SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal), EPA ICR Number 0193.11, 

OMB Control Number 2060-0092

1(b) Short Characterization/Abstract

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

were: 1) proposed on December 7, 1971 (36 FR 23939); 2) promulgated on April 6, 1973 (38 FR

8826); and 3) last amended on October 17, 2000. These regulations apply to all extraction 

plants, ceramic plants, foundries, incinerators, and propellant plants which process beryllium ore, 

beryllium, beryllium oxides, beryllium alloys, or beryllium-containing waste. The regulations 

also apply to machine shops which process beryllium, beryllium oxides, or any alloy when such 

alloy contains more than 5 percent beryllium by weight. All sources known to have caused, or to 

have the potential to cause, dangerous levels of beryllium in the ambient air are covered by the 

standard. This information is being collected to assure compliance with 40 CFR part 61, subpart 

C.

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, 

and are required of all affected facilities subject to NESHAP.

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

measurements, and retain the file for at least 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 directly to the U. S.

Environmental Protection Agency (EPA) regional office.

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

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

owner/operator of the plant site).

Over the next three years, an average of 33 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. Note that 

of a total of approximately 236 existing sources, we assume approximately 10 sources have 

elected to comply with the rule by monitoring ambient air beryllium concentrations, while the 

remaining 226 sources have elected to comply by conducting a one-time-only stack test. We 
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also have assumed that 10 percent of the 226 sources (i.e., 23 respondents) will engage in

operational changes that will require them to repeat stack testing and to carry out subsequent 

recordkeeping and reporting requirements.

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

The “Affected Public” are owners or operators of beryllium industry facilities. The 

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

and Cost – NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal). The burden to the 

Federal Government is attributed entirely to work performed by either Federal employees or 

government contractors. This burden may be found below in Table 2: Average Annual EPA 

Burden and Cost –NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

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

of this Act to: 

(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, beryllium emissions from extraction plants, ceramic 

plants, foundries, incinerators, propellant plants, and machine shops which process beryllium 

ore, beryllium, beryllium oxide, beryllium alloys, or beryllium-containing waste 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 61,

subpart C.

2(b) Practical Utility/Users of the Data
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The recordkeeping and reporting requirements in the standard 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 standard are used to inform either 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, that leaks are being detected and repaired, and that the standard

is being met. The performance test may also be observed.

The required 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 C.

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 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 (78 FR 33409) on June 4, 2013. 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) 
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which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database 

for the collection, maintenance, and retrieval of all compliance data. 

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is any way for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, EPA 

contacted: 1) the Society for Mining, Metallurgy, and Exploration (SME), at (303) 948-4200;

and 2) the National Mining Association (NMA), at (202) 463-2600.

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.

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.
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4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are sources which 

process beryllium and its derivatives. The United States Standard Industrial Classification (SIC) 

codes and corresponding North American Industry Classification System (NAICS) codes for the 

respondents affected by the standard are provided in the following table.

Standard (40 CFR, Part 61, Subpart C) SIC Codes NAICS Codes

Industrial Inorganic Chemicals, not elsewhere 

Classified

2819 325188

Primary Smelting and Refining of Nonferrous 

Metals, except Copper and Aluminum

3339 331419

Nonferrous Foundries, except Aluminum and Copper 3369 331528

Industrial and Commercial Machinery and 

Equipment, not elsewhere Classified

3599 332710

Refuse Systems 4953 562211 and 562920

4(b) Information Requested

(i) Data Items

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

Beryllium (40 CFR Part 61, Subpart C). 

A source must make the following notifications/reports:

Notifications/Reports

Notification and application of construction or modification 61.07

Notification of actual startup 61.09(a)(2)

Notification of emission test 61.13(c) and 61.33(b)

Report of emission test results 61.13(f) and 61.33(d)

Notification requesting approval to meet an ambient concentration 

limit on beryllium in the vicinity of the stationary source (alternative 

standard)

61.32(b)

Source status report for facilities complying by ambient monitoring, a 61.10(a) and 61.34(d)
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Notifications/Reports

monthly report of all measured beryllium concentrations shall be 

submitted to the administrator

A source must keep the following records:

Recordkeeping

Maintain records of monitoring data, monitoring system calibration 

checks, and any periods when the monitoring system is 

malfunctioning or inoperative for two years.

