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 ICR Number 2098.06, OMB Control Number 2060-0536

1(b) Short Characterization/Abstract

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

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 any combination of HAPs. 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 TTTTT.

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 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 years, an average of one respondent per year will be subject to the 

standards, and no additional respondents per year will become subject to the standards. 

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

without any “Terms of Clearance”.
2

The “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). The 

burden to the “Federal Government” burden is attributed entirely to work performed by federal 

employees or government contractors 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. In addition, section 

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

of this Act to: 

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

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

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

accordance with such procedures or methods, at such locations, 

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require. 

In the Administrator's judgment, HAP emissions from primary 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 recordkeeping and reporting requirements in the standards ensure compliance with 

the applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

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

capability to comply with the emission standards. Continuous emission monitors are used 
3

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

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

determine compliance in place of a continuous emission monitor.

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

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

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

installed and operated, leaks are being detected and repaired, and 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 directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

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

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

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

provisions in the standards, is the Online Tracking Information System (OTIS) which is operated 

and maintained by EPA's Office of Compliance. OTIS is EPA’s 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. Only a single respondent will be 

subject to the standards over the three year period covered by this ICR.
4

Industry trade association and other interested parties were provided an opportunity 

to comment on the burden associated with the standards as it was being developed and the 

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

compliance purposes. In developing 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 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 (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 standards do not include sensitive 
5

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 (SIC) code for the respondents 

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

Classification System (NAICS) code 331419 for Primary Smelting and Refining of Nonferrous 

Metal (except copper and aluminum).

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

A source must make the following reports:

Notifications

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:
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Recordkeeping

Five year 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 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 compliance monitoring system (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, 313A, 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 

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.
7

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

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, 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. 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. 

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.
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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 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 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.

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 611 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NESHAP program, the previouslyapproved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 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 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 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 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)

CEM $16,000 0 $0 $1,200 1 $1,200

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

above table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR 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 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 

$8,006. 

This cost is based on the average hourly labor rate as follows:
10

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), 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. Details upon which this estimate is 

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

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

Number of Respondents

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 respondent 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 each year of the three-year reporting period, is 

calculated using the following table: 
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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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 611 hours at a cost of $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). 

Furthermore, the annual public reporting and recordkeeping 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 years 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 ICR compared to the previous ICR. This is 

due to two considerations: 1) the regulations have not changed over the past three years and are 

not anticipated to change over the next three years; 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 ICR uses the most recent labor rates in calculating all burden costs. 

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 generate, maintain, retain, or disclose or provide 

information to or for a Federal agency. This includes the time needed to review instructions; 

develop, acquire, install, and utilize technology and systems for the purposes of collecting, 

validating, and verifying information, processing and maintaining information, and disclosing 

and providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-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 

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) 566-1752. 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 
13

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.
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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 c2 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 c2 1.2 2.4 0.33 0.79 0.04 0.08 $88.19

 vi. Report of performance test c, d180 1.2 216 0.33 71.28 3.56 7.13 $7,937.24

 vii. Semiannual report e10 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 f1 365 365 1 365 18.25 36.5 $40,643.85

g. Retrieve records/reports g1 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 $121.44 ($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.” 

 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. 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 respondent 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 

personhours per 

year

(E=CXD)

Management 

personhours per 

year

(Ex0.05)

Clerical 

personhours 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 c16 4 64 2 128 6.4 12.8 $6,633.54

 h) Startup, shutdown, malfunction report d8 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 follows: 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.