**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart**  **TTTTT ) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Primary

Magnesium Refining (40 CFR Part 63, Subpart TTTTT ) (Renewal), EPA I CR Number 2098.06 , OMB Control Number 2060

- 0536 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Pri mary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) were proposed on January 22, 2003 (68 FR 2970) , promulgated on October 10, 2003 (68 FR 58615) , and amended on April 20, 2006 (71 FR 20471) . These regulations apply to both existing and new facilities that perform primary magnesium refining where the total hazardous air pollutants (HAPs) emitted are greater than, or equal to, 10 tons per year for each HAP, or where the total HAPs emitted are greater than, or equal to, 25 tons per year of an y combinatio n of HAPs. New facilities include those that commenced construction or reconstructi on after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart TTTTT

. In general, all NESHAP standards require initi al 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 aff

ected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, an d records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/operator subjec t to the provisions of this part shall maintain a file of these measurements, and retain the file for at leas t five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local autho rity

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of one respondent per ye ar will be subject to the standard s , and no additional res pondents per year will become subject to the standard s
. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance ”

.2

T he “Affected Public” is a single , private entity subject to the NESHAP. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Primary

Magnesium Refining (40 CFR Part 63 , Subpart TTTTT ) (Renewal)

. T he burden to the “Federal Government” burden is attributed entirel y to work performed b y federal employees or government contractor s and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (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. Inaddition, 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) sub mit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from primary magnesium refining operations 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 TTTTT

. **2(b) Practical Utility/Users of the Data** The recordk eeping and reporti n g requirements in the standard s 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 p roceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comp ly

with the emission standard s
. Continuous emission monitors are used3

to ensure compliance with the standard s 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 notificat ions required in the standard s 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 properl y installed and operated , leaks are being detected and repaired , and the standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart TTTTT

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Publ ic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal R egister ( 77 FR 63813 ) on October 17, 2012

. No comments were received on the burden published in the Fed eral Register

. **3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard s , is the Online Tracking Information Sy stem (OTI S ) which is operated and maintained b y EPA's Office of Compliance. OTI S is EPA ’ s database for the collection, maintenan ce, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Onl y a single respondent will be subject to the standard s over the three year period covered b y this ICR.4

Industry trade association and other interested parties were provided an opportunity to comment on the burden associated with the standard s as it was being developed and the standard s has been previously reviewed to determine the minimum informati on needed for compliance purposes. Indeveloping this ICR, we contacted our internal industry experts in OAQPS, and the US Magnesium LLC , at (801) 532

- 2043

. It is our policy

to respond after a thorough review of comments received since the last ICR rene wal , as well as those submitted in response to the f irst Federal Register n otice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f 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**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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

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

- ye ar statute of limitations on which the permit program is based. T he retention of records for five years allow s EPA to establish the compliance history of a source , an y 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 ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard s do not include sensitive5

questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are primary magnesium refiners . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 3339, which corresponds to th e North American Industry Classification System (NAI CS ) code 331419 for Primary Smelting and Refining of Nonferrous Metal (except copper and aluminum). **4(b) Information Reque sted**  **(i) Data Items**
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT). A source must make the following reports:

**Notification s**  Initial notification 63.9930(a), 63.5(d), 63.9(b) Notification of compliance status 63.9930(a), 63.4710(c), 63.9(h) Notification of construction or reconstruction 63.9930(a), 63.5 Notification of actual startup 63.9930(a), 63.9(b) Notification of performance test 63.9930(a), 63.7(b), 63.8(e), 63.9(e)
**Reports** Semiannual report 63.9931(a), (b) Excess emissions report 63.9931(a), (b) Report of performance test 63.9930(e) Startup, shutdown, malfunction report 63.9931(c), 63.6(e)(3), 63.10(d)(5)
A source must keep the following records:6 **Recordkeeping** Five ye ar retention of records 63.9933(b), 63.10(b) Copies of notifications and reports 63.9932(a)(1) Startup, shutdown, and malfunction plan/records 63.9932(a)(2), 63.6(e) Documentation of performance tests and opacity observations 63.9932(a)(3), 63.10(b) Records required to demonstrate continuous compliance 63.9932(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 recordke eping at a plant site. Also, regulatory

agencies in c ooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate compliance monitoring s ys tem (CMS) for pressure drop or for liquid flow rate for wet scrubber. Perform initial performance test, Reference Method 1, 2, 2F, 2G, 3, 3A, 3B, 4, 5, 5D, 18, 23, 25D, 26, 26A, 201, 201A, 301, 303, 303A, 304, 304A, 304B, 305, 306, 306A, 306B, 307, 308, 310A, 310B, 310C, 311, 312A, 312B, 312C, 3 13A, 313B, 315, 316, 318, 319, 320, or 321 test, and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install , and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.7

Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. 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, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, startup, shutdown, malfunction plan, and quality control plan for CMS required to be submitted by

industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

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

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional of fices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars.8

**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 invol ving the process operations and the ty pes 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 informati on collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewal). **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consi stent with the concept of burden under the Paperwork Reduction Act. Where ver 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 per son is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 611 ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the p reviousl y approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%)9

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ 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 ty pe of industry

costs associated with the information collection activ ities 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 a one - time cost 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 su ch as photocop yi ng 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)

CEM $16,000 0 $0 $1,200 1 $1,200 The total capital/startup costs for this I CR are zero . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 1,200

. 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 IC R is estimated to be $ 1,200

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emis sions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 8,006

. This cost is based on the average hourl y labor rate as follows:10 Managerial $ 6 2.27 (GS

- 1 3, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 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 Magnesium Refin ing (40 CFR Part 63, Subpart TTTTT) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately one existing respondent will be subject to the standard. It is estimated that no additional respondents per ye ar 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 ye ars covered b y this ICR.
**Number of Respondents**

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

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 1 0 0 1
2 0 1 0 0 1
3 0 1 0 0 1 Average 0 1 0 0 1 1 New respondent include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is one
. The total number of annual responses , per each ye ar of the three

- ye ar reporting period, is calculated using the following table: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 0 1 0 0 Notification of compliance status 0.33 1 0 0.33 Notification of construction/ reconstruction 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of performance test 0.33 1 0 0.33 Report of performance test 0.33 1 0 0.33 Semiannual report 1 2 0 2 Startup, shutdown, malfunction report 1 1 0 1 Total 4 The number of Total Annual Responses is 4

. The total annual labor costs are $59,210

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

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 611 hours at a cost of $59,210

. Details regarding these esti mates may

be found below in Table 1. Annual Respondent Burden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewa l). Furthermore, the annual public reporting and recordk eeping burden for this collection of information is estimated to average 153 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $1,200

. 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 ye ars is estimated to be 178 labor hours at a cost of $ 8,006 . See below Table 2: Average Annual EPA Burden and Cost

–12

NESHAP for Primary

Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewal). **6(f) Reasons for Change in Burden** There is no change in the labor hours in this I CR compared to the previous ICR. This is due to two considerations : 1) the regulat ions have not changed over the past three years and are not anticipated to change over the next three ye ars ; and 2) the growth rate for the industry is either very

low, or negative , or non - existent, so there is no significant change in the overall burden. However, there is an adjustment increase in the total estimated burden costs. The change in the cost estimates occurred because the labor rates have increased since the last ICR. This I CR uses the most recent labor rates in calculating all burden cost s. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 153 hours per response. “ Burden ” means the total time, effort, or financial resources expended by persons to gene rate, 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 sy stems for the purposes of collecting, validating, and veri fying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with an y previously

applicable instructions and requirements; train personnel to be able to respond to a collection of i nformation; 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 m ethods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0699 . 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 e lectronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Reading Room is (202) 566

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

- 1752

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Offic er for EPA. Please include the EPA Docket ID13

Number EPA

- HQ

- OECA

- 2012

- 0699 and OMB Control Number 2060

- 0536 in any correspondence. **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 Magnesium Refining**  **(40 CFR Part 63**  **, Subpart TTTTT**  **) (Renewal)**

Burden Item (A) Person hours per occurrence (B)

Number of occurrences per year (C)

Person hrs. per respondent per year (D)

Respondents per year a (E)

Technical person hrs. per year (F) Management person hrs. per year (G)

Clerical person hrs. per year (H)

