year (C=AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hou r**  **s per year**  **(E=CxD) (F)** 

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Total Cost per**  **year b** 

emission estimates rates e Reports of uncontrolled arsenic emission rates f 8 1 8 1 8 0.4 0.8 $415 Semiannual excess
emissions g 6 2 12 1 12 0.6 1.2 $622 Request approval of control device bypass h 6 1 6 1 6 0.3 0.6 $311 Subtotals Labor Burden and Cost 86 4.3 8.6 $4,457 **TOTAL LABOR BURDEN AND COST**  **(rounded) 99**  **$4,457**

**Assu mptions:**  a We have assumed that there are sixteen existing sources, and that no additional new sources will become subject to the rule over the next three years. b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to acc ount for government overhead expenses: $ 62. 2 7 for Managerial (GS

- 13, Step 5, $ 38.92 x 1.6), $4 6.21 for Technical (GS

- 12, Step 1, $2 8.88 x 1.6) and $2 5.01 Clerical (GS

- 6, Step 3, $1 5.63 x 1.6). These rates are from the Office of Personnel Management (OPM)

“ 2004 General Schedule ” which excludes locality rates of pay. c We have assumed that it will take twenty four hours to perform initial performance test. d We have assumed that it will take twenty four hours to repeat performance test. e We have as sumed that fifteen respondents will be required to review the report of arsenic emission estimates rates once a year. f We have assumed that it will take eight hours to review reports of uncontrolled arsenic emission rates once a year. g It is required that excess emissions reports are reviewed on a semiannual basis. h We have assumed that one respondent will review a report requesting approval of control device bypass once a year.