SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT ) (Renewal )

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT ) (Renewal),

EPA ICR Number 2098.07 , OMB Control Number 2060

- 0536

.

1(b) Short Characterization/Abstract

The National Emission Standards for Ha zardous Air Pollutants (NESHAP) for Primary

Magnesium Refining ( 40 CFR Part 63, Subpart TTTTT ) were proposed on January 22, 2003

, promulgated on October 10, 2003, and amended on April 20, 2006

. These regulations apply to

existing facilities and new facilities that perform primary magnesium r efining where the total

hazardous air pollutants (HAPs) emitted are greater than, or equal to, 10 tons per year for each

HAP, or where the total HAPs emitted are greater than, or equal to, 25 tons per year of any

combination of HAPs. New facilities include those that commenced construction or

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

compliance with 40 CFR Part 63

, Subpart TTTTT

.

In general, all NESHAP standards require initial notification report s, performanc e 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 dur ing 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 sh all maintain a file containing

these documents , and retain the file for at least five years following the generation date of such

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

In the event that there i s no such delegated authority, the reports are sent directly to the U

. S

. Environmental Protection Agency (EPA) regional office.

The Affected Public is a single primary magnesium refining facility that is a privately

owned, for

- profit business. The “ burden ” to the Affected Public may be found below in Table 1:

Annual Respondent Burden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part

63, Subpart TTTTT) (Renewal)

. The “ burden ” to the Federal Governmen t is attributed entirely to

work performed by either F ederal employees or government contractors

, and may be found

below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Primary Magnesium

Refining (40 CFR Part 63, Subpart TTTTT) (Renewal).

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

affected facility at each plant site and that each plant site has only one respondent (i.e ., the2

owner/operator of the plant site).

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

the se standard s , and no additional respondents per year will become subject to the se same

standard s

.

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 stand ards 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 th is 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 impractic al; (F) submit

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

and (G) provide such other information as the Admini strator may

reasonably require.

In the Administrator's judgment, HAP emissions from primary magnesium refining either

cause or contribute to air pollution that may reasonably be anticipated to endanger public health

and/ or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR

Part 63, Subpart TTTTT

.

2(b) Practical Utility/Users of the Data

The rec ordkeeping and reporting requirements in the se standard s 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.

Performance tests are required in order to determine an affected facility ’ s initial3

capability to com ply with the emission standard s . Continuous emission monitors are used to

ensure compliance with the se standard s at all times. During t he 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 notificat ions required in the se standard s are used to inform the A gency 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 a nd repaired

, and the standard s 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. Non

- duplication, Consultations, and Other Collection Criteria

The requested recordkeeping an d reporting are required under 40 CFR Part 63

, Subpart

TTTTT

.

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 s imilar 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 N otice 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 Regi ster

.

3(c) Consultations

The Agency has consulted i ndustry 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 se standard s

, 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

- ow ned facilities. The growth rate for the industry is based on our consultations

with the Agency’s internal industry experts. Only a single respondent will be subject to the se4

standards over the three

- year period covered by this ICR.

I ndustry trade associat ion(s) and other interested parties were provided an opportunity to

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

standard s ha ve been reviewed previously to determine the minimum information needed for

compliance purposes. In developing this ICR, we contacted our internal industry experts in EPA

OAQPS , and the US Magnesium LLC

, at (801) 532

- 2043

.

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

ICR renewal as well as those su bmitted in response to the f irst Federal Register n otice. 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

coll ected less

- frequently, the proper operation and maintenance of control equipment and the

possibility of detecting violations would be less likely.

3(e) General Guidelines

T hese 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 Prov isions 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. T he retention of records for five years allow s 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 ad dition, 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 accordin g 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).5

3(g) Sensitive Questions

T he 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 primary magnesium

refiners

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

affected by the standards is SIC 3339

, which corresponds to the North Americ an Industry

Classification System (NAICS ) code 331410 for Primary Smelting and Refining of Nonferrous

Metal (except copper and aluminum)

.

4(b) Information Requested

(i) Data Items

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

Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT)

.

A source must make the following reports:

Notification s

Initial notification 63.9930(a), 63.9(b)

Notification of compliance status 63.9930(a), 63.9(h)

Notification of construction or reconstruction 63.9930(a), 63.5(b)(4),

63.9(b)(5)

Notification of actual startup 63.9930(a), 63.9(b)(4)(v),

63.9(b)(5)(ii)

Notification of performance test 63.9930(a), 63.7(b),

63.8(e), 63.9(e)

Reports

Semiannual report 63.9931(a), (b)

Report of performance test 63.9930(e)

Startup, shutdown, malfunction report 63.9931(c), 63.10(d)(5)

A source must keep the following records:6

Recordkeeping

Five year retention of records 63.9933(b), 63.10(b)

Copies of notifications and reports 63.9932(a)(1)

Startup, shutdown, and malfunction plan/records 63.9932(a)(2), 63.6(e) (iii

v)

Documentation of performance tests and opacity observations 63.9932(a)(3),

63.10(b) (2)(viii)

Records required to demonstrate continuous compliance 63.9932(b)

Electronic Reporting

Some of the r espondents 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 assoc iated with monitoring and recordkeeping at

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop or liquid flow

rate for wet scrubber.

