1 SF 83 SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY STANDARDS OF PERFORMANCE OMB Control No. 2060 0110 EPA ICR No. 1604.06 NSPS Smelter Regulations Including:

Subpart M, Secondary Brass and Bronze Production Plants Subpart P, Primary Copper Smelters Subpart Q, Primary Zinc Smelters Subpart R, Primary Lead Smelters Subpart S, Primary Aluminum Reduction Plants Subpart Z, Ferroalloy Production Facilities 1. Identification of the Information Collection 1( a) Title of the Information Collection The title for OMB control number 2060 0110, had been: NSPS for Secondary Brass and Bronze Production Plants. The following table lists the old OMB Control Numbers, EPA ICR Numbers and titles that were consolidated into OMB Control number 1604.01:

Table of Consolidate Prior OMB Control Numbers 2060 0110 1604.01 NSPS for Secondary Brass & Bronze Production Plants ( M) 2060 0030 1068.01 NSPS for Primary Copper, Lead & Zinc Smelter Monitoring 2060 0031 1683.02 NSPS for Primary Aluminum Reduction Plants 2060 0033 1065.02 NSPS Subpart Z: Ferroalloy Production Facilities Its new title is: NSPS Smelter Regulations: Subpart M, Secondary Brass and Bronze Production Plants; Subpart P, Primary Copper Smelters; Subpart Q, Primary Zinc Smelters; Subpart R, Primary Lead Smelters; Subpart S, Aluminum Reduction Plants; and Subpart Z, Ferroalloy Production Facilities. . The consolidated ICRs, with their prior respective OMB control and EPA ICR numbers are:

NSPS Subpart M, Secondary Brass and Bronze Production ( OMB 2060 0110, EPA ICR 1604.5): NSPS Subpart P, Primary Copper Smelters, Subpart Q, Primary Zinc Smelters, and Subpart R, Primary Lead ( OMB 2060 0030, EPA ICR 1068.01); 2 NSPS Subpart S, Primary Aluminum Smelters ( OMB 2060 0031, EPA ICR 1683.02); NSPS Subpart Z, Ferroalloy Production Facilities ( OMB 2060 0033, EPA ICR 1065.02).

SHOWN AS TABLE:

Title Subpart CFR OMB Number EPA Number Smelters M 60.133 2060 0110 1604.05 Copper P 60.166 2060 0030 1068.01 Zinc Q 60.176 2060 0030 1068.01 Lead R 60.186 2060 0030 1068.01 Aluminum S 60.195 2060 0031 1683.02 Ferroalloy Z 60.266 2060 0033 1065.02 1( b) Short Characterization/ Abstract In general, all NSPS standards require initial notifications, performance tests, and periodic reports. Owners or operators 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, in general, of all sources subject to NSPS. Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least 2 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 EPA Regional Office.

Secondary Brass and Bronze The New Source Performance Standards ( NSPS), for Subpart M, Brass and Bronze were proposed on June 11, 1973, promulgated on March 8, 1974, and amended most recently on February 14, 1989. Any facility that commences construction or modification after June 11, 1973, is subject to the requirements of this subpart. These standards apply to the following facilities in secondary brass or bronze production plants: reverberatory and electric furnaces of 1,000 kg or greater production capacity and blast ( cupola) furnaces of 250 kg/ hr or greater production capacity. Furnaces from which molten brass or bronze are cast into the shape of finished products, such as foundry furnaces, are not considered to be affected facilities. This information is being collected to assure compliance with 40 CFR Part 60, subpart M. Approximately 5 sources are currently subject to the standard, and it is estimated that no additional sources per year will become subject to the standard in the next three years. 3 Primary Copper Smelters The New Source Performance Standards ( NSPS), for Subpart P, Primary Copper Smelters were proposed on October 16, 1974, and promulgated on January 15, 1976. Any facility that commences construction or modification after October 16, 1974, is subject to the requirements of this subpart. These standards apply to the following facilities in primary copper smelters: dryer, roaster, smelting furnace, and copper converter. This information is being collected to assure compliance with 40 CFR Part 60, Subpart P. Approximately 13 sources are currently subject to the standard, and it is estimated that no additional sources will become subject to the standard in the next three years.

Primary Zinc Smelters The New Source Performance Standards ( NSPS), for Subpart Q, Primary Zinc Smelters were proposed on October 16, 1974, and promulgated on January 15, 1976. Any facility that commences construction or modification after October 16, 1974, is subject to the requirements of this subpart. These standards apply to the following facilities in primary zinc smelters: roaster and sintering machine. This information is being collected to assure compliance with 40 CFR Part 60, Subpart Q. Approximately one source is currently subject to the standard, and it is estimated that no additional sources will become subject to the standard in the next three years.

