SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Secondary Brass and Bronze Production (40 CFR Part 60, Subpart M)

(Renewal), Primary Copper Smelters (40 CFR Part 60, Subpart P) (Renewal), Primary 

Zinc Smelters (40 CFR Part 60, Subpart Q) (Renewal), Primary Lead Smelters (40 CFR 

Part 60, Subpart R) (Renewal), Primary Aluminum Reduction Plants (40 CFR Part 60, 

Subpart S) (Renewal), and Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z)

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Secondary Brass and Bronze Production (40 CFR Part 60, Subpart M) (Renewal), 

Primary Copper Smelters (40 CFR Part 60, Subpart P) (Renewal), Primary Zinc Smelters (40 

CFR Part 60, Subpart Q) (Renewal), Primary Lead Smelters (40 CFR Part 60, Subpart R)

(Renewal), Primary Aluminum Reduction Plants (40 CFR Part 60, Subpart S) (Renewal), and 

Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z) (Renewal), EPA ICR Number 

1604.10, OMB Control Number 2060-0110. 

1(b) Short Characterization/Abstract

Below is a brief characterization of the New Source Performance Standards (NSPS) for the 

subparts covered by this Information Collection Request (ICR):

Secondary Brass and Bronze

The NSPS for Secondary Brass and Bronze Production (40 CFR Part 60, Subpart M) 

were proposed on June 11, 1973, promulgated on March 8, 1974, and amended most recently on 

October 17, 2000. These regulations apply to any facility that commences construction or 

modification after June 11, 1973. These standards apply to the following facilities in secondary

brass or bronze production plants: reverberatory and electric furnaces of 1,000 kg or greater 

production capacity and blast (cupola) furnaces of 250 kg/hr or greater production capacity. 

Furnaces from which molten brass or bronze are cast into the shape of finished products, such as 

foundry furnaces, are not considered to be affected facilities. This information is being collected 

to assure compliance with 40 CFR part 60, subpart M.

It is estimated that there are 11 brass and bronze producers of brass and bronze ingots 

operating nationwide, of which many are small businesses. We have further assumed that only 

five of the brass and bronze producers are subject to the NSPS standards, and that no additional 

sources per year will become subject to the standard in the next three years.

Primary Copper Smelters

The NSPS for Primary Copper Smelters (40 CFR Part 60, Subpart P) were proposed on 
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October 16, 1974, promulgated on January 15, 1976, and most recently amended on October 17, 

2000. These regulations apply to any facility that commences construction or modification after 

October 16, 1974. These standards apply to the following facilities in primary copper smelters: 

dryer, roaster, smelting furnace, and copper converter. This information is being collected to 

assure compliance with 40 CFR part 60, subpart P.

It is estimated that there are seven copper smelters in the United States, of which six are 

engaged in the production of anode copper from copper ore concentrates using pyrometallic 

processes and would be subject to the NSPS standards. There is another copper smelter which 

uses a continuous flash furnace for converting matter copper to blister copper, but is not covered 

by this rule. We have further assumed that no additional sources will become subject to the 

standard in the next three years.

Primary Zinc Smelters

The NSPS for Primary Zinc Smelters (40 CFR Part 60, Subpart Q) were proposed on 

October 16, 1974, promulgated on January 15, 1976, and most recently amended on February

14, 1989. Any facility that commences construction or modification after October 16, 1974, is 

subject to the requirements of this subpart. These standards apply to the following facilities in 

primary zinc smelters: roaster and sintering machines. This information is being collected to 

assure compliance with 40 CFR part 60, subpart Q.

It is estimated there is only one pyro-metallurgical zinc manufacturing facility operating 

nationwide that is subject to the NSPS standards. We have further assumed that no additional 

sources will become subject to these standards in the next three years.

Primary Lead Smelters

The NSPS for Primary Lead Smelters (40 CFR Part 60, Subpart R) were proposed on 

October 16, 1974, promulgated on January 15, 1976, and most recently amended on February 14, 

1989. Any facility that commences construction or modification after October 16, 1974 is 

subject to the requirements of this subpart. These standards apply to the following facilities in 

primary lead smelters: sintering machine, sintering machine discharge end, blast furnace, dross 

reverberatory furnace, electric smelting furnace, and converter. This information is being 

collected to assure compliance with 40 CFR part 60, subpart R.

Only one lead smelter, DOE Run, is estimated to be subject to the NSPS standards. 

However, the sintering machine and blast furnace at DOE Run are scheduled to be shut down by

April 2014 based on a consent decree. Therefore, no burden is expected for these units. We 

have further assumed that no additional sources will become subject to the standard in the next 

three years.

Primary Aluminum Reduction Plants

The NSPS for Primary Aluminum Reduction Plants (40 CFR Part 60, Subpart S) were 
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proposed on October 23, 1974, promulgated on July 25, 1977, and amended most recently on 

February 14, 1989. Any facility that commences construction or modification after October 23, 

1974, is subject to the requirements of this subpart. These standards apply to the following 

facilities in primary aluminum reduction plants: potroom groups and anode bake plants. This 

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

It is estimated that there are 23 primary aluminum plants currently operating nationwide. 

The 23 plants are estimated to have 91 potlines that produce aluminum. Each plant has a paste 

production plant, and only 17 of these plants have anode bake furnaces. Of the total number of 

plants, we have assumed that five potlines at four primary aluminum plants are subject to the 

NSPS standard. However, the Agency has allowed sources to comply with the requirements for 

potroom groups and anode bake furnaces in 40 CFR part 63, subpart LL (“MACT standard”) as 

an alternative to the NSPS requirements. We have assumed that sources have elected to comply

with the MACT requirements for anode bake furnaces and therefore, the burden for the NSPS 

standard would be associated with meeting the requirements for potrooms only. We have further 

assumed that any new source potentially subject to the NSPS standard will elect to comply with 

the MACT standard provisions and as a result no new sources will become subject to the NSPS 

standard in the future.

