SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 

63, Subpart ZZZZZZ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, 

Subpart ZZZZZZ) (Renewal), EPA ICR Number 2332.04, OMB Control Number 2060-0630.

1(b) Short Characterization/Abstract

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

Aluminum, Copper and Other Non-ferrous Metals Foundries were proposed on February 9, 

2009, promulgated on June 25, 2009, and revised on September 10, 2009. These regulations 

apply to existing and new facilities conducting melting operations located at an aluminum, 

copper, or other non-ferrous foundry that is an area source of hazardous air pollutants (HAP) 

emissions, melts 600 tons per year (tpy) of aluminum, copper, or other non-ferrous metal or 

greater, and uses material that contains or has the potential to emit HAP for which the source 

category was listed. New facilities include those that commenced construction, modification or 

reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR Part 63, Subpart ZZZZZZ.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

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

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

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

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

The “Affected Public” is private sector businesses that operate aluminum, copper and 

other non-ferrous metals foundries. The burden to the “Affected Public” may be found below in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Aluminum, Copper and Other 

Non-ferrous Metals Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal). The burden to the 

“Federal Government” is attributed entirely to work performed by either federal employees or 

government contractors; this burden is found below in Table 2: Average Annual EPA Burden 

and Cost – NESHAP for Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR 

Part 63, Subpart ZZZZZZ) (Renewal).
2

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

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

owner/operator of the plant site).

Over the next three years, approximately 318 respondents per year will be subject to the 

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

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

without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

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

of this Act to: 

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

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

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

accordance with such procedures or methods, at such locations, at 

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from aluminum, copper and other nonferrous metal foundries either cause or contribute to air pollution that may reasonably be 

anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for 

this source category at 40 CFR Part 63, Subpart ZZZZZZ.

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. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
3

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

capability to comply with the emission standard. Continuous emission monitors are used to 

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

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

determine compliance in place of a continuous emission monitor.

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

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

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

installed and operated and leaks are being detected and repaired and the standard are being met.

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart 

ZZZZZZ.

3(a) Nonduplication

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, 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 ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. 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 Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts. Approximately 318 respondents will be subject to 
4

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 and the standard 

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

purposes. In developing this ICR, we contacted: 1) the American Foundry Society, at (800) 537-

4237; and 2) the Non-Ferrous Founders’ Society, at (847) 299-0950.

We received comments from the Non-Ferrous Founders’ Society (NFFS). The trade 

organization indicated that several facilities have closed in the past few years, but did not provide 

a quantitative estimate on number of closures. In addition, the NFFS indicates that several 

facilities may not be properly identified within the NAICS codes designated for aluminum, 

copper and other non-ferrous metals foundries. The organization suggest that many companies 

producing nonferrous metal castings are not properly categorized within these codes and some 

facilities included in the codes may not in fact be non-ferrous foundries. The NFFS indicates that 

the error in facility classification within the NAICS codes may have led to a difference in the 

actual number of affected facilities as compared to the estimated number of affected facilities in 

this ICR. The organization states that a change in the number of affected facility would have 

greater impacts on industry burden than the increased labor rates and required time cited in this 

ICR. To remedy this issue, the NFFS has offered to review the list of facilities under the relevant 

NAICS codes to ensure their accuracy if desired by the Agency. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. (In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of a 
5

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 (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 owners and 

operators of aluminum, copper and other non-ferrous metals foundries. The United States 

Standard Industrial Classification (SIC) codes for the respondents affected by the standards, and 

the corresponding North American Industry Classification System (NAICS) codes, are listed 

below.

Standard (40 CFR Part 63, Subpart ZZZZZZ) SIC Codes NAICS Codes

Aluminum Foundries Except Die Casting 3365 331524

Copper Foundries Except Die Casting 3366 331529

Other Nonferrous Foundries Except Die Casting 3369 331528

4(b) Information Requested

(i) Data Items

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

Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart 

ZZZZZZ).

