SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal), EPA ICR 

Number 1850.07, OMB Control Number 2060-0476. 

1(b) Short Characterization/Abstract

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

Copper Smelters were proposed on April 20, 1998 and June 26, 2000, and promulgated on June 

12, 2002. These regulations were most recently modified on April 20, 2006. These regulations 

apply to existing and new affected sources at primary copper smelter facilities; the affected 

sources include copper concentrate dryer, smelting furnace, slag cleaning vessel, copper 

converter department, and the entire group of fugitive emission sources. Owners and operators 

of a primary copper smelter are subject to the regulation only if it is a major source of hazardous 

air pollutant (HAP) or has the potential to emit any single HAP at the rate of 10 tons or more per 

year or any combination of HAP at a rate of 25 tons or more per year. 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, Subpart QQQ.

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.

There are approximately three primary copper smelter plants in the United States which 

are owned and operated by the copper smelter industry. All three are owned and operated by

privately-owned, for-profit businesses. Over the next three years, an average of three respondents 

per year will be subject to standard and will be subject to 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. No additional respondents per year will become subject to the standard. 

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 United States Environmental 

Protection Agency (EPA) regional office. 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.
2

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 

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 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,

Subpart QQQ.

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 
3

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. Nonduplication, Consultations, and Other Collection Criteria

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

QQQ.

3(a) Nonduplication

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, no 

duplication exists.

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 (79 FR 30117) on May 27, 2014. 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). The 

database is operated and maintained by EPA's Office of Compliance which is used 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 both the United States Geological Survey at

(703) 648-4978 and the American Copper Council at (212) 945-4990.
4

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.

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 (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
5

The respondents to the recordkeeping and reporting requirements are primary copper 

smelters. 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) 331411 for Primary Smelting and Refining of Copper. 

4(b) Information Requested

(i) Data Items

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

Primary Copper Smelters (40 CFR Part 63, Subpart QQQ).

A source must make the following reports:

Notifications

Initial notification 63.1454(a), 63.9(b)

Notification of performance test 63.1454(d), 63.7, 

63.9(e)

Notification of compliance status 63.1454(e), 63.9(h)

Reports

Performance test reports 63.1454(a), 

63.10(d)

Semiannual summary reports 63.1454(b), 

63.10(e)

A source must keep the following records:

Recordkeeping

Records of startup, shutdown, and malfunctions

63.1456(a)(2), 

63.1454(c), 

63.10(b)(2)

Records of air pollution control equipment maintenance, malfunctions, 

and corrective actions

63.1456(c), 

63.1454(c), 

63.10(b)(1)

Records of performance tests and other supporting documentation used 

to demonstrate compliance with relevant standards under the rule

63.1456(a)(5), 

63.1450(c), 

63.10(b)(2)

Records of monthly capture system visual inspection 63.1450(c), 
6

Recordkeeping

63.10(b)(2)

Records of converter capture system operating parameter monitoring 

system performance, calibration, and maintenance

63.1450(c), 

63.10(b)(2)

Records of control device operating parameter monitoring system 

performance, calibration, and maintenance

63.1450(c), 

63.10(b)(2)

Records of control device or converter capture system operating 

parameter deviations

63.1450(c), 

63.10(b)(2)

Copy of site-specific air pollution equipment startup, shutdown, and 

malfunction plan

63.1450(c), 

63.6(e)(3)

Copy of site-specific smelter fugitive dust control plan 63.1448(a)

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. 

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, Reference Method 1, 2F, 2G, 3, 3A, 3B, 4, 5, 5D, 17, 29 

tests, 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.
7

Respondent Activities

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.

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

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, and note the operating conditions under which compliance 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.
8

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 

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. 

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 Primary Copper 

Smelters (40 CFR Part 63, Subpart QQQ) (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 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.

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 9,380 (Total Labor Hours from Table 1). 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.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs
9

This ICR uses the following labor rates: 

Managerial $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

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 type 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 monitors 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)

Monitoring

control device $2,800 0 $0 $1,540 3 $4,620

Monitoring 

converter hood $10,800 0 $0 $1,200 3 $3,600

$0 $8,220

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. The total operation and maintenance (O&M) costs for this ICR are $8,220. 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 years of the ICR is estimated to be $8,220. These are 

recordkeeping costs. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are 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 
10

publication and distribution of collected information. The average annual Agency cost during the 

three years of the ICR is estimated to be $2,512. 

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 Primary

Copper Smelters (40 CFR Part 63, Subpart QQQ) (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 3

existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. 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

Respondents2

(E)

Number of 

Respondents

(E=A+B+C-D)

1

0 3 0 0 3

2

0 3 0 0 3

3

0 3 0 0 3

Average 0 3 0 0 3

1

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

2 Column D is subtracted to avoid double-counting respondents.

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

Total Annual Responses
11

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

Initial notification 3 0 N/A 0

Notification of performance 

test 3 5.5 N/A 16.5

Initial compliance 

determination 3 1 N/A 3

Performance test reports 3 5.5 N/A 16.5

Semiannual summary reports 3 2 N/A 6

Total 42

The number of Total Annual Responses is 42. 

The total annual labor costs are $918,324. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Copper 

Smelters (40 CFR Part 63, Subpart QQQ) (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 9,380. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Copper Smelters (40 CFR 

Part 63, Subpart QQQ) (Renewal).