61.14(f)

Maintain records of emission test results and other data needed to 

determine emissions and air concentrations for two years

61.13(g), 61.34(c),

and 61.33(e)

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.

For facilities that have elected to comply with an alternative ambient air quality limit, install, 

calibrate, maintain, and operate a continuous monitor in the vicinity of the affected facility to 

measure beryllium concentrations.

For facilities complying by ambient monitoring, perform emission testing to determine 

beryllium emissions to the atmosphere according to Method 104 or Method 103 (an alternative 

method needing approval) of appendix B to part 61.

Write the notifications and reports listed above.

Enter information required to be recorded above.
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Respondent Activities

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

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

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

maintaining information.

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

providing information.

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 
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compliance and enforcement programs.

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 two

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 Beryllium (40 

CFR Part 61, Subpart C) (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. 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.
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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 2,629 hours (see ‘Total Labor Hours’ from 

Table 1 below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

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

2013, “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. Capital/startup costs are onetime costs when a facility

becomes subject to the regulation. 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)

Ambient monitor $0 0 $0 $3,500 10 $35,000

Total $0 $35,000

The total capital/startup costs for this ICR are $0. This is the total of column D in the 
10

above table. 

The total operation and maintenance (O&M) costs for this ICR are $35,000. 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 years of the ICR is estimated to be $35,000.

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 

$14,822. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 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 

Beryllium (40 CFR Part 61, Subpart C) (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

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

respondents per year will become subject to these same standards. The overall average number 

of respondents, as shown in the table below, is 33 per year.

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

years covered by this ICR: 
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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 

Respondent 2

(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 33 0 0 33

2 0 33 0 0 33

3 0 33 0 0 33

Average 0 33 0 0 33

1

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

2

It includes 10 sources that elected to comply by conducting ambient air monitoring, and 23 sources that 

are required to conduct a repeat stack test due to an operational change. 

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

average Number of Respondents over the three year period of this ICR is 33. 

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

Notification of stack test 23 1 0 23

Emission level/operational changes 23 1 0 23

Monthly ambient concentrations 10 12 0 120

Total 166

The number of Total Annual Responses is 166.

The total annual labor costs are $257,208. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Beryllium (40 

CFR Part 61, Subpart C) (Renewal).
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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 2,629 hours at a cost of $257,208. Details regarding 

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

NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal).

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

of information is estimated to average 16 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $35,000. 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 329 

labor hours at a cost of $14,822. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal).

6(f) Reasons for Change in Burden

There is an apparent increase of two hours in the total estimated respondent burden as 

currently identified in the OMB Inventory of Approved Burdens. This increase is due to 

rounding, and is not due to any program changes. The most-recently approved ICR rounded the 

burden hours associated with recordkeeping for operating parameters and emissions to the 

nearest whole number. In contrast, burden hours are rounded to two decimal places in this ICR, 

resulting in an apparent increase of two hours.

There is an increase in the respondent cost from the most recently approved ICR due 

to the use of updated labor rates. This ICR references labor rates from the Bureau of Labor 

Statistics to calculate the respondent burden cost.

6(g) Burden Statement

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

is estimated to average 16 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 
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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-2013-0301. 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-2013-0301 and OMB Control Number 2060-0092 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 Beryllium (40 CFR Part 61, Subpart C) (Renewal)

Burden Item

A B C D E F G H

Person

hours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person

hours per 

respondent

per year

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year b($)