Perform initial performance test, Reference Method 1, 2, 2F, 2G, 3, 3A, 3B, 4, 5, 5D, 18, 23,

25D, 26, 26A, 201, 201A, 301, 303, 303A, 304, 304A, 304B, 305, 306, 306A, 306B, 307, 308,

310A, 310B, 310C, 311, 312A, 312B, 312C, 3 13A, 313B, 315, 316, 318, 319, 320, or 321 test,

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, acq uire, 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.7

Respondent Activities

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

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, excess emissions reports,

startup, shutdown, malfunction plan, and quality control plan for CMS 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 properl y installed and operated. Performance

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

emission standard s

. 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 op eration 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. IC IS is

EPA ’ s database fo r 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 headqua rters.

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.8

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

years.

5(c) Small Entity Flexibility

The majority of respondents are large businesses. However, the impact on small entities

(i.e., small businesses) was taken into consideration during the development of the regulation.

D ue 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 o verall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Primary

Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewa l).

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, specif ic 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 vali d OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping

and reporting requirement s is estimated to be 611 ( Total Labor Hours from Table 1 below ).

T hese hours are based on Agency studies and background documen ts from the development of

the regulation s , 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:9

Managerial $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 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 type of industry costs associated with the information collection act ivities in the

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

associat ed 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

ongoin g costs to maintain the monitor and other costs su ch as photocopying and postage.

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

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

(A)

Continuous

Monitoring

Device (B)

Capital/Startup

Cost for One

Respondent (C)

Number of

New

Respondents (D)

Total

Capital/Startup

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)

CEM $16,000 0 $0 $1,200 1 $1,200

Total $0 Total $1,200

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

The total capital/startup costs for this ICR is $ 0

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 1,200

. 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 $ 1,200

. These are recordkeeping

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 i ncludes activities such as the

examination of records maint ained by the respondents, periodic inspection of sources of10

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

$ 8,090.

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

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

, 20 1 4 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 Primary

Magnesium Refining (40 CFR Part 6 3, Subpart TTTTT) (Renewa l).

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

one existing respondent will be subject to the se standard s

. It is estimated that no additional

respondents per year will become subject to these same standards

. The overall average number

of responden ts, as shown in the table below, is one 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 1 0 0 1

2 0 1 0 0 1

3 0 1 0 0 1

Average 0 1 0 0 1

1 New respondents include sources with constructed, reconstructed and modified affected facilities.

C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the11

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

.

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

Initial notification 0 1 0 0

Notification of compliance status 0.33 1 0 0.33

Notification of construction/ reconstruction 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of performance test 0.33 1 .2 0 0. 40

Report of performance test 0.33 1 .2 0 0. 40

Semiannual report 1 2 0 2

Startup, shutdown, malfunction report 1 1 0 1

Total 4 .13

The number of Total Annual Responses is 4 (rounded)

.

The total annual labor costs are $61,500

. Details regarding these estimates may be found

below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Primary Magnesium

Refining (40 CFR Part 63, Subpart TTTTT) (Renewa l).

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 below in Tables 1 and 2

, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 611 hours

. Details regarding these estimates may be

found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Primary

Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewa l)

.

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 of12

information is estimated to average 153 hours per response

.

The total annual capital/startup and O&M costs to the regulated entity are $1,200

. 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 178

labor hours at a cost of $8,090. See below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart TTTTT) (Renewal)

.

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

tasks because th e 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 no change in burden hours in this ICR from the previous ICR because the

regulations has not changed, and are not expected to change, in the next three years. There is

, however, a small adjustment increase in the estimated labor costs as due to an update in labor

rates.

6(g) Burden Statement

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

is estimated to average 153 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 uti lize 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

instructi ons 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, a nd 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 t his ICR under13

Docket ID Number EPA

- HQ

- OECA

- 2012

- 0699

. 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 informat ion, 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 identif ied

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), WJC 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 i s (202) 566

- 17 52

. Also, you can se nd comments to the Office of

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID

Number EPA

- HQ

- OECA

- 2012

- 0699 and OMB Control Numb er 2060

- 0536 in any

correspondence.