Ferroalloy Production Facilities

The NSPS for Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z) were 

proposed on October 21, 1974, promulgated on July 25, 1977, and amended most recently on 

October 17, 2000. Any facility that commences construction or modification after October 21, 

1974 is subject to the requirements of this subpart. These standards apply to the following 

facilities in ferroalloy production plants: electric submerged arc furnaces which produce silicon 

metal, ferrosilicon, calcium silicon, silicomanganese zirconium, ferrochrome silicon, silvery

iron, high-carbon ferrochrome, charge chrome, standard ferromanganese, silicomanganese, 

ferromanganese silicon, or calcium carbide; and dust-handling equipment. This information is 

being collected to assure compliance with 40 CFR part 60, subpart Z.

It is estimated that there are only seven ferroalloy production facilities currently operating 

nationwide. Of the total number of facilities, we have assumed that two ferroalloy production 

facilities, Simcala and Globe Selma, are subject to the NSPS standards. We have further 

assumed that no additional sources per year will become subject to the NSPS standards over the 

next three years since demand for domestic production of ferroalloys has declined.

Based on all the information gathered from industry data gathered during the 

development of the NSPS rules and industry experts and as it is specified in the individual 

descriptions of the industry sectors above, we have concluded that the production of domestic 

nonferrous metals has declined over the past decade resulting in no new plants being built and in 

many plants permanently closing down operations.

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 
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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/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.

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

without any “Terms of Clearance”. 

The “Affected Public” includes secondary brass and bronze production facilities, primary

copper smelters, primary zinc smelters, primary lead smelters, primary aluminum reduction 

plants, and ferroalloy production facilities. The “burden” to the Affected Public may be found 

below in Tables 1a thru 1d: Annual Respondent Burden and Cost – NSPS for Secondary Brass 

and Bronze Production (40 CFR Part 60, Subpart M) (Renewal), Primary Copper Smelters (40 

CFR Part 60, Subpart P)(Renwal), Primary Zinc Smelters (40 CFR Part 60, Subpart Q)

(Renewal), Primary Lead Smelters (40 CFR Part 60, Subpart R) (Renewal), Primary Aluminum 

Reduction Plants (40 CFR Part 60, Subpart S) (Renewal), and Ferroalloy Production Facilities 

(40 CFR Part 60, Subpart Z) (Renewal). The Federal Government “burden” is attributed entirely

to work performed by either Federal employees or government contractors and is found below in 

Tables 2a thru 2d: Average Annual EPA Burden and Cost – NSPS for Secondary Brass and 

Bronze Production (40 CFR Part 60, Subpart M) (Renewal), Primary Copper Smelters (40 CFR 

Part 60, Subpart P) (Renewal), Primary Zinc Smelters (40 CFR Part 60, Subpart Q) (Renewal), 

Primary Lead Smelters (40 CFR Part 60, Subpart R) (Renewal), Primary Aluminum Reduction 

Plants (40 CFR Part 60, Subpart S) (Renewal), and Ferroalloy Production Facilities (40 CFR Part 

60, Subpart Z) (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).
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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, particulate matter emissions and sulfur dioxide 

emissions from secondary brass and bronze, primary copper, lead and zinc smelter facilities, 

particulate matter and total fluoride emissions from primary aluminum reduction plants, and 

carbon monoxide emissions from ferroalloy production facilities cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the 

NSPS were promulgated for this source category at 40 CFR part 60, subparts M, P, Q, R, S, and 

Z.

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 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 standards are being met. 

The performance test may also be observed.
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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, subparts

M, P, Q, R, S, and Z.

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 (78 FR 33409) on June 4, 2013. 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 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. 

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. In developing this ICR, we contacted: 1) Asarco, at (520) 798-7500; and 2) Kennecott 

Utah Copper, at (801) 204-2000.

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. 
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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

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.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are brass and bronze 

production facilities, primary copper smelters, primary zinc smelters, primary lead smelters, 

aluminum reduction plants, and ferroalloy production facilities. The United States Standard 

Industrial Classification (SIC) code for the respondents affected by the standards and the 
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corresponding North American Industry Classification System (NAICS) codes are listed in the 

table below. 

Standard (40 CFR Part 60, Subparts M, P, Q, R, S, 

and Z)

SIC Codes NAICS Codes

Secondary Smelting, Refining, and Alloying of 

Nonferrous Metal (except Copper and Aluminum) 3341 331492

Primary Smelting and Refining of Copper 3331 331411

Primary Smelting and Refining of Nonferrous Metal 

(except Copper and Aluminum) 3339 331419

Primary Aluminum Production 3334 331312

Electrometallurgical Ferroalloy Product Manufacturing 3313 331112

4(b) Information Requested

(i) Data Items

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

Secondary Brass and Bronze Production (40 CFR Part 60, Subpart M), Primary Copper Smelters 

(40 CFR Part 60, Subpart P), Primary Zinc Smelters (40 CFR Part 60, Subpart Q), Primary Lead 

Smelters (40 CFR Part 60, Subpart R), Primary Aluminum Reduction Plants (40 CFR Part 60, 

Subpart S), and Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z). 

