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 L ead

- Acid Battery Manufacturing (40 CFR P art 60, S ubpart KK) (Renewal) , EPA I CR 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 propose d 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 an y startup, shutdown, or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average o f 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 ye ars, an average of 52 respondents per ye ar will be subject to the standard, and n o additional resp ondents per year will become subject to the standard. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any

“Terms of Clearance.” The respondents to this ICR (the “Affected Public) are publicl y owned and operated lea d

acid 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 in2

Table 1: Annual Respondent Burden and Cost

− NSPS for L ead

- Acid Battery Manufacturing (40 CFR P art 60, S ubpart KK) (Renewal) . Since this regulation only affects the lead

- acid battery manufacturing industry , the “burden ” to the Federal Government is attributed entirel y to work performed b y either Federal employee s or government contractor. This burden is calculated below in Table 2: Average Annual EPA Burden and Cost

− NSPS for L ead

- Acid Battery Manufacturing (40 CFR P art 60, S ubpart 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 sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y 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 e very 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 reasonabl y require. In the Administrator's judgment, lead emissions from lead

- acid battery manufacturing plants either cause or contribute to air pollution that may reasonabl y 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 the3

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 le gal proceedings. Performance tests are required in order to determine an affected facility ’s initial capability to comp ly

with the emission standard

. Continuous emission monitors are used to ensure compliance with the standard at all times. During the p erformance 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 requi red in the standard are used to inform the Agency o r 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 and the standard is being met. T he 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 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 Register (77 FR 63813) on October 17 , 20 12 . 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 OTI S, which is operated and maintained by EPA’s Office of Compliance. OTI S is EPA’s database for the collection, maintenance, and retrieval of all compliance data. W e 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 standard s over the three

- ye ar period covered b y this ICR.4

Industry trade associations and other int erested 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 renewa l, 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 an y 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 Colle ction**  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 maint enance 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** These 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 f ive

- ye ar 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, an y pattern of non

- compliance and to determine the appropriate level of enforcement a ction. 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 in formation 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 369 02, 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 ( SI C ) code for the respondents affected b y the standards is SI C 3691 for Storage Batteries, which corresponds to the North American Industry Classification S ys tem (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 b y the NSPS for Lead Acid Battery

Manufacturing ( 40 CFR P art 60, S ubpart 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) Phy sical 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 s ys tems (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 sy stem is inoperative 60.7(b)

Performance test records 60.7(d) 60.7(e) , 60.3736 **Recordkeeping** Pressure drop monitoring records for sources using a scrubber s ys tem 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 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 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 s ys tem 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 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 informat ion. Adjust the existing way s to comply with an y 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 s ys tem). Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantl y 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 results, 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 might inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to co mpl y with the emission standard. Data and records maintained by the respon dents 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. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EP A uses the OTI S for tracking air pollution compliance and enforcement b y 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 require d by

this regulation must be retained by the owner/ operator for two ye ars. **5(c) Small Entity Flexibility** There are no small entities (i.e. small businesses) affected b y this regulation. The information available on the Lead

- Acid Battery Manufacturing sector indicates that small operations are being bought b y larger facilities. It was assumed for this I CR 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 P art 60, S ubpart KK) (Renewal) **. 6. Estimating the Burden a**  **nd 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 he adings believed to be consistent 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 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 record

keeping 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 an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR 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 b y 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 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 photocop yi ng 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 Monitors 1 $ 0 0 0 $ 900 13 $ 1 1 , 7 00

1 It is estimated that 25 percent of the 52 existing sources (i.e., 13 sources) have scrubber systems and are, therefore, requi red to install and maintain a monitor to measure and record pressure drop across the scrubbing system. There are no capital/star

tup costs for this IC R. This is the total of column D in the above table. The total operation and maintenance (O &M) costs for this I CR are $ 1 1 , 7 00 . 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 1 , 7 00 . These are the costs of recordkeeping. **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 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 hourl y labor rate as follows:

Managerial $6 2.27 (GS

- 13, Step 5, $38. 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), 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 emplo yees . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NSPS for Lead

- Acid Battery

Manufacturin g (40 CFR P art 60, S ubpart KK) (Renew al )

.10

**6(d) Estimating the Respondent Universe and Total Burden and Costs** Based o n our research for this I CR, approximately 52 existing respondents will be subject to the standard s on an aver age ye ar over the next three ye ars . It is estimated that no additional respondents per ye ar will become subject. The overall , average number of respondent s, as shown in the table below, is 52 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 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 ye ar period of this ICR is 52. The total number of annual responses per ye ar is calculated using the following table:

**Total Annual Responses**  (A) Information Collection Activity (B) Number of Respondents 1 (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 p erformance t est 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 operatio ns 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 estimate s may be found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Lead

- Acid Battery Manufacturing (40 CFR P art 60, S ubpart 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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 4,0 53 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, S ubpart KK) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden fo r 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 $1 1 , 7 00. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operati on 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 L ead

- Acid Battery Manufacturing (40 CFR P art 60, S ubpart KK) (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 regulations 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 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 currentl y 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.
T here 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 I CR 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 financial12

resources expended b y 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 s ys tems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 inform ation 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0 656

. An electronic version of the public docket is avail able 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 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

- 17 52 . 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 Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 20 12

- 0 656 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 informati on.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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Management person hours**  **per year**  **( F=**  **Ex 0.05)**  **(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 t est c 20.87 1 20.87 0 0 0 0 $0 Repeat performance test d 20.87 1 20.87 0 0 0 0 $0 New and Existing Sources Monitoring of emissions and operation s 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/ M odification 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 p erformance test 1.74 1 1.74 0 0 0 0 $0 Report of p erformance test Included in 3B New and Existing Sources Semiannual report s 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 f 0.64 365 2 38.04 13 3,094

. 56 154.73 309.46 $ 344 , 589 .0 3 Records of startups, shutdowns, malfunctions, etc. 1.30 1 1.30 52 67.83 3.39 6.78 $7,552.64 F. Train P ersonnel N/A G. Audits N/A14

**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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Management person hours**  **per year**  **( F=**  **Ex 0.05)**  **(G)**

**Clerical person**  **hours per year**  **( G=**  **Ex0.1) (H)** 

**Total Cost Per year**  **b**

**Subtotal for Recordkeeping Requirements** 3,63 7 $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: $121.4 4 per hour for Executive, Administrative, and Managerial labor; $ 100

. 23 per hour for Technical labor, and $ 50

. 5 1 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 201 2 , “Table 2: Civilian Workers, by Occupational and Industry Group.” The rates ar e 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 Semi annual 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 person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Management person**  **- hours**  **per year**
**(Ex0.05) (G)** 

**Clerical person**  **** **hours 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 2 0.87 0 0 0 0 $0 Repeat of Performance Test c 20.87 0.2 4.17 0 0 0 0 $0 Review Performance Test results c 6.96 1.2 8.35 0 0 0 0 $0 New and Existing Sources Review of Semi

- annual Reports d 2 1 6.96 13 90.43 4.52 9.04 $ 4,686.74 Subtotals Labor Burden and cost 10 3.99 $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 t hree 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 no t 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 acco unt 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 scrubbe r 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.