SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 

61, Subpart N) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, 

Subpart N) (Renewal), EPA ICR Number1081.11, OMB Control Number 2060-0043.

1(b) Short Characterization/Abstract

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

Arsenic Emissions from Glass Manufacturing Plants were proposed on July 20, 1983, and 

promulgated on August 4, 1986. The standards were amended on October 3, 1986, May 31, 

1990, February 12, 1999, October 17, 2000, and February 27, 2014. The most recent amendment 

revises the test methods and procedures, and does not change the reporting and recordkeeping 

requirements. These regulations apply to each glass melting furnace that uses commercial 

arsenic as a raw material. These standards do not apply to pot furnaces. Also, re-bricking is not 

considered construction or modification for the purposes of 40 CFR Section 61.05(a). 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 61, Subpart N.

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 two years following the date of such measurements, 

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

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

States Environmental Protection Agency (EPA) regional office.

 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, an average of 16 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 
2

without any “Terms of Clearance.” 

The affected entities are owners and operators of glass manufacturing plants, all of which 

are owned by private, for-profit businesses. The burden to the “Affected Public” may be found 

in Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic Emissions 

from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal). The “Federal 

Government” burden is attributed entirely to work performed by federal employees or 

government contractors and may be found in Table 2: Average Annual EPA Burden and Cost –

NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, 

Subpart N) (Renewal). 

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, arsenic emissions from glass manufacturing plants 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 61,

Subpart N.

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, leaks are being detected and repaired, and the standard is 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 61, Subpart 

N.

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 (79 FR 30117) on May 27, 2014. 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 Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.
4

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 developing 

this ICR, we contacted both the Glass Manufacturing Industry Council at (614) 818-9423, and 

the National Glass Association at (866) 342-5642.

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.

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.

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 glass manufacturing 

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

affected by the standards and the corresponding North American Industry Classification System 

(NAICS) code are listed below.
5

Standard (40 CFR Part 61, Subpart N) SIC Codes NAICS Codes

Flat Glass Manufacturing 3211 327211

Glass Container Manufacturing 3221 327213

Other Pressed and Blown Glass and 

Glassware Manufacturing 3229 327212

Mineral Wool Manufacturing 3296 327993

4(b) Information Requested

(i) Data Items

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

Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N). 

A source must make the following reports:

Notifications

Notification and application of construction or modification 61.06, 61.07

Notification of anticipated date of initial startup 61.09(a)(1)

Notification of actual startup 61.09(a)(2)

Notification of initial performance emissions test 60.13(c), 

61.165(d)(2)

Reports

Source status report 61.10(a)

Report initial performance emissions test results 61.13(f), 

61.165(d)(2)

Report of arsenic emission estimates 61.165(d)(3)

Report of uncontrolled arsenic emission rates 61.165(d)(4)

Request approval of control device bypass 61.165(e)
6

Reports

Report of results of continuous monitoring system (CMS) evaluation 61.165(f)(1)

Semiannual report of excess emissions (opacity) 61.165(f)(2)

A source must keep the following records:

Recordkeeping

Record continuous opacity and temperature of gas entering control 

device

61.165(a)(1)

Records of emission test results and other data needed to determine 

emissions

61.13(g), 

61.165(a)(2)

Records of CMS performance evaluations 61.165(a)(3)

Occurrence and duration of startup, shutdown, and malfunction of 

furnace

61.165(a)(4)

Malfunction of air pollution control device 61.5165(a)(5)

Periods when monitors are inoperative 61.165(a)(6)

Maintenance and repair of control device, CMS or monitor 61.165(a)(7)

Records of approved control device bypass 61.165(b)

Semiannual records of uncontrolled arsenic emission rate 61.165(c)

Records are required to be retained for two (2) years 61.14(f), 61.165(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. 
7

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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

supply pressure for wet scrubber.

Perform initial performance test, Reference Method 1, 2, 3, 5D, and 108 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.
8

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 Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management

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

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

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

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

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

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

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

determinations.

Information contained in the reports is 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 two

years.

5(c) Small Entity Flexibility

A 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 

development of the regulation. The number of small entities affected by this rule could not be 

determined, based on review of the following sources: the promulgated rule notice in the Federal 

Register (51 FR 27956) on August 4, 1986; the Inorganic Arsenic Emissions from Glass 

Manufacturing Plants Background Information for Proposed Standards (1983); and a search of 

publicly available current data sources. Based on the Background Information document, about 

70 percent of glass plants are considered to be small firms; however, arsenic usage by these 

small firms is not known.