A source must make the following reports:

Notifications

Notification and application of construction or modification 60.7(a)(1)

Notification of actual startup 60.7(a)(3)

Notification of physical or operational change which may increase the 

emission rate

60.7(a)(4)

Notification of the date of demonstration of continuous monitoring 

system performance commencement (except for subpart M)

60.7(a)(5)

Notification of the continuous opacity monitoring system data results 

will be used to determined compliance with the opacity standard

60.7(a)(7)

Notification of the anticipated date for conducting the opacity of 

observations (visible emissions observations)

60(a)(6) and 

60.11(e)(1)

Notification of initial performance test 60.8(d)
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Notifications

Advance notification of each monthly performance test after the initial 

performance test (NSPS subpart S only) 

60.194(c)

Reports

NSPS Subparts M, P, Q, R, S, and Z

Performance test results 60.8(a)

Report of excess emissions of fluoride (between 1.0 kg/Mg and 1.3 

kg/Mg) in any monthly performance test, under NSPS subpart S

60.192(b)

NSPS Subparts P, Q, R, S, and Z Z [except for NSPS subpart M which does not required 

sources to installed a continuous monitoring 

system (CMS)]

Semiannual reports of excess emissions and deviations from parameters 

established during the performance test if using a continuous monitoring 

device, as described below:

60.7(c)

Excess emissions of opacity and sulfur dioxide under NSPS, subpart P 60.165(d)

Excess emissions of opacity and sulfur dioxide under NSPS subpart Q 60.175(c)

Excess emissions of opacity and sulfur dioxide under NSPS subpart R 60.185(c)

Excess emissions of opacity, under NSPS subpart Z 60.264(b)

NSPS Subpart Z

Report of any product change no later than 30 days after implementation 

of product change

60.264(c)

A source must keep the following records:

Recordkeeping

NSPS Subparts M, P, Q, R, S and Z

Startups, shutdowns, malfunctions, periods where the continuous 

monitoring system, if required, is inoperative

60.7(b)

Emission test results, continuous monitoring system data, performance 

test results and other data needed to determine compliance with mass 

and visible emission limits.

60.7(d), 60.7(f)
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Recordkeeping

Records are required to be retained for two years 60.7(f)

NSPS Subpart P

Monthly records of the total smelter charge and the weight percent (dry

basis) of arsenic, antimony, lead and zinc contained in the charge.

60.165(a)

NSPS Subparts Q and R

Calculations of two-hour average sulfur dioxide concentrations that 

have been recorded daily for the 12 consecutive 2-hour periods of each 

operating day.

60.175(b), 

60.185(b)

NSPS Subpart S

Daily records of the weight of aluminum and anode produced; of 

production rates of aluminum and anodes; raw material feed rates; and 

cell or potline voltages.

60.194(a)

60.194(b)

NSPS Subpart Z

Daily records of product produced; description of constituents of 

furnace charge, including the quantity, by weight; time and duration of 

each tapping period and identification of material tapped; all furnace 

power input data obtained; all flow rate data or all fan motor power 

consumption and pressure drop data.

60.265(a)

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.
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Respondent Activities

With the exception of subpart M, respondents shall install, calibrate, maintain, and operate a 

CMS. Subparts P, Q, R, and Z respondents shall use a CMS to monitor for opacity. In 

addition, subparts P, Q, and R respondents shall use a CMS to monitor sulfur dioxide 

emissions. Subpart S respondents shall use a CMS to daily weigh aluminum and anode 

produced. Subpart Z respondents also shall use a CMS to measure and record the furnace 

power input, the flow rate through each separately ducted hood of the capture system or, 

alternatively, measure and record all fan motor power consumption and pressure drop across 

the fan.

Perform initial and monthly/annual performance test, if applicable, repeat performance tests. 

Respondents shall use the following Reference Methods (RM): 1) RM 5 for particulate matter 

concentrations and volumetric flow rate of the effluent gas (all subparts); 2) RM 9 for visible 

emissions observations of opacity (all subparts); 3) RM 13A or 13B for ducts or stacks and 

RM 14 for roof monitors to determine the total fluoride concentration and volumetric flow rate 

of effluent gas (subpart S); and 4) Use RM 3B integrated sampling procedure to determine the 

carbon monoxide concentration and determine the emission rate correction factor to determine 

the rate of particulate matter (subpart Z).

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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., inlet and outlet concentrations when determining percent 

efficiency). 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. 
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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, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard, and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

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

Many of the primary nonferrous facilities are operated by large corporations and there are 

not any estimated small entities at Primary Copper smelters. Given the small amount of total 

affected entities, this ICR renewal assumes zero small entities will be affected. In the 

development of the NSPS standards, the recordkeeping and reporting requirements were selected 
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within the context of the specific subpart and the specific industry sector processes equipment 

and pollutants. The standards reflect the burden on small businesses. 

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 in below Tables 1a thru 1d: Annual Respondent Burden and Cost – NSPS for Secondary

Brass and Bronze Production (40 CFR Part 60, Subpart M) (Renewal), Primary Copper Smelters 

(40 CFR Part 60, Subpart P) (Renewal), Primary Zinc Smelters (40 CFR Part 60, Subpart Q)

(Renewal), Primary Lead Smelters (40 CFR Part 60, Subpart R) (Renewal), Primary Aluminum 

Reduction Plants (40 CFR Part 60, Subpart S) (Renewal), and Ferroalloy Production Facilities 

(40 CFR Part 60, Subpart Z) (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 each of 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 4,961 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: 
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Managerial $122.49 ($58.33+ 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

September 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.

Table 1 Index: Total Annual Respondent Burden and Cost

Table NSPS Standard(s) Labor Hours Annual Cost

Table 1a NSPS for Secondary Brass and Bronze Production (40 

CFR part 60, subpart M) 1,058 $103,486

Table 1b

NSPS for Primary Copper Smelters (40 CFR part 60, 

subpart P); Primary Zinc Smelters (40 CFR part 60, 

subpart Q); and Primary Lead Smelters (40 CFR part 

60, subpart R)

1,546 $151,179

Table 1c NSPS for Primary Aluminum Reduction Plants (40 

CFR part 60, subpart S) 1,915 $187,265

Table 1d NSPS for Ferroalloy Production Facilities (40 CFR part 

60, subpart Z) 442 $43,194

Total 4,961 $485,124

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

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

subject standards 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 monitor(s) and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
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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)

Subpart M

None N/A 0 $0 N/A 0 $0

Subparts P, Q, R

Opacity monitor $36,000 0 $0 $7,500 7 $52,500

CMS that measures SO2

emissions $25,100 0 $0 $5,400 7 $37,800

Subpart S

CMS that weighs Al and 

anode produced daily Unknown 0 $0 $5,000 4 $20,000

Subpart Z

Opacity monitor $36,000 0 $0 $7,500 2 $15,000

CMS that measures 

furnace power input and 

flow rate or fan motor 

power consumption and 

pressure drop across fan 

Gas flow -

$13,500

Pressure drop -

$1,300

0 $0 $900 2

$1,800

TOTAL $0 $127,100

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 $127,100. 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 $127,100. 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 

$10,779. 
16

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 Secondary

Brass and Bronze Production (40 CFR Part 60, Subpart M), Primary Copper Smelters (40 CFR 

Part 60, Subpart P), Primary Zinc Smelters (40 CFR Part 60, Subpart Q), Primary Lead Smelters

(40 CFR Part 60, Subpart R), Primary Aluminum Reduction Plants (40 CFR Part 60, Subpart S), 

and Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z) (Renewal). 