1. Applications

A. Application for approval of 

construction/modification

4 1 4 0 0 0 0 $0 

B. Request for ambient air monitoring 

alternative

4 1 4 0 0 0 0 $0 

2. Surveys and studies N/A $0

3. Reporting requirements $0

A. Read instructions 1 1 1 0 0 0 0 $0 

B. Required activities 

Initial emissions test 20 1 20 0 0 0 0 $0 

Determine emission level from stack 

test c

8 1 8 23 184 9.2 18.4 $20,698.16 

Monitoring of ambient beryllium 

concentrations

See 3E

C. Create information See 3E

D. Gather existing information See 3E

E. Write report

Notification of actual startup 2 1 2 0 0 0 0 $0 

Notification of stack test d2 1 2 23 46 2.3 4.6 $5,174.54 

Report of emission level 

determination/operational change e

8 1 8 23 184 9.2 18.4 $20,698.16 

Plan for locating monitors 16 1 16 0 0 0 0 $0 

Report monthly ambient 

concentrations f

8 12 96 10 960 48 96 $107,990.40

Subtotal for Reporting Requirements 1,580.1 $154,561.26
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Burden Item

A B C D E F G H

Person

hours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person

hours per 

respondent

per year

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year b($)

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 4C

C. Implement activities See 3B

D. Develop record system N/A

E. Time to enter information

Records of operating parameters and 

emissions g

0.25 365 91.25 10 912.5 45.63 91.25 $102,647.13 

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 1,049.38 $102,647.13

TOTAL ANNUAL BURDEN AND COST (rounded) 2,629 $257,208

Assumptions:

a. For the purpose of determining recordkeeping and reporting burdens associated with this rule, we have assumed there are 33 respondents, and that no new 

additional sources will be subject over the three-year period of this ICR. Of a total of approximately 236 existing sources, we have assumed approximately 10 

sources have elected to comply with the rule by monitoring ambient air beryllium concentrations and that the remaining 226 sources have complied by 

conducting a one-time-only stack test. We also have assumed that 10 percent of the 226 sources (i.e., 23 respondents) will engage in operational changes that 

will require them to repeat stack testing and to carry out subsequent recordkeeping and reporting requirements.

b. This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, March 2013, “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 respondent will take eight hours to determine the emission level from the stack test.

d. We have assumed that each respondent will take two hours to write notification report of stack test.

e. We have assumed that each respondent will take eight hours to complete the report of emission level determination/operational change.

f. We have assumed that each respondent will take eight hours once per month to write the monthly ambient concentrations report.

g. We have assumed that each of the ten respondents will take fifteen minutes each day to enter records of operating parameters and emissions information.
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal)

Burden Item

A B C D E F G H

Technical 

person-hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year b($)

Initial performance test

New plant 20 1 20 0 0 0 0 $0 

Report review

Notification of construction 2 1 2 0 0 0 0 $0 

Request to use ambient air concentration 

alternative 

2 1 2 0 0 0 0 $0 

Notification of actual startup 0.5 1 1 0 0 0 0 $0 

Notification of initial stack test 0.5 1 1 0 0 0 0 $0 

Report of initial analysis 2 1 2 0 0 0 0 $0 

Existing plant

Notification of stack test 40 1 40 0 0 0 0 $0 

Report of emission level 

determination/operational change c

2 1 2 23 46 2.3 4.6 $2,383.93 

Report of monthly ambient 

concentrations d

2 12 24 10 240 12 24 $12,437.88 

TOTAL ANNUAL BURDEN AND COST (rounded) 329 $14,822

Assumptions:

a. For the purpose of determining recordkeeping and reporting burdens associated with this rule, we have assumed there are 33 respondents, and that no new 

additional sources will be subject over the three-year period of this ICR. Of a total of approximately 236 existing sources, we have assumed approximately 10 

sources have elected to comply with the rule by monitoring ambient air beryllium concentrations and that the remaining 226 sources have complied by 

conducting a one-time-only stack test. We also have assumed that 10 percent of the 226 sources (i.e., 23 respondents) will engage in operational changes that 

will require them to repeat stack testing and to carry out subsequent recordkeeping and reporting requirements.

b. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2013 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.

c. We have assumed it will take two hours per respondent to review the emission level determination/operational change report.

d. We have assumed it will take two hours per respondent per month to review the monthly ambient concentrations report.