Part B of the Supporting Statement

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

information.14

Table 1: Annual Respondent Burden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart

TTTTT) (Renewal)

Burden Item (A)

Person

hours per

occurrence (B)

Number of

occurrences

per year (C)

Person

hours per

respondent

per year

(C=AxB) (D)

Respondents

per year a (E)

Technical

person

hours per

year

(E=CxD) (F)

Management

person hours

per year

(F=Ex0.05) (G)

Clerical

person

hours per

year

(G=Ex0.1) (H)

Annual

costs ($) b

1. Reporting requirements

a. Familiarize with regulatory

requirements 4 1 4 1 4 0.2 0.4 $462.58

b. Process/review information 4 4 16 1 16 0.8 1.6 $1,850.33

c. Write reports

i. Initial notification 2 1 2 0 0 0 0 $0

ii. No tification of compliance

status c 2 1 2 0.33 0.66 0.03 0.07 $76.33

iii. Notification of

construction/reconstruction 2 1 2 0 0 0 0 $0

iv. Notification of actual startup 2 1 2 0 0 0 0 $0

v. Notification of performance test c 2 1.2 2.4 0.33 0.79 0.04 0.08 $91.59

vi. Report of performance test c, d 180 1.2 216 0.33 71.28 3.56 7.13 $8,243.21

vii. Semiannual report e 10 2 20 1 20 1 2 $2,312.91

viii. Startup, shutdown, malfunction

report 4 1 4 1 4 0.2 0.4 $462.58

Subtotal for Reporting Requirements 134 $13,500

2. Recordkeeping requirements

a. Familiarize with regulatory

requirements 4 1 4 1 4 0.2 0.4 $462.58

b. Plan activities 12 1 12 1 12 0.6 1.2 $1,387.75

c. Implement activities 12 1 12 1 12 0.6 1.2 $1,387.7515

d. Time to train personnel 10 1 10 1 10 0.5 1 $1,156.46

e. Time to enter information

- - - - - - - -

f. Store, file, and maintain records f 1 365 365 1 365 18.25 36.5 $42,210.61

g. Retrieve records/reports g 1 12 12 1 12 0.6 1.2 $1,387.75

Subtotal for Recordkeeping

Requirements 477 $47,993

Total Labor Burden and Costs

(rounded) h 611 $61,500

Total Capital and O&M Costs

(rounded) h $1,200

Grand Total (rounded) h $62,700

Assumptions:

a We have assumed that there are approximately one respondents subject to the rule, with no new sources expected over the next three

- years of this ICR.

b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours ar e 10 perc ent of Technical hours.

c We have assumed that performance test will be repeated once in three years.

d We assume that this includes Method 23 test.

e We assumed that it will take respondent ten hours two times per year to complete semiannual report.

f This includes inspection of unpaved areas.

g We assume that it will take 1 hour once per month to retrieve records/reports.

h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.16

Table 2: Average Annual EPA Bu rden and Cost

– NESHAP for Primary Magnesium Refining (40 CFR Part 63, Subpart

TTTTT) (Renewal)

Burden Item (A)

Person

hours per

occurrence (B)

Number of

occurrences

per year (C)

Person

hours per

respondent

per year

(C=AxB) (D)

Respondents

per Year a (E)

Technical

person

hours per

year

(E=CxD) (F)

Management

person hours

per year

(F=Ex0.05) (G)

Clerical

person

hours per

year

(G=Ex0.1) (H)

Annual

costs ($) b

1. Initial performance test c 24 1 24 0.33 7.92 0.40 0.79 $414.53

2. Repeat performance test c 24 0.2 4.8 0.33 1.58 0.08 0.16 $82.91

3. Report review 0 0 0 $0

a) Initial notification 8 1 8 0 0 0 0 $0

b) Notification of performance test c 8 1.2 9.6 0.33 3.17 0.16 0.32 $165.81

c) Notification of compliance status

c 8 1 8 0.33 2.64 0.13 0.26 $138.18

d) Notification of construction/

reconstruction 8 1 8 0 0 0 0 $0

e) Notification of actual startup 8 1 8 0 0 0 0 $0

f) Report of performance test c 8 1.2 9.6 0.33 3.17 0.16 0.32 $165.81

g) Semiannual report d 16 4 64 2 128 6.4 12.8 $6,699.52

h) Startup, shutdown, malfunction

report e 8 1 8 1 8 0.4 0.8 $418.72

Total Annual Burden and Costs

(rounded) f 178 $8,090

Assumption:

a We have assumed that there are approximately one respondents subject to the rule, with no new sources expected over the next three

- years of this ICR.

b This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS

- 12, Step 1, $2 9.17 + 60%); Managerial $62.90 (GS

- 13, Step 5, $39.31 +

60%); and Clerical $25.25 (GS

- 6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10

percent of Technical hours. These rates are from the 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.17

c We have assumed that performance test will be repeated once i n three years.

d We have assumed that it would take 16 hours four times per year to review semiannual report.

e We have assumed that it will take eight hour once per year to review the startup, shutdown, malfunction report.

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