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

Copper Smelter s (40 CFR Part 63, Subpart QQQ) (Renewal) EPA I CR Number 1850.0 6 , OMB Control Number 2060

- 0476 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Primary Copper Smelters were proposed on April 20, 1998, and June 26, 2000, respectivel y. This standard applies to each new and existing affected source found at a primary c opper smelter. N ew facilities include those that commenced construction or reconstruction after the date of the proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart QQQ. The effected sources are copper concentrate dryer, smelting furnace, slag cleaning vessel, copper converter department, and the entire group of fugitive emission sources

. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports b y the owners/operators of the affected facilities. In addition, they are required to maintain records of the occurrence and duration of any startup , shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance and are required of all affected facilities subject to NESHAP. Owners and operators of a primary copper smelter are subject to the regulation only if it is a major source of hazardous air pollutant (HAP) emitting or has the potential to emit any single HAP at the rate of 10 tons or more per ye ar or any combination of HAP at a rate of 25 tons or more per year. In addition, respondents are required to submit an annual performance test report for each control device, along with a semiannual compliance report. These notifications, records, and reports are essential in determining compliance and are required of all sources subject to this subpart. Respondents subject to the rule are required to prepare and maintain on

- site two site

- specific operating plans: 1) a startup, shutdown, malfunction plan , and 2) a fugitive dust control plan. These plans do not require approval by EPA but are required to be maintained at the smelter site. Respondents subject to the provisions of this part are required to maintain a file of these measurements, and to retain the file for at least five years following the date of such measurements, maintenance reports, and records. Each record is to be filed at the site for at least two years after the date of each occurrence, measurement, maintenance, report or record, and off

- site for the remaining three years. 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 United2

States Environmental Protection Agency (EPA) regi onal office. Approximately

three respondents are currently subject to the regulation, and it is estimated that no additional new respondents will become subject to the regulation in the next three years. There are approximately

three primary

c opper sme lter plants in the United States which are owned and operated b y the copper smelter industry

. All three are owned and operated b y privately

- owned , for

- profit businesses. The burden to the “Affected Public” is listed in Table 1: Annual Industry

Burden and Cost

- NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ ) ( Renewal )

. The Federal government burden does not include work performed by Federal emplo ye es. The burden refers to work performed b y contractors, and that burden is found in Table 2: Average Annual EPA Burden

- NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ ) (Renewal).
In the development of the IC R, we addressed the Office of Management and Budget (OMB) “Terms of Clearance (TOC) ” on the active ICR. The TOC are as follows :

When this I CR is renewed, EPA shoul d review the respondent burden, universe, labor rates, and capital c osts and ensure these estimates have been updated. EPA has addressed each item of concern in the TOC. The respondent burden, universe, labor rates, and capital cost, have been thoroughly checked , and all estimates updated.
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standard s of performance for each category or subcategory

of major sources and area sources of HAP. These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction. In addition, section 114(a) states th at the Administrator may require any

owner or 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 m ethods; (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.3

In the Administrator's judgment, HAP emissions from p rimary copper smelters cause or contribute to air pollution that may reasonabl y b e anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, subpart QQQ. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. Inaddition, the col lected information is used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility’s i nitial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution contro l devices are properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed. The information generated by the monitoring, recordkeeping, and reporting requirem ents described in this I CR is used by the agency

to ensure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart QQQ. **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 s ent directl y to the delegated state or local agency
. If a state or local agency h as adopted their 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 b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R was published in the Federal Register (76 FR 26900) on May 9, 2011 . No comments were received on the burden published in the Federal Register

.4

**3(c) Consultations**
The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and m aintained by the EPA Office of Compliance. OTIS is the EPA 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. Approx imately

3 respondents will be subject to the standard over the three

- year period covered by this ICR. 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. In dev eloping this ICR, we contacted the United States Geological Survey (USGS) at (703) 648

- 4978, and America Copper Council (ACC) at ( 212 ) 945

- 4990

. It is our polic y t o respond after a thorough review of comments received since the las t ICR renewal as well as those submitted in response to the First Federal Register Notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the st andards. 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 b y these standards was collected les s frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General Guidelines** None of these reporting or recordkeeping requirements violate any of the regulations establ ished by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