Table 2 Index: Total Annual Burden and Cost for the Federal Government

Table NSPS Standard(s) Labor Hours Annual Cost

Table 2a NSPS for Secondary Brass and Bronze Production (40 

CFR part 60, subpart M) 0 $0 

Table 2b NSPS for Primary Copper Smelters (40 CFR part 60, 

subpart P); Primary Zinc Smelters 

(40 CFR part 60, subpart Q); and Primary Lead Smelters 

(40 CFR part 60, subpart R)

64 $2,902

Table 2c NSPS for Primary Aluminum Reduction Plants (40 CFR 

part 60, subpart S) 156 $7,048

Table 2d NSPS for Ferroalloy Production Facilities 

(40 CFR part 60, subpart Z) 18 $829

Total Cost 238 $10,779

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

19 existing respondents 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 19 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
17

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)

NSPS Subpart M

1 0 0 5 0 5

2 0 0 5 0 5

3 0 0 5 0 5

Average 5

NSPS Subpart P, Q and R

1 0 8 0 0 8

2 0 8 0 0 8

3 0 8 0 0 8

Average 8

NSPS Subpart S

1 0 4 0 0 4

2 0 4 0 0 4

3 0 4 0 0 4

Average 4

NSPS Subpart Z

1 0 2 0 0 2

2 0 2 0 0 2

3 0 2 0 0 2

Average 2

Total 19

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 19. 

The total number of annual responses per year is calculated using the following table: 
18

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

NSPS Subpart M

N/A 5 0 5 5

NSPS Subpart P, Q and R

Semiannual report 7 2 0 14

NSPS Subpart S

Notification of annual 

performance test 2 1 0 2

Notification of monthly 

performance test 2 12 0 24

Report of annual performance test 2 1 0 2

Report of monthly performance 

test 2 12 0 24

Semiannual report 4 2 0 8

Subpart S Total 60

NSPS Subpart Z

Semiannual report 2 2 0 4

Total (All Subparts) 83

The number of Total Annual Responses is 83. 

The total annual labor costs are $485,124. Details regarding these estimates may be 

found below in Tables 1a thru 1d: Annual Respondent Burden and Cost – NSPS for Secondary

Brass and Bronze Production (40 CFR Part 60, Subpart M) (Renewal), Primary Copper Smelters 

(40 CFR Part 60, Subpart P) (Renewal), Primary Zinc Smelters (40 CFR Part 60, Subpart Q), 

Primary Lead Smelters (40 CFR Part 60, Subpart R) (Renewal), Primary Aluminum Reduction 

Plants (40 CFR Part 60, Subpart S), and Ferroalloy Production Facilities (40 CFR Part 60, 

Subpart Z) (Renewal).
19

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 4,961 hours at a cost of $485,124. Details regarding 

these estimates may be found below in Table 1a thru 1d. Annual Respondent Burden and Cost –

NSPS for Secondary Brass and Bronze Production (40 CFR Part 60, Subpart M), Primary

Copper Smelters (40 CFR Part 60, Subpart P), Primary Zinc Smelters (40 CFR Part 60, Subpart 

Q), Primary Lead Smelters (40 CFR Part 60, Subpart R), Primary Aluminum Reduction Plants 

(40 CFR Part 60, Subpart S), and Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z)

(Renewal). 

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

information is estimated to average 60 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $127,100. 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 238 

labor hours at a cost of $10,779. See below Tables 2a thru 2d: Average Annual EPA Burden and 

Cost – NSPS for Secondary Brass and Bronze Production (40 CFR Part 60, Subpart M)

(Renewal), Primary Copper Smelters (40 CFR Part 60, Subpart P) (Renewal), Primary Zinc 

Smelters (40 CFR Part 60, Subpart Q) (Renewal), Primary Lead Smelters (40 CFR Part 60, 

Subpart R) (Renewal), Primary Aluminum Reduction Plants (40 CFR Part 60, Subpart S)

(Renewal), and Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z) (Renewal)

(Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the respondent burden from the most recently

approved ICR. This increase is not due to any program changes. The increase is due to a 

correction in respondent burden activity associated with NSPS Subpart S. The previous ICR did 

not include the time required to prepare semiannual reports for the respondents. This correction 

resulted in an increase in respondent burden hours, costs, and the total number of responses. 

There is also an increase in the respondent labor costs due to an update in labor rates. 

Further, there is an overall decrease in O&M costs due to an update in the number of 

sources. In this ICR, we estimate that two ferroalloy facilities are subject to Subpart Z and one 

primary lead facility is subject to subpart R; however, the affected sintering unit and blast 
20

furnace at this primary lead facility will be shutdown and will no longer have burden associated 

with these standards. 

6(g) Burden Statement

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

is estimated to average 60 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-2013-0334. 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-2013-0334 and OMB Control Number 2060-0110 in any

correspondence.