A source must make the following reports:

Notifications
6

Notifications

Notification of applicability 63.11550(a) 

Notification of performance tests 63.11555

Notification of compliance status 63.11553(b)

Performance test for copper foundries and other non-ferrous foundries of 

600 tpy or greater of metal melt production 63.11551(a)

Periodic observations of fabric filter exhausts for existing melting 

operations subject to the PM limit 63.11552(b)

BLDS for fabric filters for new melting operations subject to a PM limit 63.11552(c)

Reports

Management practices plan for aluminum, copper, and other non-ferrous 

foundries 63.11550(a)

Startup, shutdown, and malfunction plan/reports 63.11555

Performance test plan 63.11555

Compliance report if deviation occurs 63.11553(e)

A source must keep the following records:

Recordkeeping

Records to document compliance with management practices plan 63.11552(a), 

63.11553(c)(2)

Records to support notifications 63.11553(c)(1)

Records of monitoring data 63.11553(c)(3)

Records of metal melt production for copper and non-ferrous foundries 

less than 600 tpy 63.11553(c)(4)

Records of bag leak detection system 63.1553(c)(5)

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.

(ii) Respondent Activities
7

Respondent Activities

Familiarization with the regulatory requirements.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B, 

4, 5, 5D, and 17 tests, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

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

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 Enforcement and Compliance History Online (ECHO) 

and ICIS. 

5(b) Collection Methodology and Management

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

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

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

emission standard. Data and records maintained by the respondents are tabulated and published 
8

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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

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

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

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

The majority of the respondents are small entities (i.e., small businesses). A small entity

for this industry is defined by the Small Business Administration as a firm having no more than 

500 employees; therefore, 98 percent of the aluminum foundries, 100 percent of the copper 

foundries, and 100 percent of the other non-ferrous foundries are small entities. The standard 

excludes two thirds (648) of the 966 foundries from regulation. Only the largest copper and other 

non-ferrous foundries (23 total) are subject to emission standards; approximately 318 foundries 

are required to comply with management practices. Of the 318 foundries that are subject to the 

rule, approximately 307 (97 percent) are small entities. The standard provides the maximum 

degree of operational flexibility for small entities. The Agency considers these to be the 

minimum requirements needed to ensure compliance and, therefore, cannot reduce them further 

for small entities. Our analyses show that the standard will not result in a significant economic 

impact on a substantial number of small entities because the only new requirements will be 

compliance provisions. The total annual cost for each of the affected small entities is less than 

0.05 percent of company sales revenues.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Aluminum, 

Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.
9

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 11,900 (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 ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

The only type of industry costs associated with the information collection activity in the 

regulations is labor cost. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 
10

$13,300.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

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

Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart 

ZZZZZZ) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

318 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 318 per year. 

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

years covered by this ICR.

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

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 0 318 0 0 318

2 0 318 0 0 318

3 0 318 0 0 318

Average 0 318 0 0 318

1

New respondents include sources with constructed, reconstructed and modified affected facilities. In this standard 

existing respondents submit initial notifications.

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 318.
11

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

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

Notification of applicability 0 1 0 0

Notification of compliance status 0 1 0 0

Notification of performance test 0 1 0 0

Site specific test plan 0 1 0 0

Management practices plan 0 1 0 0

Startup, shutdown, and malfunction plan/reports 0 1 0 0

Semiannual compliance reports 31.8 2 0 63.6

Total 64

The number of Total Annual Responses is 64 (rounded).

The total annual labor costs are $1,200,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Aluminum, 

Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 11,900 at a cost of $1,200,000. Details regarding these 

estimates may be found in Table 1. Annual Respondent Burden and Cost – Table 1: Annual 

Respondent Burden and Cost - NESHAP for Aluminum, Copper and Other Non-ferrous Metals 

Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 
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information is estimated to average 186 hours per response.

There are no annual capital/startup and O&M costs to the regulated entity.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 293 

labor hours at a cost of $13,300. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Aluminum, Copper and Other Non-ferrous Metals Foundries (40 CFR Part 63, Subpart 

ZZZZZZ) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in the respondent labor hours in this ICR compared to the previous 

ICR. This is due to assuming all sources will have to re-familiarize with regulatory requirements

each year. This also results in an increase in labor costs for the respondents. In addition, there is 

an increase in labor costs for both the respondents and the Agency due to an increase in labor 

rates. This ICR uses updated labor rates from the Bureau of Labor Statistics to calculate burden 

costs.

