SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Area Sources: Primary Copper Smelting, Secondary Copper Smelting, 

and Primary Nonferrous Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, 

Subparts EEEEEE, FFFFFF, and GGGGGG) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Area Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary 

Nonferrous Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, 

FFFFFF, and GGGGGG) (Renewal), EPA ICR Number 2240.05, OMB Control Number 2060-

0596.

1(b) Short Characterization/Abstract

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

Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous 

Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and 

GGGGGG1

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

regulations apply to new and existing primary copper smelting facilities (Subpart EEEEEE), new 

secondary copper smelting facilities (Subpart FFFFFF), and new and existing primary zinc or 

beryllium 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 EEEEEE, FFFFFF, and GGGGGG.

The 2007 final area source rule for primary beryllium production facilities (part of the 

primary nonferrous metals category) in Subpart GGGGGG does not impose any new information 

collection burden. 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 approved the information collection requirements previously in 40 CFR Part 61, 

Subpart C under EPA ICR Number 0193.08, OMB Control Number 2060-0092. Therefore, this 

burden is not covered under this ICR. 

In general, all NESHAP standards require initial notification reports, 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, 

1 Note the title of this ICR has been revised to remove the NESHAP for Polyvinyl Chloride and Copolymer 

Production Area Sources (40 CFR Part 63 Subpart DDDDDD). The burden associated with this Subpart is covered 

under the EPA ICR Number 2454.02, OMB Control Number 2060-0684.

 
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and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file containing 

these documents, and retain the file for at least five years following the generation date of such 

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.

The “Affected Public” are owners and operators of new and existing primary copper 

smelting facilities, new secondary copper smelting facilities, and new and existing primary zinc 

or beryllium production facilities that are area sources of HAP. There are three primary coppersmelting and two primary zinc-smelting facilities, which are owned and operated by the primary 

copper and zinc smelting industry. None of the five facilities in the United States are owned by 

either state, local, tribal or the Federal government. They are all owned and operated by 

privately-owned, for-profit businesses. We assume that they will all respond to EPA regulations.

The “burden” to the Affected Public may be found below in Table 1: NESHAP for Area 

Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous 

Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and 

GGGGGG) (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: Primary Copper 

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

Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and GGGGGG) (Renewal).

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

affected facilities 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, approximately five respondents (three primary copper smelters 

and two primary zinc smelters) per year will be subject to these standards, and no additional 

respondents per year will become subject to these same standards.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance”.

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 
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114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, HAP emissions from primary copper smelters, 

secondary copper smelters, and primary zinc production facilities either cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, 

the NESHAP were promulgated for this source category at 40 CFR Part 63, Subparts EEEEEE, 

FFFFFF, and GGGGGG.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards 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 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 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.
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3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subparts 

EEEEEE, FFFFFF, and GGGGGG.

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 (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. 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 these standards as they were being developed and these

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the International Zinc 

Association (IZA), at (919) 361-4647; and 2) the International Copper Association, Ltd., 

at (212) 251-7240.

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

Instances of less-frequent information collection would decrease the margin of assurance 
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that facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less-frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of a 

source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (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 these standards do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and 

operators of new and existing primary copper smelters, new secondary copper smelters, and new 

and existing primary zinc smelters that are area sources of HAP. The United States Standard 

Industrial Classification (SIC) codes for the respondents affected by the standards and the 

corresponding North American Industry Classification System (NAICS) codes can be found in 

the table below.
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Standard (40 CFR Part 63, Subparts EEEEEE, 

FFFFFF, and GGGGGG) SIC Codes NAICS Codes

Nonferrous Metal (except Aluminum) Smelting and 

Refining 3331, 3339 331410

Copper Rolling, Drawing, Extruding, and Alloying 3341 331420

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: Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous 

Metals-Zinc, Cadmium, and Beryllium (Renewal).

A source must make the following reports:

Notifications

Notification of applicability 63.9(a)

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

Notification of special compliance requirements 63.9(d)

Notification of performance test 63.9(e)

Notification of opacity/VE observations 63.9(f)

Additional CMS notifications 63.9(g)

Notification of compliance status 63.9(h)

Notification of changes in information 63.9(j)

Notification of deviations 63.11147(d), 

63.11162(h)

Reports

Monthly emissions summary or quarterly report 63.11147(b)(6)

Reports of deviation 63.11147(d), 

63.11162(h)

Semiannual monitoring reports 63.11147(e), 

63.11162(i)

Excess emissions and monitoring systems reports 63.11148(h)

Initial /repeat performance tests 63.7(e)(1)
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Reports

63.6(h)(7), 

Compliance Reports

A source must keep the following records:

Recordkeeping

Baghouse and monitoring information (COMS for sintering machine) 63.10, 63.11147(f), 

63.11155(d)(4), 

63.11162(j), 

63.11163(d)(4)

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)

63.10, 

63.11148(g)(2), 

63.11155(c)

Startup, shutdown, or malfunction 63.11148(g)(1)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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 
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Respondent Activities

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 

requirements.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

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 Enforcement and Compliance History Online (ECHO) 

and ICIS.