Part B of the Supporting Statement

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

information.
21

Table 1a: Annual Respondent Burden and Cost – NSPS for Secondary Brass and Bronze Production (40 CFR Part 60, Subpart

M) (Renewal)

BURDEN ITEMS

(A)

Respondent 

Hours per 

Occurrence 

(B)

Number of 

Occurrences 

per 

Respondent 

per Year 

(C)

Hours per 

Respondent 

per Year

(C=A x B) 

(D)

Number of 

Respondents 

per Year a 

(E)

Technical 

Hours per 

Year

(E=C x D) 

(F)

Management 

Hours per 

Year

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x 0.1) 

(H)

Total Labor 

Costs per 

Year b  

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

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

B. Required activities

Initial performance test c24 1 24 0 0 0 0 $0

Repeat of performance Test d24 0.2 4.8 0 0 0 0 $0

Reference method 5 or 9 e4 1.2 4.8 0 0 0 0 $0

Monitoring of emissions and systems performance f0.5 365 182.5 5 912.5 45.63 91.25 $102,642.11

C. Create information ------------------------Included in 3B and 4E----------------------------

D. Gather existing information ------------------------Included in 3B and 4E----------------------------

E. Write Report

Notification of actual startup e2 1 2 0 0 0 0 $0

Notification of initial performance test f2 1 2 0 0 0 0 $0

Notification of CMS e, f2 1 2 0 0 0 0 $0

Notification of anticipated date for conducting the 

opacity of observations e, f 2 1 2 0 0 0 0 $0

Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

Semiannual reports of excess emissions and 

monitoring systems performance g4 2 8 0 0 0 0 $0

Subtotal for Reporting Requirements 1,049.38 $102,642.11

4. Recordkeeping Requirements

A. Read instructions ------------------------Included in 3A----------------------------

B. Plan activities ------------------------Included in 3B----------------------------
22

C. Implement activities ------------------------Included in 3B----------------------------

D. Develop record system N/A

E. Time to enter and transmit information h

Records of startups, shutdowns, malfunctions, etc. 1.5 1 1.5 5 7.5 0.38 0.75 $843.63

Records of emissions and systems performance ------------------------Included in 3B----------------------------

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 8.63 $844.63

TOTAL LABOR BURDEN AND COST (rounded) 1,058 $103,486

Assumptions:

a We have assumed that are approximately 5 out of 11 secondary brass and bronze ingots production plants subject to NSPS subpart M. We have further assumed that no new sources will 

become subject to the rule over the three year period of this ICR. 

b

The labor rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates 

are from column 1, “Total compensation.” The rate has been increased by 110% to account for the benefit packages available to those employed by private industry.

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

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

e

 Sources are required to use the following Reference Methods (RM) in conducting performance tests, if applicable: 1) RM 5 for particulate matter concentrations and volumetric flow rate 

of the effluent gas (all subparts); 2) RM 9 for visible emissions observations of opacity. 

f Section 60.11 of the General Provisions allows sources to use a continuous opacity monitor (COM) in lieu of Method 9 to determine compliance with the opacity standard. However, we 

have assumed that all sources are complying with the standard using RM 9. 

g

 Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, sources 

subject to NSPS subpart M are not required to submit semiannual reports. 

h

Sources are required to maintain records of startups, shutdowns and malfunctions including periods where the continuous monitoring system is inoperative, and of emission test results, 

continuous monitoring system data including, performance test results and other data needed to determine compliance with mass and visible emission limits.
23

Table 1b: Annual Respondent Burden and Cost – NSPS for Primary Copper Smelters (40 CFR Part 60, Subpart P), Primary

 Zinc Smelters (40 CFR Part 60, Subpart Q), Primary Lead Smelters (40 CFR Part 60, Subpart R) (Renewal)

BURDEN ITEMS

(A)

Respondent 

Hours per 

Occurrence 

(B)

Number of 

Occurrences 

per 

Respondent 

per Year 

(C)

Hours per 

Respondent per 

Year

(C=A x B) 

(D)

Number of 

Respondents 

per Year a 

(E)

Technical 

Hours per 

Year

(E=C x D) 

(F)

Management 

Hours per 

Year

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x 0.1) 

(H)

Total Labor 

Costs per 

Year b  

1. Applications N/A

2. surveys and Studies N/A

3. Reporting Requirements

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

B. Required activities

 Initial performance test c24 1 24 0 0 0 0 $0

 Repeat of performance test d24 0.2 4.8 0 0 0 0 $0

 Reference Method 5 or 9 e4 1.2 4.8 0 0 0 0 $0

 Monitoring of emissions and operations f0.5 365 182.5 7 1,278 64 128 $143,698.95

C. Create information ------------------------Included in 3B and 4E----------------------------

D. Gather existing information ------------------------Included in 3B and 4E----------------------------

E. Write Report

 Notification of actual startup e2 1 2 0 0 0 0 $0

 Notification of initial performance test f2 1 2 0 0 0 0 $0

 Performance test results 2 1 2 0 0 0 0 $0

 Notification of CMS e, f2 1 2 0 0 0 0 $0

 

 Notification of anticipated date for conduction the 

opacity of observations e, f2 1 2 0 0 0 0 $0

 Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

 Semiannual reports of excess emissions and 

monitoring systems performance g 4 2 8 7 56 2.8 5.6 $6,299.13

 Process Change 2 2 4 0 0 0 0 $0

Subtotal for Reporting Requirements 1,534.4 $149,998.08

4. Recordkeeping Requirements

A. Read instructions ------------------------Included in 3A----------------------------
24

B. Plan activities ------------------------Included in3B----------------------------

C. Implement activities ------------------------Included in 3B----------------------------

D. Develop record system N/A

E. Time to enter and transmit information: h 

 Records of startups, shutdowns, malfunctions, etc. 1.5 1 1.5 7 10.5 0.53 1.05 $1,181.09

 Records of monitoring of emissions and operations ------------------------Included in 3B---------------------------- $0

F. Train personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 12.08 $1,181.09

TOTAL ANNUAL BURDEN AND COST (rounded) 1,546 $151,179

Assumptions:

a It is estimated that six primary pyrometallic copper smelters (subpart P), one primary pryrometallurgical zinc smelter (subpart Q), and one primary pryrometallurgical lead smelter (subpart 

R) are currently subject to the NSPS standards, which totals 8 respondents. However, the affected units at the primary lead smelter will be shutdown, and only 7 respondents will have 

burden associated with this rule. We have further assumed that no additional sources will become subject to the standard in the next three years.

b The labor rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates 

are from column 1, “Total compensation.” The rate has been increased by 110% to account for the benefit packages available to those employed by private industry.