6(g) Burden Statement

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

is estimated to average 186 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 
13

Docket ID Number EPA-HQ-OECA-2011-0526. 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) 566-1927. 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-2011-0526 and OMB Control Number 2060-0630 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Aluminum, Copper and Other Non-ferrous Metals

Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal)

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent

(C) 

Personhours per 

respondent 

(C=A*B)

(D) 

Respondents 

per year b

(E) 

Technical 

personhours per 

year 

(E=C*D)

(F) 

Management 

person-hours 

per year 

(F=E*0.05)

(G) 

Clerical 

personhours per 

year 

(G=E*0.1)

(H) 

Costa, $

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and 

Utilization of Technology and Systems N/A

4. Reporting Requirements

A. Familiarize with Regulatory 

Requirements 4 1 4 318 1,272 63.6 127.2 $146,719.48

B. Required activities 

 Prepare management practices plan 4 1 4 0 0 0 0 $0 

 Initial performance tests 40 1 40 0 0 0 0 $0 

 Daily VE (30 days) then weekly VE c, d 0.1 78 7.8 23 179.4 8.97 17.94 $20,692.98 

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

 Initial notification of applicability 4 1 4 0 0 0 0 $0 

 Notification of compliance status 4 1 4 0 0 0 0 $0 

 Notification of 

construction/reconstruction N/A

 Notification of anticipated startup N/A

 Notification of actual startup N/A

 Notification of special compliance 

requirements N/A

 Request for compliance extension N/A
15

 Notification of performance test 1 1 1 0 0 0 0 $0 

 Site specific test plan 4 1 4 0 0 0 0 $0 

 Notification of performance evaluation N/A

 Quality assurance plan for 

CEMS/COMS N/A

 NESHAP waiver request N/A

 Startup, shutdown, and malfunction 

plan/reports 4 1 4 0 0 0 0 $0 

 Semiannual compliance reports e8 2 16 31.8 508.8 25.44 50.88 $58,687.79 

Subtotal for Reporting Requirements 2,254 $226,100

5. Recordkeeping Requirements 

A. Familiarize with Regulatory 

Requirements See 4A

B. Plan activities See 4A

C. Implement activities See 4A

D Develop record system 4 1 4 0 0 0 0 $0 

E. Time to enter information 0.5 52 26 318 8,268 413.4 826.8 $953,676.59 

F. Time to transmit or disclose 

information 0.25 2 0.5 318 159 7.95 15.9 $18,339.93 

G. Time to adjust existing ways 2 1 2 0 0 0 0 $0 

F. Time to train personnel 4 1 4 0 0 0 0 $0 

G. Time for audits N/A

Subtotal for Recordkeeping 

Requirements 9,691 $972,017 

TOTAL LABOR BURDEN AND COST 

(rounded f)

11,900 $1,200,000 

Capital and O&M Costs f

$0

Grand TOTAL f

$1,200,000 

Assumptions:

a This ICR uses the following labor rates: $123.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for 

Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by Occupational and Industry 

group.” The rates are from “column 1, Total Compensation. “ The rates have been increased by 110% to account for the benefit packages available to those employed by private 

industry.

b We have assumed that 318 foundries will be subject to the rule and will perform these activities over the 3-year term of the ICR.
16

c We have assumed that all of the 23 foundries subject to the PM emission limit must perform the visible emissions observations over the 3-year term of the ICR.

d This activity is based on daily VE for 30 days and weekly thereafter (30 + 335/7 = 78).

e

Semiannual compliance reports are required when deviations occur. We estimate that 10 percent of the foundries will experience deviations.

f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Aluminum, Copper and Other Non-ferrous Metals

Foundries (40 CFR Part 63, Subpart ZZZZZZ) (Renewal)

Burden Item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent

(C)

Plants 

per year

(D) 

Technical 

personhours per 

year 

(D=A*B*C)

(E) 

Management 

personhours per 

year 

(F=E*0.05)

(F) 

Clerical 

personhours per 

year 

(G=E*0.1)

(G) 

Costa, $

Report Review:

Initial notification of applicability 1 1 0 0 0 0 $0 

Startup, shutdown, malfunction 

plan/report 2 1 0 0 0 0 $0 

Notification of compliance status 2 1 0 0 0 0 $0 

Semiannual excess emissions report b4 2 31.8 254.4 12.72 25.44 $13,315.3 

TOTAL BURDEN AND COST 

(rounded c)

293 $13,300 

Assumptions:

a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.90 

(GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 x 1.6). These rates are from the Office of 

Personnel Management (OPM) 2014 General Schedule which excludes locality rates of pay.

b

Semiannual compliance reports are required when deviations occur. We estimate that 10 percent of the foundries will experience deviations.

c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.