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

- ye ar statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any p attern of non - compliance, and to determine the appropriate level of enforcement action. E PA has found that the most flagrant violators have violations extending beyond the five years. In addition, EPA would be prevent ed 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 i s made will5

be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sens itive Questions**  None of the reporting or recordkeeping requirements contains sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are primary copper smelters . The United States Standard Industrial Classification (SI C) code for the respondents affected b y the standard is 3331, which correspond to the North American Industry Classification Sy stem (NAI CS) code 331411 for Primary Smelting and Refining of Copper. **4(b) Information Requested** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items** In this ICR, all the data recorded or reported is re quired by the National Emission Standards for Hazardous Air Pollutants for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ). A source must make the following reports:
**Notifications** Initial notification 63.1454(a) , 63.9(b) Notification of performan ce test 63.1454(d), 63.7, 63.9(e) Notification of compliance status 63.1454(e) , 63.9(h) **Reports** Performance test reports 63.1454(a) , 63.10(d) Semiannual summary

reports 63.1454(b) , 63.10(e) A source must keep the following records: **Recordkeeping**6 **Recordkeeping** Records of startup, shutdown, and malfunctions 63.1456(a)(2), 63.1454(c) , 63.10(b)(2) Records of air pollution control equipment maintenance, malfunctions, and corrective actions 63.1456(c), 63.1454(c) , 63.10(b)(1) Records of performance tests and other supporting documentation used to demonstrate compliance with relevant standards under the rule 63.1456(a)(5), 63.1454(c) , 63.10(b)(2) Records of monthly

capture system visual inspection 63.1454(c) , 63.10(b)(2) Records of converter capture system operatin g parameter monitoring sy stem performance, calibration, and maintenance 63.1454(c) , 63.10(b)(2) Records of control device operating parameter monitoring sy stem performance, calibration, and maintenance 63.1454(c) , 63.10(b)(2) Records of control device or converter capture system operating parameter deviations 63.1454(c) , 63.10(b)(2) Copy of site

- specific air pollution equipment startup, shutdown, and malfunction plan 63.1450(c) , 63.6(e)(3) Copy of site

- specific smelter fugitive dust control plan 63.1448 (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 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. **Respondent Activities** Perform initial performance test, Reference Methods 1, 2F, 2G, 3, 3A, 3B, 4, 5, 5D, 17, 29 tests, and repeat performanc e 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, v alidating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information.7 **Respondent Activities** Adjust e xisting way s 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 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 ty pe of monitoring equipment has significantly reduc ed 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 acquisi tion, analysis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information System (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 operational. P erformance test reports are used b y the Agency to discern a source’s initial capability to comply

with the emission standard, and n ote 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.
In formation contained in the reports is entered into OTI S which i s operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. E PA uses OTIS for tracking air pol lution compliance and enforcement by l ocal and state regulatory

a gencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve , and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars.8

**5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the devel opment of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers thes e to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. T o 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

f or each information collection activity w ithin this request is shown in Table 1: Annual Industry Burden for NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)

. **6. Estimating the Burden and Cost of the Collection**  Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized h eadings 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 c onduct 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 th ese recordkeeping and reporting requirements is estimated to be 8,837 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $118.92 ($56.63 + 110%) Technical $97.78 ($46.56 + 110%) Clerical $4 8.76 ($23.22 + 110%)9

These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2010, "Table 2. Civilian Workers, by Occupational and Industry group." The rates are from column 1, "Total Compensation." The rates hav e been increased by 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collectio n activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenance (O&M) Cos**  **ts** (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)
Monitoring control device $2,800 0 $0 $1,540 3 $4,620 Monitoring converter hood $10,800 0 $0 $1,200 3 $3,600 $0 $8,220 The total capital/startup costs for this I CR are zero. This is the total of column D in the above table. The total operation and maintenance (O&M) costs consists of photocopying, and postage are $8,220. 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 ye ars of the I CR is estimated to be $ 8,220. **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. The EPA compliance and enforcement program includes activities such as: the examination of records maintain ed 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 $ 2,488