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

d

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

e Sources are required to use the following Reference Methods (RM) in conducting performance tests, if applicable: 1) RM 5 for particulate matter concentrations and volumetric flow rate 

of the effluent gas (all subparts); 2) RM 9 for visible emissions observations of opacity. Sources are expected to conduct the visible emissions observation of opacity during the initial 

performance test.

f Section 60.11of the General Provisions allows sources to use a continuous opacity monitor (COM) in lieu of Method 9 to determine compliance with the opacity standard. However, we 

have assumed that all sources are complying with the standard using RM 9. 

g 

 Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, sources 

subject to NSPS subparts P, Q, R and S are required to submit semiannual reports. 

h

 Sources are required to maintain records of monitoring of operations including startups, shutdowns and malfunctions including periods where the continuous monitoring system is 

inoperative, emission test results, continuous monitoring system data including, performance test results and other data needed to determine compliance with mass and visible emission limits.
25

Table 1c: Annual Respondent Burden and Cost – NSPS for Primary Aluminum Reduction Plants (40 CFR Part 60, Subpart S)

 (Renewal)

BURDEN ITEMS

(A)

Respondent 

Hours per 

Occurrence 

(B)

Number of 

Occurrences 

per Respondent 

per Year 

(C)

Hours per 

Respondent 

per Year

(C=A x B) 

(D)

Number of 

Respondents 

per Year a 

(E)

Technical

Hours per 

Year

(E=C x D) 

(F)

Management 

Hours per 

Year

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x0.1)

(H)

Total Labor 

Costs per 

Year b  

1. Applications

2. Survey and Studies

3. Reporting Requirements

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

B. Required activities

Initial performance test c24 1 24 0 0 0 0 $0

Monthly performance test d24 12 288 2 576 28.8 57.6 $64,791.07

Annual performance test d24 1 24 2 48 2.4 4.8 $5,399.26

Repeat of performance test c, d24 1.3 31.2 4 125 6.2 12.5 $14,038.07

 Reference Method 5 or 9 e4 1.2 4.8 0 0 0 0 $0

 Monitoring of emissions and operations f0.5 365 182.5 4 730 36.5 73 $82,113.69

C. Create Information ------------------------Included in 3B and 4E----------------------------

D. Gather Existing Information ------------------------Included in 3B and 4E----------------------------

E. Write Report

 Notification of actual startup e2 1 2 0 0 0 0 $0

 Notification of annual performance tests d, f 2 1 2 2 4 0.2 0.4 $449.94

 Notification of monthly performance tests d, f 2 12 24 2 48 2.4 4.8 $5,399.26

 Performance test results f2 12 24 4 96 4.8 9.6 $10,798.51

 Notification of CMS e, f2 1 2 0 0 0 0 $0

 Notification of anticipated date for conduction the 

opacity of observations e, f2 1 2 0 0 0 0 $0

 Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

 Semiannual reports of excess emissions and 

monitoring systems performance g 4 2 8 4 32 1.6 3.2 $3,600

Process Change 2 2 4 0 0 0 0 $0

Subtotal for Reporting Requirements 1,907.8 $186,589.80

4. Recordkeeping Requirements
26

A. Read Instructions ------------------------Included in 3A----------------------------

B. Plan Activities ------------------------Included in 3B----------------------------

C. Implement Activities ------------------------Included in 3B----------------------------

D. Develop Record System N/A

E. Time to Enter and Transmit Information: h 

 Records of startups, shutdowns, malfunctions, etc. 1.5 1 1.5 4 6 0.3 0.6 $674.91

Records of monitoring of emissions and operations ------------------------Included in 3B---------------------------- $0

F. Train Personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 6.9 $674.91

TOTAL ANNUAL BURDEN AND COST (rounded) 1,915 $187,265

Assumptions:

a

It is estimated that there are 23 primary aluminum plants are currently operating nationwide with 91 potlines that produce aluminum, each plant having a paste production plant, and 

only 17 of these plants having anode bake furnaces. However, only a total of 5 potlines at 4 plants are estimated to be subject to the NSPS standards. However, the Agency has 

promulgated new standards for the primary aluminum sector, MACT subpart LL. This rule allows sources to comply with the requirements for potroom groups and anode bake 

furnaces as an alternative to the NSPS requirements. In addition, the MACT rule requirements for anode bake plants are more stringent and superseded the NSPS requirements for 

such affected facility. Therefore, the burden for complying with the NSPS standard is associated with sources complying with the requirements for potroom groups only. We have 

further assumed that no additional sources per year will become subject to the NSPS standard in the next three years. 

b The labor rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “Table 2. Civilian Workers, by occupational and industry group.” 

The rates are from column 1, “Total compensation.” The rate has been increased by 110% to account for the benefit packages available to those employed by private industry.

c

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

d The rule requires sources to conduct a monthly performance test after the initial test and requires them to provide a 15 days advance notice of each test, except for the two sources 

specified in the rule that were allowed to conduct an annual performance test. We have further assumed that only 10 percent of the performance tests will have to be repeated.

e Sources are required to use the following Reference Methods (RM) in conducting performance tests, if applicable: 1) RM 5 for particulate matter concentrations and volumetric 

flow rate of the effluent gas; and 2) RM 9 for visible emissions observations of opacity. 

f Section 60.11 of the General Provisions allows sources to use a continuous opacity monitor (COM) in lieu of Method 9 to determine compliance with the opacity standard. 

