SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal), EPA ICR 

Number 1856.10, OMB Control Number 2060-0414.

1(b) Short Characterization/Abstract

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

Lead Smelters were proposed on April 17, 1998, promulgated on June 4, 1999, and amended on 

November 15, 2011. This amendment updates requirements to reduce the risks associated with 

this source category to acceptable levels, by adjusting the cap to 1.2 tons per year (TPY) for the 

furnace area stack and refining operations stacks and by updating work practice standards to 

minimize fugitive dust emissions. Additionally, this amendment eliminates the SSM exemption, 

updates the language in the regulation, and requires stack testing for lead compounds on a 

quarterly basis. These regulations apply to existing and new facilities engaged in producing lead 

metal from ore concentrates. The category includes, but is not limited to, the following smelting 

processes: Sintering, reduction, preliminary treatment, refining and casting operations, process 

fugitive sources, and fugitive dust sources. 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 TTT.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

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

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

Over the next three years, we don’t expect an existing respondent to be subject to the 

rule. However, we calculated the burden for implementation of the rule, which is still effective, 

based on the assumption of an average of one respondent per year. We also assumed that no

additional respondents per year will become subject to the standard. We expect that if a new 

primary lead smelting is built in the future it would meet NSPS Subpart TTT applicability and 

become subject to this rule. 
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The Office of Management and Budget (OMB) approved the currently active ICR 

without any ‘Terms of Clearance.” 

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

Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) 

(Renewal). The “Federal Government” burden is attributed entirely to work performed by 

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

EPA Burden and Cost – NESHAP for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) 

(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, HAP emissions from facilities engaged in primary lead 

processing 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 TTT.

2(b) Practical Utility/Users of the Data

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.
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Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

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

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

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

The performance test may also be observed.

The required quarterly 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

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) 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. 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. In developing 
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this ICR, we contacted both the Doe Run Company at (314) 453-7100 and the Missouri 

Department of Natural Resources at (800) 361-4827.

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 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 (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
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4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities engaged in 

primary lead processing. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 3339, which corresponds to the North American 

Industry Classification System (NAICS) 331410 for Lead Smelting and Refining, Primary. 

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 Lead Smelters (40 CFR Part 63, Subpart TTT). 

A source must make the following reports:

Notifications

Initial notification requirements 63.9(b)(1)

Notification of compliance status when a source becomes subject to 

the standard

63.9(h)

Notification that source is subject to special compliance requirements, 

if applicable

63.9(d)

Notification of performance test 63.7(b), 63.9(e)

Rescheduled of performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)

Change in information already provided 63.9(j)

Request for an extension of compliance with relevant standard 63.9(c)

Reports

Application for approval of the construction or reconstruction of a new 

major affected source, or reconstruction of a major affected source

63.5(6)(d)

Performance test results 63.10(d)(2)

Report of opacity and visible emission observations 63.9(f)
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Reports

Startup, shutdown and malfunction plan 63.6(e)(3)

Periodic startup, shutdown and malfunction reports 63.10(d)(5)(i)

Notification of compliance status 63.9(h)

SOP for baghouses and fugitive dust control 63.1548(b)

Progress reports for compliance extension (if applicable) 63.6(i)

Report of quarterly compliance tests 63.1546 (a) 

Semiannual reports 63.1549(e)

A source must keep the following records:

Recordkeeping

Startup, shutdown and malfunction plan 63.6(e)(3)

All reports and notifications 63.10(b)(1)

Records of startup, shut-down, and malfunction of process equipment 63.10(b)(2)(i), (iv), 

(v)

Records of malfunctions of air pollution control equipment 63.10(b)(2)(ii)

Any applicability determination that demonstrates why owner or 

operator believes source(s) is/are unaffected

63.10(b)(3)

Records of maintenance of air pollution control equipment 63.10(b)(2)(iii)

Records of flow monitoring system performance evaluations, 

malfunctions, calibrations, and adjustments

63.10(b)(2)(vi), 

(vii), (viii), (ix), (x), 

(xi), 63.10(c)

Documentation required for waiver of recordkeeping or reporting 

requirements (if applicable)

63.10(b)(2)(xii)

