1

Supporting Statement 

ENVIRONMENTAL PROTECTION AGENCY 

NSPS for Lead-Acid Battery Manufacturing (40 CFR part 60, subpart KK) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) (Renewal), 

EPA ICR Number 1072.10, OMB Control Number 2060-0081

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Lead-Acid Battery Manufacturing

were proposed on January 14, 1980, promulgated on April 16, 1982, and amended on October 

17, 2000. These regulations apply to the following affected facilities in lead-acid battery

manufacturing plants with production capacity that is equal to, or exceeds 6.5 tons of lead: 

grid casting facilities, paste mixing facilities, three-process operation facilities, lead-oxide 

manufacturing facilities, lead reclamation facilities, and other lead-emitting operations, 

commencing construction, modification, or reconstruction after the date of proposal. This 

information is being collected to assure compliance with 40 CFR part 60, subpart KK.

In general, all NSPS 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 NSPS.

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

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

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

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

Environmental Protection Agency (EPA) regional office.

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

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

owner/operator of the plant site).

Over the next three years, an average of 52 respondents per year will be subject to the 

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

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

without any “Terms of Clearance.”

The respondents to this ICR (the “Affected Public) are publicly owned and operated leadacid battery manufacturing plants. None of the facilities are owned by either state, local and 

tribal agencies or the Federal government. The burden to respondents is calculated below in 
2

Table 1: Annual Respondent Burden and Cost − NSPS for Lead-Acid Battery Manufacturing 

(40 CFR Part 60, Subpart KK) (Renewal). Since this regulation only affects the lead-acid battery

manufacturing industry, the “burden” to the Federal Government is attributed entirely to work 

performed by either Federal employees or government contractor. This burden is calculated 

below in Table 2: Average Annual EPA Burden and Cost − NSPS for Lead-Acid Battery

Manufacturing (40 CFR Part 60, Subpart KK) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best-demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years.

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, lead emissions from lead-acid battery manufacturing 

plants either cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health and/or welfare. Therefore, the NSPS were promulgated for this source category at 

40 CFR part 60, subpart KK.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 
3

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 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 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 60, 

subpart KK.

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 standard is the 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. We estimate that there are 52 existing respondents subject to the reporting 

requirements of this standard, and that no new sources will become subject to the standards over 

the three-year period covered by this ICR.
4

Industry trade associations and other interested parties were provided an opportunity to 

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

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

purposes. For this renewal, we contacted: 1) the Advanced Lead Acid Battery Consortium 

(ALABC), at (919) 361-4674; and 2) the Battery Council International (BCI), at (202) 719-4107.

EPA did not receive any comments from the consultations. 

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 standard do not include sensitive 

questions.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are lead acid battery

manufacturing plants. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 3691 for Storage Batteries, which corresponds to 

the North American Industry Classification System (NAICS) code 335911 for Storage Battery

Manufacturing.

4 (b) Information Requested

(i) Data Items

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

Acid Battery Manufacturing (40 CFR Part 60, Subpart KK).

A source must make the following reports:

Notifications

Notification of construction/reconstruction 60.7(a)(1) 

Notification of initial startup 60.7(a)(3)

Notification of initial performance test 60.8(d)

Physical or operational change 60.7(a)(4)

Reports

Report opacity results (reported with the initial performance test 

results) and at other times opacity observations are required 60.11(e)

Report of performance test results 60.8(a)

Periodic reports if using continuous emissions monitoring systems 

(e.g., semiannual)

60.7(c)

60.7(e)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system is inoperative

60.7(b)

Performance test records 60.7(d)

60.7(e), 60.373
6

Recordkeeping

Pressure drop monitoring records for sources using a scrubber system 

Maintain records for at least two years 60.7(f)

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 a monitoring device that measures pressure drop across 

the scrubbing system every 15 minutes.

Perform initial performance test using Reference Method 12 to determine lead concentration 

and volumetric flow rate, and Reference Method 9 for opacity readings, 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.

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.

Transmit, or otherwise disclose the information.
7

Currently, sources are using monitoring equipment that provides 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 results, 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 might 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 two 

years.