However, we have assumed that all sources are complying with the standard using RM 9. 

g

 Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, 

sources subject to NSPS subpart S are required to submit semiannual reports. 

h Sources are required to maintain records of their operations including records of startups, shutdowns and malfunctions, periods where the continuous monitoring system is 

inoperative, emission test results, performance test results and other operational data needed to determine compliance with mass and visible emission standards. 
27

Table 1d: Annual Respondent Burden and Cost – NSPS for Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z)

 (Renewal)

BURDEN ITEMS

(A)

Respondent 

Hours per

Occurrence 

(B)

Number of 

Occurrences 

per 

Respondent 

per Year 

(C)

Hours per 

Respondent 

per Year

(C=A x B) 

(D)

Number of 

Respondents 

per Year a 

(E)

Technical 

Hours per 

Year

(E=C x 

D) 

(F)

Management 

Hours per 

Year

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x 0.1) 

(H)

Total 

Labor 

Costs per 

Year b 

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 1 0 0 0 0 $0

B. Required Activities

Initial performance test c24 1 24 0 0 0 0 $0

Repeat of performance test c, d24 0.2 4.8 0 0 0 0 $0

 Reference Method 5 or 9 e4 1.2 4.8 0 0 0 0 $0

 Monitoring of emissions and operations f0.5 365 182.5 2 365 18.25 36.5 $41,056.84

C. Create Information ------------------------Included in 3B and 4E----------------------------

D. Gather Existing Information ------------------------Included in 3B and 4E----------------------------

E. Write Report

Notification of actual startup e2 1 2 0 0 0 0 $0

Notification of initial performance test f2 1 2 0 0 0 0 $0

Performance test results f2 1 2 0 0 0 0 $0

Notification of CMS e, f2 1 2 0 0 0 0 $0

Notification of anticipated date for conduction the opacity 

of observations e, f2 1 2 0 0 0 0 $0

Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

Notification of product change 4 1 4 0 0 0 0 $0

Semiannual reports of excess emissions and monitoring 

systems performance g 4 2 8 2 16 0.8 2 $1,799.75

Subtotal for Reporting Requirements 438.55 $42,857.59

4. Recordkeeping Requirements

A. Read Instructions ------------------------Included in 3A----------------------------

B. Plan Activities ------------------------Included in 3B----------------------------

C. Implement Activities ------------------------Included in 3B----------------------------
28

D. Develop Record System N/A

E. Time to Enter and Transmit Information: h 

Records of startups, shutdowns, malfunctions, etc. 1.5 1 1.5 2 3 0.15 0.3 $337.45

Records of monitoring of emissions and operations ------------------------Included in 3B---------------------------- $0

F. Train Personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 3.45 $337.45

TOTAL ANNUAL BURDEN AND COST (rounded) 442 $43,194

Assumptions:

a It is estimated that two of 7 ferroalloy production facilities nationwide are subject to the NSPS subpart Z standards. We have further assumed that no additional sources per year will 

become subject to the NSPS standard in the next three years. 

b

 The labor rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates 

are from column 1, “Total compensation.” The rate has been increased by 110% to account for the benefit packages available to those employed by private industry.

c

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

d

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

e

 Sources are required to use the following Reference Methods (RM) in conducting performance tests, if applicable: 1) RM 5 for particulate matter concentrations and volumetric flow rate 

of the effluent gas; 2) RM 9 for visible emissions observations of opacity. 

f Section 60.11 of the General Provisions allows sources to use a continuous opacity monitor (COM) in lieu of Method 9 to determine compliance with the opacity standard. However, we 

have assumed that all sources are complying with the standard using RM 9. 

g We have assumed that the one source will not have a product change over the 3 year period of the ICR.

h

 Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, sources 

subject to NSPS Subpart Z are required to submit semiannual reports. 

i Sources are required to maintain records of operations including startups, shutdowns and malfunctions, periods where the continuous monitoring system is inoperative, emission test 

results, and continuous monitoring system data including, performance test results and other data needed to determine compliance with mass and visible emission limits.
29

Table 2a: Average Annual EPA Burden and Cost – NSPS for Secondary Brass and Bronze Production (40 CFR Part 60,

 Subpart M) (Renewal)

Activity

(A)

EPA Hours

per 

Occurrence 

(Technical 

hours)

(B)

Number of 

Occurrences 

per Plant 

per Year

(C)

EPA Hours 

per Year

(C=A x B)

(D)

Plants per 

Year a

(E) 

Technical 

Hours per 

Year 

(E=C x D)

(F)

Management 

Hours per 

Year 

(F= E x 0.05)

(G)

Clerical 

Hours per 

Year

(G= E x 0.1)

(H)

Costs per 

Year b

Notification of actual startup c2 1 2 0 0 0 0 $0

Notification of initial performance test 2 1 2 0 0 0 0 $0

Report of performance test results 2 1 2 0 0 0 0 $0

Notification of CMS 2 1 2 0 0 0 0 $0

Notification of anticipated date for conducting the 

opacity of observations 2 1 2 0 0 0 0 $0

Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

Notification of Product Change 4 1 4 0 0 0 0 $0

Semiannual reports of excess emissions and monitoring 

systems performance d 4 2 8 0 0 0 0 $0

TOTAL ANNUAL BURDEN AND COST (rounded) 0 $0

Assumptions:

a.

 We have assumed that there are approximately five secondary brass and bronze producers subject to the NSPS subpart M standard and that no new sources will become subject to the 

NSPS standard in the next three years. 

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) 

"2012 General Schedule" which excludes locality rates of pay.

c.