Documentation of initial notifications 63.10(b)(2)(xiv)

Production records of the weight and lead content of unrefined lead, 

copper matte, and copper speiss

63.1549(b)(1)

Records of bag leak detection system output 63.1549(b)(2)

Records of bag leak detection system alarms and corrective actions 63.1549(b)(3)

Records of fugitive dust control activities 63.1549(b)(4)

Records of baghouse inspections and maintenance 63.1549(b)(5)
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Recordkeeping

Records of doorway in-draft checks 63.1549(b)(6)

Records of flow monitoring system output (if applicable) 63.1549(b)(7)

Records of damper position checks (if applicable) 63.1549(b)(8)

Five-year retention of records 63.10(b)(1), 

63.1549(b)

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 lead, opacity, or for pressure drop and liquid 

supply pressure for baghouse or equivalent control device.

Perform initial performance test, Reference Method 1; 2, 2F, 2G; 3, 3A, 3B; 4; 12 or 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.

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.
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Respondent Activities

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.

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. 
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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

There are no small businesses, as defined by the Small Business Administration (SBA), 

affected by this regulation. The SBA defines a small entity engaging in primary lead processing 

operations as a firm having no more than 500 to 1,000 employees (depending on the size 

definition for the affected NAICS code). The sole facility subject to the rule does not meet the 

definition of a small entity. 

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 Lead 

Smelters (40 CFR Part 63, Subpart TTT) (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 6,265 (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

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%)
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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. In a new primary lead smelting facility becomes 

subject to the rule, the rule requires the installation of a lead continuous emission monitor once 

EPA has approved the CEMS specifications. Since the Agency has not approve the specification 

yet and a new facility is not foreseen in the near future, we are unable to come up with 

capital/startup cost and operation and maintenance cost estimate at this time. 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&M1

(G)

Total O&M,

(E X F)

Bag Leak detection 

system - continuous 

particulate matter 

sensor

$10,500

0 $0 $6,500 1 $6,500

Flow monitors with 

high/low alarms $6,500 0 $0 $6,500 1 $6,500

Method 12 

Performance Tests2 N/A $156,000 1 $156,000

TOTAL $0 $169,000

1Assumption: $500 per year per monitoring system per baghouse; we assume the respondent has 13 baghouses.

2Assumption: $13,000 per test per stack, 12 tests per year across 3 stacks.

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 $169,000. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 
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industry over the next three years of the ICR is estimated to be $169,000. 

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 

$2,826. 

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

Lead Smelters (40 CFR Part 63, Subpart TTT) (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

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

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is one 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 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 1 0 0 1

2 0 1 0 0 1

3 0 1 0 0 1

Average 0 1 0 0 1

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 

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

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

Quarterly Reports 1 4 0 4

Semiannual Reports 1 2 0 2

Total 6

The number of Total Annual Responses is 6.

The total annual labor costs are $613,379. Details regarding these estimates may be 

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

Smelters (40 CFR Part 63, Subpart TTT) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 
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Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 6,265. Details regarding these estimates may be found in 

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

Part 63, Subpart TTT) (Renewal). 

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

information is estimated to average 1,044 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $169,000. 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 0

labor hours at a cost of $2,826. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Primary Lead Smelters (40 CFR Part 63, Subpart TTT) (Renewal).

6(f) Reasons for Change in Burden

There is an overall decrease in the respondent and Agency burden and cost from the 

OMB Inventory of Approved Burdens. The currently approved burden is the cumulative burden 

and cost from EPA ICR Number 1856.06 (existing rule) and EPA ICR Number 1856.08 (2011 

amendment). In this ICR renewal, we have combined the two ICRs to reflect current rule 

requirements and removed duplicate items. In addition, this ICR renewal reflects a decrease in 

the number of respondents from two to one since EPA ICR Number 1856.06. We have assumed 

that there are an estimated one respondent subject to NSPS Subpart TTT since rule is still in 

effect. These changes result in an apparent decrease in labor hours and costs. 