Primary Lead Smelters The New Source Performance Standards ( NSPS), for Subpart R, Primary Lead Smelters were proposed on October 16, 1974, and promulgated on January 15, 1976. Any facility that commences construction or modification after October 16, 1974, is subject to the requirements of this subpart. These standards apply to the following facilities in primary lead smelters: sintering machine, sintering machine discharge end, blast furnace, dross reverberatory furnace, electric smelting furnace, and converter. This information is being collected to assure compliance with 40 CFR Part 60, Subpart R. Approximately one source is currently subject to the standard, and it is estimated that no additional sources will become subject to the standard in the next three years.

Primary Aluminum Reduction Plants The New Source Performance Standards ( NSPS), for Subpart S, Primary Aluminum Reduction Plants were proposed on October 23, 1974, promulgated on July 25, 1977, and amended most recently on February 14, 1989. Any facility that commences construction or modification after October 23, 1974, is subject to the requirements of this subpart. These standards apply to the following facilities in primary aluminum reduction plants: potroom groups and anode bake plants. Note that an owner or operator of an affected facility may elect to comply with the requirements of this subpart or the requirements of subpart LL of part 63. This 4 information is being collected to assure compliance with 40 CFR Part 60, subpart S. Approximately 6 sources are currently subject to the standard, and it is estimated that no additional sources will become subject to the standard in the next three years.

Ferroalloy Production Facilities The New Source Performance Standards ( NSPS), for Subpart Z, Ferroalloy Production were proposed on October 21, 1974, promulgated on July 25, 1977, and amended most recently on February 14, 1990. Any facility that commences construction or modification after October 21, 1974, is subject to the requirements of this subpart. These standards apply to the following facilities in ferroalloy production plants: electric submerged arc furnaces which produce silicon metal, ferrosilicon, calcium silicon, silicomanganese zirconium, ferrochrome silicon, silvery iron, high carbon ferrochrome, charge chrome, standard ferromanganese, silicomanganese, ferromanganese silicon, or calcium carbide; and dust handling equipment. This information is being collected to assure compliance with 40 CFR Part 60, subpart Z. Approximately one source is currently subject to the standard, and it is estimated that no additional sources per year will become subject to the standard in the next three years. These numbers and the number of sources for the other subparts covered by this ICR are based on data in EPA's Aerometric Information Retrieval System ( AIRS) database, data on primary nonferrous metal smelters in the Sector Facility Indexing Project ( SFIP), and information provided by staff in EPA's Office of Air Quality Planning and Standards.

2. Need for and Use of the Collection 2( a) Need/ Authority for the Collection The EPA is charged under Section 111 of the Clean Air Act, as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which ( taking into consideration the cost of achieving such emissions reduction, or any nonair quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated [ Section 111( a)( l)]. The Agency refers to this charge as selecting the best demonstrated technology ( BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years. In addition, Section 114( a) states that the Administrator may require any owner or operator subject to any requirement of this Act to: . . . ( A) establish and maintain such records; ( B) make such reports; ( C) install, use, and maintain such monitoring equipment, and use such audit procedures, or 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, 5 production variables or other indirect data when direct monitoring of emissions is impractical; ( F) submit compliance certifications in accordance with section 114( a)( 3); and ( G) provide such other information as the Administrator may reasonably require. In the Administrator's judgment, particulate matter emissions from secondary brass and bronze plants, primary copper, lead and zinc smelters, primary aluminum reduction plants, and ferroalloy production facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, NSPS regulations were promulgated for these source categories at 40 CFR Part 60, Subparts M, P, Q, R, S and Z.