Annual costs ($) b (C=A*B) (E=C*D) (F=E*0.05) (G=E*0.1) 1 . Read rule and instructions a. Read rule and instructions 4 1 4 1 4 0.2 0.4 $ 445.41 b. Process/review information 4 4 16 1 16 0.8 1.6 $ 1 , 781.65 c. Write reports i. Initial notification 2 1 2 0 0 0 0 $ 0 ii. Notification of compliance status c 2 1 2 0.33 0.66 0.03 0.07 73.49 iii. Notification of construction/reconstruction 2 1 2 0 0 0 0 $0 iv. Notification of actual startup 2 1 2 0 0 0 0 $ 0 v. Notification of performance test c 2 1.2 2.4 0.33 0.79 0.04 0.08 $ 88.19 vi. Report of performance test c , d 180 1.2 216 0.33 71.28 3.56 7.13 $ 7 , 937.24 vii. Semiannual report e 10 2 20 1 20 1 2 $ 2 , 227.06 viii. Startup, shutdown, malfunction report 4 1 4 1 4 0.2 0.4 $ 445.41 **Subtotal for**  **Reporting Requirements**  **134 .24**  **$ 12,998.46**  2. Recordkeeping requirements a. Read rule and instructions 4 1 4 1 4 0.2 0.4 $ 445.41 b. Plan activities 12 1 12 1 12 0.6 1.2 $ 1,336.24 c. Implement activities 12 1 12 1 12 0.6 1.2 $ 1,336.24 d. Time to train personnel 10 1 10 1 10 0.5 1 $ 1,113.53 e. Time to enter information

- - - - - - - - f. Store, file, and maintain records f 1 365 365 1 365 18.25 36.5 $ 40,643.85 g. Retrieve records/reports g 1 12 12 1 12 0.6 1.2 $ 1,336.24 **Subtotal for**  **Recordkeeping Requirements**  **477 .25**  **$ 46,211.50**  **Total Labor**  **Burden and Costs (rounded)**  **611 $59,**  **210**15

Assumptions:
a. We have assumed that there are approximately one respondents subject to the rule, with no new sources expected over the next three

- years of this ICR. b This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $12 1.44 ($57.83+ 110%); and Clerical $50.51 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” T he rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit pa ckages available to those employed by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c. We have assumed that performance test will be repeated once in three years. d. We assume that this includes Method 23 test.
e. We assumed that it will take resp ondent ten hours two times per year to complete semiannual report. f. This includes inspection of unpaved areas. g. We assume that it will take 1 hour once per month to retrieve records/reports.16

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart**  **TTTTT) (Renewal)**  (A) (B) (C) ( D ) ( E ) ( F) ( G ) ( H) Person hours per occurrence Number

of occurrences per year Person

hours per respondent per year (C=AxB) Respondents

per Year a Technical

person hours per year (E=CXD) Management

person hours per year (Ex0.05) Clerical

person hours per year (Fx0.1) Annual

costs ($) b

1. Initial performance test 24 1 24 0.33 7.92 0.396 0.79 $ 410.45 2. Repeat performance test 24 0.2 4.8 0.33 1.58 0.08 0.16 $ 82.09 3. Report review a) Initial notification 8 1 8 0 0 0 0 $ 0 b) Notification of performance test 8 1.2 9.6 0.33 3.17 0.16 0.32 $ 164.18 c) Notification of compliance status 8 1 8 0.33 2.64 0.13 0.26 $ 136.82 d) Notification of construction/reconstruction 8 1 8 0 0 0 0 $ 0 e) Notification of actual startup 8 1 8 0 0 0 0 $ 0 f) Report of performance test 8 1.2 9.6 0.33 3.17 0.16 0.32 $ 164.18 g) Semiannual report c 16 4 64 2 128 6.4 12.8 $ 6,633.54 h) Startup, shutdown, malfunction report d 8 1 8 1 8 0.4 0.8 $ 414.60 **Total Annual Burden**  **and Costs (rounded)**  **178 $8,**  **006** Assumption:
a. We have assumed that there are approximately one respondents subject to the rule, with no new sources expected over the next three

- years of this ICR. b. This cost is based on the average hourly labor rate as follow s: Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%); Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2012 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 that it would take 16 hours four times per year to review semiannual report. d. We have assumed that it will take eight hour once per year to review the startup, shutdown, malfunction report.