6(g) Burden Statement

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

is estimated to average 1,044 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.
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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-2014-0068. 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-2014-0068 and OMB Control Number 2060-0414 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 Primary Lead Smelters (40 CFR Part 63, Subpart TTT) 

(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. Acquisition, Installation, and Utilization of Technology and Systems N/A

4. Reporting Requirements

 A. Read instructions 2 1 2 0 0 0 0 $0

 B. Required activities:

 i. Initial Performance tests: c  8 1 8 0 0 0 0 $0

 ii. Monitoring of operations and equipment: d

 - Implement baghouses SOP 13.4 365 4,891 14,891 244.55 489.1 $550,667.91

 - Quarterly compliance stack tests for lead compounds

 Main stack 8 4 32 1 32 1.6 3.2 $3,602.82 

 Furnace area stack 8 4 32 1 32 1.6 3.2 $3,602.82 

 Refining building stack 8 4 32 1 32 1.6 3.2 $3,602.82 

D. Gather Existing Information See 4B and 5E

E. Write report a, c

 i. Notification of compliance status 2 1 2 0 0 0 0 $0

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

 iii. Notification of construction/ reconstruction a 2 1 2 0 0 0 0 $0

 iv. Notification of Performance Test 2 1 2 0 0 0 0 $0
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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

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

 vi. Reports of performancetest results 4 1 4 0 0 0 0 $0

 vii. Operation and maintenance reports 10 1 10 0 0 0 0 $0

 viii. Semi-annual reports e 16 2 32 1 32 1.6 3.2 $3,602.82 

 ix. Notification of physical/operational changes f 2 1 2 0 0 0 0 $0

 x. Submit quarterly reports 16 4 64 1 64 3.2 6.4 $7,205.63 

Subtotal for Reporting Requirements 5,845 $572,284.80

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities See 4B

C. Implement activities See 4B

D. Develop record system N/A

E. Time to enter and transmit information: 1 365 365 1 365 18.25 36.5 $41,094.62 

 - Records of operating parameters 

 - Records of compliance inspections 

 - Records of performance tests 

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 420 $41,094.62 

TOTAL LABOR BURDEN AND COST 

(rounded): 6,265 $613,379
17

Assumptions:

a

 We have assumed that there are an estimated one respondent which is subject to NSPS Subpart TTT since it is still in effect. We have assumed that there will be no 

new net growth for this industry over the three year period of this ICR. 

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% to account for the benefit packages 

available to those employed by private industry.

c

 We have assumed that all sources are in compliance with initial rule requirements including initial performance test using Method 12 for lead emissions and initial 

sinter building in-draft compliance demonstration. 

d

 Monitoring of operations includes: 1) implementation of Standard Operating Procedures (SOP) for operation and maintenance of baghouses on a daily basis 

such that its bag leak detection system does not alarm more than five percent of the time in any 6-month period which we have assumed it takes about 13.4 labor 

hours per 24 hour day to implement the monitoring and recordkeeping requirements; 2) an quarterly compliance tests for lead compounds; 3) and the monitoring of 

sinter building in-draft for which the operators are given three options to comply including: daily checks for in-draft at all doorway openings using an anemometer 

or equivalent device; establish and maintain the ventilation exhaust rate and damper positions at settings that result in an in-draft at each open doorway; and an 

alternative monitoring method.

e

 We have assumed that sources are continuing to submit semiannual reports.

f

 We are assuming that sources will not be changing operating parameters even when sources may purchase new equipment.
18

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

(Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

person 

hours 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

Initial notification 2 1 2 0 0 0 0 $0

Notification of performance test 0.5 4 2 1 2 0.1 0.2 $104.68

Notification of physical or Operational changes c4 1 4 0 0 0 0 $0

Semi-annual reports 10 2 20 1 20 1 2 $1,046.80 

Review quarterly test results 8 4 32 1 32 1.6 3.2 $1,674.88 

TOTAL ANNUAL BURDEN AND COST 

(rounded): 62 $2,826

Assumptions:

a We have assumed that there is approximately one respondents currently operating in the United States since the NSPS Subpart TTT rule is still in effect. It is 

estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector. 

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

Managerial rate of $62.90, Technical rate of $46.67, and Clerical rate of $25.25. These rates are from the Office of Personnel Management (OPM) “2014 General 

Schedule” which excludes locality rates of pay. 

c We have assumed that all existing sources are in compliance with the initial rule requirements.