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

information is estimated to average 223 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $8,220. 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 55

labor hours at a cost of $2,512. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal).
12

6(f) Reasons for Change in Burden

There is an increase of 543 hours in the total estimated respondent burden compared with 

the ICR currently approved by OMB. This change in hours is due to the removal of burden for 

submitting initial notifications, which are not required for existing sources, and the addition of 

managerial and clerical staff that are now involved in recordkeeping activities.

There is also a small adjustment increase in EPA burden costs due to the use of more 

updated labor rates. 

6(g) Burden Statement

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

is estimated to average 223 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-2014-0067. 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 

number for the docket center is (202) 566-1927. 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-2014-0067 and OMB Control Number 2060-0476 in any

correspondence. 
13

Part B of the Supporting Statement

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

information.
14

Table 1: Annual Respondent Burden and Cost – NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) 

(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 

personhours per 

year 

(E=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. Survey and Studies N/A

3. Reporting requirements

 A. Read instructions 16 1 16 0 0 0 0 0

 B. Required activities

 Conduct PM

 performance test c 120 4.5 540 3 1,620 81 162 $182,392.56

 Conduct copper converter 

 building performance test d 240 1 240 3 720 36 72 $81,063.36

 C. Create information See 3B & 4E

 D. Gather existing information See 3B & 4E

 E. Write Report

 Initial notification 8 1 8 0 0 0 0 $0

 Notification of performance test 2 5.5 11 3 33 1.65 3.3 $3,715.40

 Initial compliance determination 40 1 40 3 120 6 12 $13,510.56

 Performance test reports e80 5.5 440 3 1,320 66 132 $148,616.16

 Summary report f40 2 80 3 240 12 24 $27,021.12

Subtotal for Reporting Requirements 4,661 $456,319.16

4. Recordkeeping requirements

 A. Read instructions 40 1 40 0 0 0 0 0

 B. Plan activities 100 1 100 0 0 0 0 0

 C. Implement Activities 
15

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 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per year 

(Ex0.1)

(H) 

Total Cost 

per year b

 i. Prepare startup, shutdown, 

 malfunction plan 80 1 80 0 0 0 0 $0

 ii. Copper concentrate dryer

 Monitor control device 

 parameters g 0.5 365 182.5 3 547.5 27.38 54.75 $61,641.93

 iii. Smelting vessel

 Inspect tapping hood system h4 12 48 3 144 7.2 14.4 $16,212.67

 Monitor control device 

 parameters g 0.5 365 182.5 3 547.5 27.38 54.75 $61,641.93

 iv. Slag cleaning vessel

 Inspect tapping hood system i4 12 48 1 48 2.4 4.8 $5,404.22

 Monitor control device 

 parameters i, g 0.5 365 182.5 1 182.5 9.13 18.25 $20,547.31

 v. Batch copper converters

 Inspect converter hood system 4 12 48 3 144 7.2 14.4 $16,212.67

 Monitor hood system 

 ventilation parameters g 0.5 365 182.5 3 547.5 27.38 54.75 $61,641.93

 Monitor control device 

 parameters g 0.5 365 182.5 3 547.5 27.38 54.75 $61,641.93

 vi. Prepare fugitive dust control 

 plan 100 1 100 0 0 0 0 0

 D. Develop record system 100 1 100 0 0 0 0 0

 E. Time to enter information j1 365 365 3 1,095.00 54.75 109.5 $123,283.86

 F. Time to train personnel k100 1 100 3 300 15 30 $33,776.40

Subtotal for Recordkeeping Requirements 4,719 $462,004.86

TOTAL LABOR BURDEN AND COST 9,380 $918,324
16

Assumptions:

a

 We have assumed that there are approximately three sources that are subject to the standard, with no new additional sources expected over the next three years.

 b

 This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and 

$51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 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 each of the three respondents will take 120 hours, 4.5 times per year to conduct performance tests for PM as required under 40 CFR 63.1453.

d

 We have assumed that each of the three respondents will take 240 hours to conduct copper converter building performance test once per year.

e

 We have assumed that each respondents will take eighty hours, 5.5 times per year to complete a performance test report.

f

 We have assumed that it will take each respondent forty hours to write summary report two times per year.

g

 Recordkeeping requirements are required daily on all monitor control device parameters.

h We have assumed that inspections on all tapping hood systems are done on a monthly basis.

i We have assumed that one of the three existing sources will be equipped with a slag cleaning vessel.

j Each respondent is required to record information on a daily basis.

k

 We have assumed that it will take each of the respondent 100 hours to train personnel once a year.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) 

(Renewal)

Activity

(A) 

EPA personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C) 

EPA personhours per 

plant per year 

(AxB)

(D) 

Plants per 

year 

a

(E) 

Technical 

personhours per 

year (CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost, $ b

Activity

Review reports

 a. Report of no deviations 4 1 4 0 0 0 0 $0

 b. Report of deviations 4 1 4 0 0 0 0 $0

 c. Report of SSM 8 1 8 0 0 0 0 $0

 d. Reports of equipment leaks 8 1 8 0 0 0 0 $0

 e. Report on wastewater c

8 2 16 3 48 2.4 4.8 $2,512.32

TOTAL ANNUAL BURDEN AND COST 55 $2,512

Assumptions:

 a

 We have assumed that there are approximately three sources that are subject to the standard, with no new additional sources expected over the next three years.

 

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

 It is assumed that all of the three respondents will each take 8 hours to review reports on wastewater on a semiannual basis.