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

d. Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, 

sources subject to NSPS Subpart M are not required to submit semiannual reports. 
30

Table 2b: Average Annual EPA Burden and Cost – NSPS for Primary Copper Smelters (40 CFR Part 60, Subpart P), Primary

Zinc Smelters (40 CFR Part 60, Subpart Q), Primary Lead Smelters (40 CFR Part 60, Subpart R) (Renewal)

Activity

(A)

EPA Hours 

per 

Occurrence 

(Technical 

hours) 

(B)

Number of 

Occurrences 

per Plant per 

Year 

(C)

EPA Hours 

per Year

(C=A x B) 

(D)

Plants per 

Year a 

(E) 

Technical 

Hours per 

Year 

(E=C x D) 

(F)

Management 

Hours per

Year 

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x 0.1) 

(H)

Costs per 

Year b 

Notification of actual startup c2 1 2 0 0 0 0 $0

Notification of initial performance test 2 1 2 0 0 0 0 $0

Report of performance test results 2 1 2 0 0 0 0 $0

Notification of CMS 2 1 2 0 0 0 0 $0

Notification of anticipated date for conducting the 

opacity of observations 2 1 2 0 0 0 0 $0

Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

Semiannual reports of excess emissions and monitoring 

systems performance d 4 2 8 7 56 2.8 5.6 $2,902.17

TOTAL ANNUAL BURDEN AND COST (rounded) 64 $2,902

Assumptions:

a.

 We have assumed that are approximately six primary copper smelters (subpart P), one primary zinc smelter (subpart Q), and one primary lead smelter 

(subpart R) subject to the NSPS standard for a total of eight respondents. However, the affected units at the one primary lead smelter facility will be shutdown, and only 7 facilities in total 

will have burden associated with this rule. We have further assumed that there will be no new sources in the next three years.

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) "2012 General 

Schedule" which excludes locality rates of pay.

c. Assumes that all existing sources are in compliance with the initial rule requirements. 

d.

 Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, sources 

subject to NSPS subparts P, Q and R are required to submit semiannual reports.
31

Table 2c: Average Annual EPA Burden and Cost – NSPS for Primary Aluminum Reduction Plants (40 CFR Part 60, Subpart

 S) (Renewal)

Activity

(A)

EPA Hours 

per 

Occurrence 

(Technical 

hours) 

(B)

Number of 

Occurrences 

per Plant per 

Year 

(C)

EPA Hours 

per Year

(C=A x B) 

(D)

Plants per 

Year a 

(E) 

Technical 

Hours per 

Year 

(E=C x D) 

(F)

Management 

Hours per 

Year 

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x 0.1) 

(H)

Costs per 

Year b 

Notification of actual startup c2 1 2 0 0 0 0 $0

Notification of annual or monthly performance tests d 

2 1 2 2 4 0.2 0.4 $207.30

2 12 24 2 48 2.4 4.8 $2,487.58

Report of annual or monthly performance test results d 

2 1 2 2 4 0.2 0.4 $207.30

2 12 24 2 48 2.4 4.8 $2,487.58

Notification of CMS 2 1 2 0 0 0 0 $0

Notification of anticipated date for conducting the 

opacity of observations 2 1 2 0 0 0 0 $0

Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

Semiannual reports of excess emissions and monitoring 

systems performance e 4 2 8 4 32 1.6 3.2 $1,658.38

TOTAL ANNUAL BURDEN AND COST (rounded) 156 $7,048

Assumptions:

a

It is estimated that there are 23 primary aluminum plants are currently operating nationwide with 91 potlines that produce aluminum, each plant having a paste production plant, and only 

17 of these plants having anode bake furnaces. However, only a total of 5 potlines at 4 plants are estimated to be subject to the NSPS standards. However, the Agency has promulgated 

new standards for the primary aluminum sector, MACT subpart LL. This rule allows sources to comply with the requirements for potroom groups and anode bake furnaces as an 

alternative to the NSPS requirements. In addition, the MACT rule requirements for anode bake plants are more stringent and superseded the NSPS requirements for such affected facility. 

Therefore, the burden for complying with the NSPS standard is associated with sources complying with the requirements for potroom groups only. We have further assumed that no 

additional sources per year will become subject to the NSPS standard in the next three years. 

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) 

"2012 General Schedule" which excludes locality rates of pay.

c. Assumes that all existing sources are in compliance with the initial rule requirements.

d.

 We assume that of the 4 plants two would have to notify/report of their annual performance tests and the other two their monthly performance tests

e.

Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, sources 

subject to NSPS subpart S are required to submit semiannual reports.
32

Table 2d: Average Annual EPA Burden and Cost – NSPS for Ferroalloy Production Facilities (40 CFR Part 60, Subpart Z)

 (Renewal)

Activity

(A)

EPA Hours 

per 

Occurrence 

(Technical 

hours) 

(B)

Number of 

Occurrences per 

Plant per Year 

(C)

EPA Hours 

per Year

(C=A x B) 

(D)

Plants per 

Year a 

(E) 

Technical 

Hours per 

Year 

(E=C x D) 

(F)

Management 

Hours per 

Year 

(F= E x 0.05) 

(G)

Clerical 

Hours per 

Year

(G= E x 0.1) 

(H)

Costs per 

Year b 

Notification of actual startup c2 1 2 0 0 0 0 $0

Notification of initial performance test 2 1 2 0 0 0 0 $0

Report of performance test results 2 1 2 0 0 0 0 $0

Notification of CMS 2 1 2 0 0 0 0 $0

Notification of anticipated date for conducting the 

opacity of observations 2 1 2 0 0 0 0 $0

Notification of modification/reconstruction 2 1 2 0 0 0 0 $0

Notification of product change 4 1 4 0 0 0 0 $0

Semiannual reports of excess emissions and monitoring 

systems performance d4 2 8 2 16 0.8 1.6 $829.19

TOTAL ANNUAL BURDEN AND COST (rounded) 18 $829

Assumptions:

a.

 We have assumed that there are 2 ferroalloy production facilities subject to NSPS subpart Z and that no new sources will become subject to the NSPS standard in the next three years. 

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) 

"2012 General Schedule" which excludes locality rates of pay.

c. Assumes that all existing sources are in compliance with the initial rule requirements. 

d Only existing sources using a continuous monitoring system (i.e., a COM or a continuous parameter monitoring system) are required to submit semiannual reports. Therefore, sources 

subject to NSPS subpart Z are required to submit semiannual reports.