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 
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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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters.

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

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: 

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

Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and GGGGGG)

(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. Where 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.
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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 74 hours (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 previouslyapproved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The 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 are 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 

$628.
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This cost is based on the average hourly labor rate as follows:

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

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

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

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

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

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Area 

Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary Nonferrous 

Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and 

GGGGGG) (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 these standards. Of the five respondents, three are 

primary copper smelters and two are 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 have 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

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 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 respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 
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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:

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 Reports

 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 4

The number of Total Annual Responses is 4.

The total annual labor costs are $7,400. Details regarding these estimates may be found 

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

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

and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and GGGGGG) (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 below, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 74 hours. Details regarding these estimates may be found 

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

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

and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and GGGGGG) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.
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Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 18 (rounded) 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

labor hours at a cost of $628. See below in Table 2: Average Annual EPA Burden and Cost –

NESHAP for Area Sources: Primary Copper Smelting, Secondary Copper Smelting, and Primary 

Nonferrous Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, 

FFFFFF, and GGGGGG) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is a small adjustment increase in respondent burden hours and cost as currently 

identified in the OMB Inventory of Approved Burdens. The increase is due to a change in 

assumption. In this ICR, we assume all existing sources will take some time each year to refamiliarize themselves with the regulatory requirements.

6(g) Burden Statement

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

is estimated to average 18 hours per response. “Burden” means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

either 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.
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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), WJC West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. 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.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Primary Copper Smelting, Secondary Copper 

Smelting, and Primary Nonferrous Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and 

GGGGGG) (Renewal)

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(F=Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(G=Ex0.1)

(H) 

Total 

Cost per 

Year, $b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

 a. Familiarize with regulatory 

requirements d 8 1 8 5 40 2 4 $4,625.82 

 b. Required activities

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

 Initial/repeat performance testse 4 1 4 0 0 0 0 $0 

 Initial notification of 

applicability 4 1 4 2 8 0.4 0.8 $925.16 

 Initial notification of 

compliance status f 8 1 8 2 16 0.8 1.6 $1,850.33 

 Reports per Title V permit c 2 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 74 $7,401 

4 Recordkeeping requirements
16

 a. Familiarize with regulatory 

requirements See 3A

 b. Plan activities See 3A

 c. Implement activities See 3A

 d. Record all data required by 

Title V permit c 0.25 1 0.25 0 0 0 0 $0 

 e. Time to transmit or disclose 

information c 0.25 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 $0 

TOTAL LABOR BURDEN AND 

COST (rounded)g 74 $7,400 

CAPITAL AND O&M COST 

(rounded)g $0 

GRAND TOTAL (rounded)g $7,400 

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: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and 

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, Table 2. Civilian Workers, 

by occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110 percent to account for the benefit 

packages available to those employed by private industry.

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 familiarize with regulatory requirements. 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. g

 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Area Sources: Primary Copper Smelting, Secondary Copper 

Smelting, and Primary Nonferrous Metals-Zinc, Cadmium, and Beryllium (40 CFR Part 63, Subparts EEEEEE, FFFFFF, and 

GGGGGG) (Renewal)

Activity

(A) 

EPA

person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

person 

hours 

per 

plant 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(F=Ex0.05)

(G)

Clerical 

person 

hours per 

year 

(G=Ex0.1)

(H) 

Total 

Cost 

per 

Year, 

$b

1. Report review

 a. Initial notification of applicability c 2 1 2 2 4 0.2 0.4 $209.36 

 b. Initial notification of compliance statusd 4 1 4 2 8 0.4 0.8 $418.72 

TOTAL ANNUAL BURDEN AND 

COST (rounded)e 14 $628 

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: $62.90 

Managerial rate (GS-13, Step 5, $39.31 x 1.6), $46.67 Technical rate (GS-12, Step 1, $29.17 x 1.6), and $25.25 Clerical rate (GS-6, Step 3, $15.78 x 1.6). These 

rates are from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay. c

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

d

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

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