Due to technical considerations involving the process operations and the types of control 

equipment employed, the recordkeeping and reporting requirements are the same for both small 
9

and large entities. The Agency considers these to be the minimum requirements needed to 

ensure compliance and, therefore, cannot reduce them further for small entities. To the extent 

that larger businesses can use economies of scale to reduce their burden, the overall burden will 

be reduced.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic 

Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (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.

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 3,080 (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.
10

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

The type of industry costs associated with the information collection 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) 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)

Continuous 

Opacity Monitor N/A N/A $0 $3,000 16 $48,000

Temperature 

Monitor N/A N/A $0 $500 16 $8,000

Totals $0 $56,000

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $56,000. 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 $56,000. 

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 

$10,000. 

This cost is based on the average hourly labor rate as follows:
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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), 2015 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 Inorganic 

Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N).

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

16 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 16 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 16 0 0 16

2 0 16 0 0 16

3 0 16 0 0 16

Average 0 16 0 0 16

1

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 16. 

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

Total Annual Responses
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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

Application of construction or modification 0 0 N/A 0

Notification of anticipated startup 0 0 N/A 0

Notification of actual startup 0 0 N/A 0

Source status report 0 0 N/A 0

Notification of initial performance emission 

test 0 0 N/A 0

Notification of physical or operation change 0 0 N/A 0

Report of arsenic emission estimates 15 2 N/A 30

Report of uncontrolled arsenic emission rates 15 2 N/A 30

Request approval of control device bypass 1 1 N/A 1

Semiannual excess emissions (opacity) 1 2 N/A 2

Total 63

The number of Total Annual Responses is 63. 

The total annual labor costs are $310,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic 

Emissions from Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 3,100. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic Emissions from 

Glass Manufacturing Plants (40 CFR Part 61, Subpart N) (Renewal). 

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

information is estimated to average 49 hours per response.
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The total annual capital/startup and O&M costs to the regulated entity are $56,000. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

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.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 228

labor hours at a cost of $10,000. See Table 2: Average Annual EPA Burden and Cost –

NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants (40 CFR Part 61, 

Subpart N) (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 no change in the respondent burden hours in this ICR compared to the previous 

ICR. However, there is an adjustment increase in the estimated labor costs from using more 

updated labor rates. In addition, there is an adjustment increase in the Agency burden due to a 

correction. The previous ICR underestimated the number of uncontrolled arsenic emission rate 

reports reviewed by the Agency. These reports are submitted by 15 of the 16 subject sources. 

This ICR assumes the Agency reviews reports submitted by all 15 sources. 

6(g) Burden Statement

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

is estimated to average 49 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 
14

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2014-0038. 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-2014-0038 and OMB Control Number 2060-0043 in any

correspondence. 

Part B of the Supporting Statement

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

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants 

(40 CFR Part 61, Subpart N) (Renewal)

Burden item

(A)

Technical 

Person-hours 

per 

occurrence

(B)

No. of 

occurrences 

per respondent 

per year

(C)

Technical 

Person-hours 

per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 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 c

1 1 1 0 0 0 0 $0

 B. Required Activities N/A

Initial performance emission tests d

80 1 80 0 0 0 0 $0

Repeat of performance emission tests 80 0.2 16 0 0 0 0 $0

 C. Create information See 3B

 D. Gather existing information See 3B

 E. Write report

Application of construction or modification 2 1 2 0 0 0 0 $0

Notification of anticipated startup 2 1 2 0 0 0 0 $0

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

Source status report 2 1 2 0 0 0 0 $0

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

Report of initial performance emission test See 3B

Notification of physical or operation change 2 1 2 0 0 0 0 $0

Report results of continuous monitoring system 

(CMS) evaluation See 3B

Report of arsenic emission estimates e

16 2 32 15 480 24 48 $55,509.84
16

Report of uncontrolled arsenic emission rates f  8 2 16 15 240 12 24 $27,754.92

Request approval of control device bypass g

6 1 6 1 6 0.3 0.6 $693.87

Semiannual excess emissions (opacity) h

16 2 32 1 32 1.6 3.2 $3,700.66

Subtotal for Reporting Requirements 872 $87,659.29

4. Recordkeeping Requirements

 A. Read instructions See 3A

 B. Plan activities See 3B

 C. Implement activities See 3B

 D. Develop record system N/A

 E. Time to enter information i 40 1 40 16 640 32 64 $74,013.12

 Record continuous opacity See 4E

 and temperature of gas

 entering control device 

Records of emission test results See 4E

Records of CMS performance evaluations See 4E

Occurrence and duration of startup, shutdown, and 

malfunction of furnace See 4E

Records of malfunction of control device See 4E

Periods when monitors are inoperative See 4E

Maintain and repair of control device, CMS, or 

monitors See 4E

Records of approved control device bypass See 4E

Semiannual records of uncontrolled arsenic emission 

rate j 40 2 80 16 1,280 64 128 $148,026.24

 F. Time to train personnel N/A

 G. Time for audits N/A

Subtotal for Recordkeeping Requirements 2,208 $222,039.36

TOTAL LABOR BURDEN AND COST 3,079.7 $309,698.65

(rounded) 3,080 $309,699
17

Capital and O&M Cost (see Section 6(b)(iii)): $56,000

TOTAL COST: $365,699

Assumptions:

a

 We have assumed that there are sixteen existing sources, and that no additional new sources will become subject to the rule over the next three years.

b

 This ICR uses the following labor rates: $129.93 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, 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% to account for the benefit packages 

available to those employed by private industry.

c

 We have assumed that it will take one hour to read instructions.

d

 We have assumed that it will take eighty hours to complete performance test.

e

 We have assumed that fifteen respondents will write report of arsenic emission estimates on a semiannual basis.

f

 We have assumed that fifteen respondents will write report of uncontrolled arsenic emission rates on a semiannual basis.

g

 We have assumed that one respondent will write report requesting approval of control device bypass once a year.

h

 We have assumed that one respondent will write an excess emissions report semiannually.

i

 It will take each respondent forty hours to enter information.

j

 It will take each respondent forty hours twice a year to record uncontrolled arsenic emission rate.

NOTE: Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Glass Manufacturing Plants 

(40 CFR Part 61, Subpart N) (Renewal)

Burden Item

(A) (B) (C) (D) (E) (F) (G) (H)

Technical 

Personhours per 

occurrence

No. of 

occurrences 

per year

Technical 

Personhours per 

Plant per 

year

Respondents 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year 

(Ex0.1)

Total Cost per 

year b

(C=AxB) (E=CxD) (Ex0.05)

Initial performance test

 New facility c

24 1 24 0 0 0 0 $0 

Repeat performance test

 New facility d

24 0.2 4.8 0 0 0 0 $0 

Review reports 

 New facility

Construction or modification application 0.5 1 0.5 0 0 0 0 $0 

Notification of anticipated startup 0.5 1 0.5 0 0 0 0 $0 

Notification of actual startup 0.5 1 0.5 0 0 0 0 $0 

Source status report 0.5 1 0.5 0 0 0 0 $0 

Notification of initial performance emissions test 0.5 1 0.5 0 0 0 0 $0 

Report of initial performance emissions test results 8 1 8 0 0 0 0 $0 

Notification of physical or operational change 0.5 1 0.5 0 0 0 0 $0 

Notification of emissions test 0.5 1 0.5 0 0 0 0 $0 

Report results of CMS evaluation 8 1 8 0 0 0 0 $0 

 Existing facility

Report of arsenic emission estimates rates e

4 1 4 15 60 3 6 $3,140.40 

Reports of uncontrolled arsenic emission rates f

8 1 8 15 120 6 12 $6,280.80
19

Burden Item

(A) (B) (C) (D) (E) (F) (G) (H)

Technical 

Personhours per 

occurrence

No. of 

occurrences 

per year

Technical 

Personhours per 

Plant per 

year

Respondents 

per year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year 

(Ex0.1)

Total Cost per 

year b

(C=AxB) (E=CxD) (Ex0.05)

Semiannual excess emissions g

6 2 12 1 12 0.6 1.2 $628.08 

Request approval of control device bypass h

6 1 6 1 6 0.3 0.6 $314.04 

TOTAL LABOR BURDEN AND COST 

(rounded) 228 $10,363

Assumptions:

a

 We have assumed that there are sixteen existing sources, and that no additional new sources will become subject to the rule over the next three years.

b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 (GS-13, Step 5, 

$39.31 + 60%) for managerial, $46.67 (GS-12, Step 1, $29.17 + 60%) for Technical, and $25.25 (GS-6, Step 3, $15.78 + 60%) for Clerical. These rates are from the 

Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.

c

 We have assumed that it will take twenty four hours to perform initial performance test.

d

 We have assumed that it will take twenty four hours to repeat performance test.

e

 We have assumed that reports submitted by the fifteen respondents will be reviewed once a year. These reports are submitted semiannually. 

f 

 We have assumed that it will take eight hours to review reports of uncontrolled arsenic emission rates once a year. These reports are submitted semiannually. 

g

 It is required that excess emissions reports are reviewed on a semiannual basis.

h

 We have assumed that the report requesting approval of control device bypass will be reviewed once a year.