5(c) Small Entity Flexibility

There are no small entities (i.e. small businesses) affected by this regulation. The 

information available on the Lead-Acid Battery Manufacturing sector indicates that small 

operations are being bought by larger facilities. It was assumed for this ICR that none of the 

existing sources is a small entity.
8

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 – NSPS for Lead-Acid Battery

Manufacturing (40 CFR Part 60, Subpart KK) (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 4,053 hours (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 NSPS 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 $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

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.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitors and other costs such as photocopying and postage.
9

(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 Costs, 

(B X C)

(E)

Annual 

O&M 

Costs for 

One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M 

Costs,

(E X F)

Pressure Drop 

Monitors1

$ 0 0 0 $ 900 13 $ 11,700

1

 It is estimated that 25 percent of the 52 existing sources (i.e., 13 sources) have scrubber systems and are, therefore, required to 

install and maintain a monitor to measure and record pressure drop across the scrubbing system.

There are no capital/startup costs for this ICR. This is the total of column D in the above 

table.

The total operation and maintenance (O&M) costs for this ICR are $ 11,700. 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 $11,700. These are the costs of

recordkeeping.

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 

$4,687.

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

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

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

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

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

for Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) (Renewal).
10

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 52 existing respondents will be subject 

to the standards on an average year over the next three years. 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 52 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 13 39 0 52

2 0

13 39 0 52

3 0

13 39 0 52

Average 0 13 39 0 52

To avoid double-counting respondents column D is subtracted. As shown above, the 

average Number of Respondents over the three year period of this ICR is 52.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents1 

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual 

Responses 

E=(BxC)+D

Notification of initial performance 

test

0 1 0 0

Notification of construction / 

reconstruction

0 1 0 0

Notification of initial startup 0 1 0 0

Semi-annual Report 13 2 39 65

Total 65

1 Because we do not anticipate any new sources to become subject to the NSPS, so no initial performance tests or notifications 

are incorporated in the count of responses. The information available on the sector indicates that facilities are closing operations 

or are that small operations are being bought by larger facilities, so we have also assumed that there will be no significant process 

changes triggering NSPS, subpart KK, applicability.
11

The number of total annual responses is 65. 

The total annual labor costs are $392,422. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Lead-Acid Battery

Manufacturing (40 CFR Part 60, Subpart KK) (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 4,053 hours at a cost of $392,422. Details regarding 

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

for Lead- Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) (Renewal). 

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

of information is estimated to average 62 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $11,700. 

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 104

labor hours at a cost of $4,687. See Table 2 below: Average Annual EPA Burden and Cost –

NSPS for Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) (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 very

low, negative or non-existent, so there is no significant change in the overall burden. However, 

there is an increase in the total respondent labor costs as currently identified in the OMB 

Inventory of Approved Burdens. This increase is not due to any program changes. The change 

in cost estimates reflects updated labors rates available from the Bureau of Labor Statistics. 

There is a slight decrease in the annual O&M cost from the previous ICR due to 

rounding. The previous ICR estimated an O&M cost of $11,700 but rounded the figure to the 

nearest thousand, or $12,000. This ICR presents a more-accurate cost figure by not rounding the 

O&M costs.

6(g) Burden Statement

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

is estimated to average 62 hours per response. Burden means the total time, effort, or financial 
12

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-2012-0656. 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 

Number EPA-HQ-OECA-2012-0656 and OMB Control Number 2060-0081 in any

correspondence.

Part B of the Supporting Statement

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

information.
13

Table 1: Annual Respondent Burden and Cost – NSPS for Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) 

(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

(F=Ex0.05)

(G)

Clerical 

person 

hours per 

year

(G=Ex0.1)

(H)

Total Cost 

Per year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read Instructions Included in 3B