. This cost is based on the avera ge hourl y labor rate as follows:10 Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)
These rates are from the Office of Personnel Management (OPM) “2011 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 ye es. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden, NESHAP for Primary C opper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 3 respondents will be subject to the standard. It is estimated that no additional sources per year will become subject. The overall average number of respondents, as shown in the table below is 3 per ye ar. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR. **Number of Respondents**

Year (A)

Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 3 0 0 3 2 0 3 0 0 3 3 0 3 0 0 3 Average 0 3 0 0 3

1 New respondent include sources with constructed, reconstructed, and modified affected facilities. 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 3. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Inf ormation Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D Initial notification 3 1 N/A 3 Notification of performance test 3 5.5 N/A 16.511 **Total Annual Responses** (A) Inf ormation Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D Initial compliance determination 3 1 N/A 3 Performance test reports 3 5.5 N/A 16.5 Summary reports 3 2 N/A 6 Total 45 The number of Total Annual Responses is 45. The total annual labor costs are $ 847,257 . Details regarding th ese estimates may be found in Table 1: Annual Industry Burden and Cost

- NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal). **6(e) Bottom Line Burden Hours Burden Hours and Cost Tables**
The detailed bottom line burden hours and cos t 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 costs are $ 847,257 . Details regarding these estimates may be found in Table 1. Annual Respon dent Burden and Cost: NESHAP for Primary C opper Smelters (40 CFR Part 63, Subpart QQQ). F urthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 196 hours per response.
The total annual capital/startup and O&M costs to the regulated entity are $8,220. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 55 labor hours at a cost of $ 2,488 . See Table 2 : Annual Agency Burden and Cost: NESHAP for Primary Copper Smelters (40 CFR Part 63, Subpart QQQ) (Renewal)

. **6(f) Reasons for Change in Burden** There is no change in the labor hours in this I CR as compared to the previous I CR. Th is situation is due to two considerations: 1) the regulatio ns have not changed over the past three ye ars and are not anticipated to change over the next three years; and 2) the growth rate for the industry is very low, negative, or non - existent, so there is no significant change in the overall burden. There is, h owever, an increase in the estimated burden cost as currentl y identified in the OMB Inventory of approved Burdens. The increase is not due to any program changes. The change in burden cost i s due to the use of the most updated labor rates.12

**6(g) Burde n Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 196 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s 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 O MB Control Number. The OMB Control Numbers for EPA ’ s 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 s uggested methods for minimiz ing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0 205

. 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 content of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search” than 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 In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., 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 Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 1927

. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0 205 and OMB Control Number 2060

- 0476 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.**Table 1:**  **A nnual**  **Respondent Burden**  **and Cost** 

**– NESHAP**  **for Primary**  **Copper Smelters**  **(40 CFR**  **Part 63,**  **Subpart QQQ)** 

**(Renewal)**

**Burden item (A)**  **Person hours per**  **occu rrence**  **(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)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

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

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

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions 16 1 16 0 0 0 0 $0 B. Required activities Conduct control device p erformance test c 120 4.5 540 3 1,620 81 162 $ 175,935.24 Conduct converter building performance test d 240 1 240 3 720 36 72 $ 78,193.44 C. Create information See 3B & 4E D. Gather existing information See 3B & 4E E. Write Report Initial notification 8 1 8 3 24 1.2 2.4 $ 2,606.44 Notification of performance test 2 5.5 11 3 33 1.65 3.3 $ 3,583.87 Initial compliance determination 40 1 40 3 120 6 12 $ 13,032.24 Performance test reports e 80 5.5 440 3 1,320 66 132 $ 143,354.64 Summary report f 40 2 80 3 240 12 24 $ 26,064.48 Subtotal for Reporting Requirements **4,688.55** 4. Recordkeeping requirements A. Read instructions 40 1 40 0 0 0 0 $0 B. Plan activities 100 1 100 0 0 0 0 $0 C. Implement Activities i. Prepare startup, shutdown, malfunction plan 80 1 80 0 0 0 0 $0 ii. Copper concentrate dryer Monitor control device parameters g 0.5 365 182.5 3 547.5 0 0 $ 53,304.90 iii. Smelting vessel Inspect tapping hood system h 4 12 48 3 144 0 0 $ 14,080.32 Monitor control device parameters g 0.5 365 182.5 3 547.5 0 0 $ 53,404.90 iv. Slag cleaning vess el Inspect tapping hood system i 4 12 48 1 48 0 0 $ 4,693.4414