 B. Required Activities

 New Sources

 Initial performance test c20.87 1 20.87 0 0 0 0 $0

 Repeat performance test d20.87 1 20.87 0 0 0 0 $0

 New and Existing Sources

 Monitoring of emissions and operations Included in 4E

 C. Create information Included in 3B

 D. Gather existing information Included in 3E

 E. Write Report

 New Sources

 Notification of construction/reconstruction/ 

 Modification

1.74 1 1.74 0 0 0 0 $0

 Notification of initial startup 1.74 1 1.74 0 0 0 0 $0

 Notification of CMS demonstration 1.74 1 1.74 0 0 0 0 $0

 Notification of initial performance test 1.74 1 1.74 0 0 0 0 $0

 Report of performance test Included in 3B

 New and Existing Sources

 Semiannual reports

e

13.91 2 27.83 13 361.74 18.09 36.17 $40,280.73

Subtotal for Reporting Requirements 416 $40,280.73

4. Recordkeeping requirements

 A. Read instructions Included in 3A

 B. Plan activities Included in 4E

 C. Implement Activities Included in 4E

 D. Develop record system N/A

 E. Time to enter information

 Records monitoring of emissions and operations f0.64 365 238.04 13 3,094.56 154.73 309.46 $344,589.03

 Records of startups, shutdowns, malfunctions, etc. 1.30 1 1.30 52 67.83 3.39 6.78 $7,552.64

 F. Train Personnel N/A

 G. Audits N/A
14

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

(F=Ex0.05)

(G)

Clerical 

person 

hours per 

year

(G=Ex0.1)

(H)

Total Cost 

Per year b

Subtotal for Recordkeeping Requirements 3,637 $352,141.67

TOTAL LABOR BURDEN AND COST (rounded) 4,053 $392,422 

Assumptions:

a We have assumed that there are approximately 52 sources currently subject to NSPS, subpart KK. We have assumed that there will be no new sources over the period of this ICR. Therefore, 

the average number of respondents per year is estimated to be 52.

b This ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51 per hour for Clerical labor. 

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.

c All sources are required to use Method 9 for opacity observations, except for lead oxide manufacturing facilities. All respondents would have to perform Method 12 to calculate the lead 

concentration and the volumetric flow rate of the effluent gases. It requires at least three runs of 60 minutes and 0.85 dscm.

d We have assumed that 20 percent of initial performance tests must be repeated due to failure.

e

 Semiannual reports are required by this rule for those sources that have to install continuous monitoring systems (e.g., pressure drop monitors across the scrubbing systems). We have assumed 

that 25% of the sources (i.e., 13 sources) have scrubbing systems.

f

 Monitoring of emissions and operations requirements includes pressure drop measurements across the scrubbing system at least every 15 minutes, if applicable. We have assumed that 25% of 

the sources (i.e., 13 sources) have scrubbing systems.
15

Table 2: Average Annual EPA Burden and Cost – NSPS for Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK)

 (Renewal)

Activity

(A)

EPA personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

per 

year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

New Sources

 Notification of construction/reconstruction 1.74 1 1.74 0 0 0 0 $0

 Notification of initial startup 0.87 1 0.87 0 0 0 0 $0

 Notification of CMS demonstration 0.87 1 0.87 0 0 0 0 $0

 Notification of Initial Performance Test 0.43 1.2 0.52 0 0 0 0 $0

 Initial Performance Test 20.87 1 20.87 0 0 0 0 $0

 Repeat of Performance Test c20.87 0.2 4.17 0 0 0 0 $0

 Review Performance Test results c6.96 1.2 8.35 0 0 0 0 $0

New and Existing Sources

 Review of Semi-annual Reports d2 1 6.96 13 90.43 4.52 9.04 $4,686.74

Subtotals Labor Burden and cost 103.99 $4,686.74

TOTAL ANNUAL BURDEN AND COST (rounded) 104 $4,687

Assumptions:

a

 We have assumed that there are approximately eighty-nine respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Within those 

eighty-nine existing sources, only seventy-six are subject to the emission limits in the standard. The remaining thirteen respondents are permitted as synthetic minors and, therefore, are not subject 

to the emission limits in the standard. 

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for Managerial (GS-13, Step 5, $38.92 

x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General 

Schedule” which excludes locality rates of pay.

c We have assumed that 20 percent of initial performance tests is typically repeated due to failure.

d We have assumed that 25 percent of the 52 existing sources (i.e., 13 sources) have scrubber systems and are therefore, required to install and maintain a monitor to measure and record 

pressure drop across the scrubbing system, and submit semi-annual reports.