**Burden item (A)**  **Person hours per**  **occu rrence**  **(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)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

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

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

Monitor control device parameters i, g 0.5 365 182.5 1 182.5 0 0 $ 17,844.85 v. Batch copper converters Inspect converter hood syste m 4 12 48 3 144 0 0 $ 14,080.32 Monitor hood system ventilation parameters g 0.5 365 182.5 3 547.5 0 0 $ 53,404.90 Monitor control device parameters g 0.5 365 182.5 3 547.5 0 0 $ 53,404.90 vi. Prepare fugitive dust control pl an 100 1 100 0 0 0 0 $0 D. Develop record system 100 1 100 0 0 0 0 $0 E. Time to enter information j 1 365 365 3 1,095 0 0 $ 107,069.10 F. Time to train personnel k 100 1 100 3 300 15 30 $ 32,580.60 Subtotal for Recordkeeping Requirements **4,148.5** Subtotals Labor Burden and Cost 8,180.5 218.85 437.7 $ 847,257.18 **TOTAL LABOR BURDEN AND COST (rounded)**  8,837.05 8,837 (rounded) $ 847,257

**Assu mptions:**  a We have assumed that there are approximately three sources that are su bject to the standard, with no new additional sources expected over the next three years. b This ICR uses the following labor rates: $ 118.92 per hour for Executive, Administrative, and Managerial labor; $97.78 per ho ur for Technical labor, and $48.76 p er hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December , 2010, Table 2. Civilian Workers, by Occupational and Industry group. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. c We have assumed that eac h of the three respondents will take 120 hours, 4.5 times per year to conduct the control device performance test

. d We have assumed that each of the three respondents will take 240 hours to conduct conv erter building performance test once per year. e We have assumed that each respondents will take eighty hours , 5.5 times per year to complete a performance tes t report. f We have assumed that it will take each respondent forty hours to w rite summary report two times per year. g Recordkeeping requirements are required daily on all monitor control device parameters. h We have assumed that inspections on all tap ping hood systems are done on a monthly basis

. i We have assumed that one of the three existing sources will be equipped with a slag cleaning vessel. j Each respondent is required to record information on a daily basis. k We have assumed that it will take each of the respondent 100 hours to train personnel once a year.15

**Table 2: Average Annual EPA Burden**
**- NESHAP for Primary Copper Smelters**  **(40 CFR Part 63, Subpart QQQ) (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)** 

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

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

**Cost, $ b** 

Activity Revie w reports a. Report of no deviations 4 1 4 0 0 0 0 $0 b. Report of deviations 4 1 4 0 0 0 0 $0 c. Report of SSM 8 1 8 0 0 0 0 $0 d. Reports of equipment leaks 8 1 8 0 0 0 0 $0 e. Report on wastewater c 8 2 16 3 48 2 .4 4.8 $2, 487.68 Subtotals Labor Burden and cost 48 2.4 4.8 $2, 487.68 **TOTAL ANNUAL BURDEN AND COST (rounded)**  55.2 55 (rounded) $2, 488

**Assu mptions:**  a We have assumed that there are approximately three sources that are subject to the s tandard, with no new additional sourc es expected over the next three years. b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial rate ( GS

- 13, Step 5, $38.92 x 1.6), $46.21 Technical rate (GS

- 12, Step 1, $28.88 x 1.6), and $25.01 Clerical rate (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 It is assumed that all of the three respondents will each take 8 hours to review reports on wastewater o n a semiannual basis.