2( b) Practical Utility/ Users Of The Data The control of emissions of particulate matter and other specified pollutants from secondary brass and bronze, primary copper, lead and zinc smelters, primary aluminum reduction and ferroalloy production plants require not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. Emissions of metallic particulate matter from Secondary Brass and Bronze Production Plants are the result of operation of any reverberatory and electric furnaces of 1,000 kg or greater production capacity and blast ( cupola) furnaces of 250 kg/ h or greater production capacity. Emissions of metallic particulate matter and sulfur dioxide from Primary Copper Smelters are the result of the operation of each dryer, roaster, smelting furnace or copper converter. The same emissions from Primary Lead Smelters are the result of each sintering machine, sintering machine discharge end, blast furnace, dross reverberatory furnace, electric smelting furnace and converter. Emissions from Primary Zinc Smelters are the result of each roaster and sintering machine. Emissions of gaseous hydrogen fluoride and particulate fluorides, alumina, carbon monoxide, volatile organic compounds and sulfur dioxide from Primary Aluminum Reduction Plants are the result of the operation of potroom groups and anode bake plants. Emissions of particulate matter and carbon monoxide from Ferroalloy Production Facilities are the result of the operation of electric submerged arc furnaces that produce: silicon metal, ferrosilicon, calcium silicon, silicomanganese zirconium, ferrochrome silicon, silvery iron, high carbon ferrochrome, charge chrome, standard ferromanganese, silicomanganese, ferromanganese silicon, or calcium carbide; and dust handling equipment. These standards rely on the capture of particulate matter emissions by control devices such as filters, scrubbers, or electrostatic precipitators. The required notifications are used to inform the Agency or delegated authority when a source becomes subject to the standard. The reviewing authority may then inspect the source to check if the particulate control devices, e. g., filters, scrubbers, and percipitators, are properly installed and operated and the standards are being met. Performance test reports are needed as these are the Agency's record of a source's initial capability to comply with the emission standard, and serve as a record of the operating conditions under which compliance was achieved. An example of an operating condition common to all subparts addressed in this ICR is the opacity of gases during operation of an affected facility. The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities affected by the NSPS continue 6 to operate the control equipment and achieve compliance with the regulations. Adequate monitoring, recordkeeping, and reporting is necessary to ensure compliance with these standards, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.

3. Nonduplication, Consultations, and Other Collection Criteria The recordkeeping and reporting requested is required under 40 CFR Part 60, Subparts M, P, Q, R, S and Z.

3( a) Nonduplication If the standard has not been delegated, the information is sent 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 their own similar regulation to implement the Federal Regulation, 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 Standard. 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 on March 31, 2000.

3( c) Consultations No comments were received on the burden published in the Federal Register.

3( d) Effects of Less Frequent Collection Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the required 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 likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease.

3( e) General Guidelines None of the reporting or recordkeeping requirements violate any of the regulations established by OMB in 5 CFR 1320.6. 7 3( f) Confidentiality The required information consists of emissions data and other information that have been determined not to be private. However, 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 None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested 4( a) Respondents/ SIC Codes The respondents of the recordkeeping and reporting requirements are:

Regulation SIC Codes NAICS Codes NSPS Subpart M, Secondary Brass and Bronze Production Plants 3341 331492 NSPS Subpart P, Primary Copper Smelters 3331 331411 NSPS Subpart Q, Primary Zinc Smelters 3339 331419 NSPS Subpart R, Primary Lead Smelters 3339 331419 NSPS Subpart S, Primary Aluminum Reduction Plants 3334 331312 NSPS Subpart Z, Ferroalloy Production Facilities 3313 331112 4( b) INFORMATION REQUESTED ( i) Data Items All data in this ICR that is recorded and/ or reported is required by 40 CFR Part 60, Subpart M, Secondary Brass and Bronze Production Plants; Subpart P, Primary Copper 8 Smelters; Subpart Q, Primary Zinc Smelters; Subpart R, Primary Lead Smelters; Subpart S, Primary Aluminum Reduction Plants; or Subpart Z, Ferroalloy Production Facilities.

A source must make the following reports Reports for All NSPS Regulations Included in this ICR Construction/ reconstruction 60.7( a)( 1)

Anticipated startup 60.7( a)( 2)

Actual startup 60.7( a)( 3)

Physical or operational change 60.7( a)( 4)

Demonstration of continuous monitoring system ( except for Subpart M) 60.7( a)( 5)

Initial performance test results 60.8( a)

Initial performance test notification 60.8( d)

There are no Additional Reports for NSPS Subpart M Additional Reports for NSPS Subpart P excess emissions of opacity and sulfur dioxide 60.7( c) and 60.165( d)

Additional Reports for NSPS Subpart Q Excess emissions of opacity and sulfur dioxide 60.7( c) and 60.175( c)

Additional Reports For NSPS Subpart R excess emissions of opacity and sulfur dioxide 60.7( c) and 60.185( c) 9 Additional Reports For NSPS Subpart S Excess emissions of fluoride ( between 1.0 kg/ Mg and 1.3 kg/ Mg) in any performance test 60.192( b)

Advance notification of each performance test after initial performance test 60.194( c)

Additional Reports For NSPS Subpart Z Excess emissions of opacity 60.7( c) and 60.264( b)

product change 60.264( c)

Recordkeeping for all NSPS Regulations included in this ICR Startups, shutdowns, malfunctions, periods where the continuous monitoring system ( if required) is inoperative 60.7( b)

Performance test records 60.7( d)

Records are required to be retained for 2 Years 60.7( f)

No Additional Recordkeeping for NSPS Subpart M Additional Recordkeeping for NSPS Subpart P Monthly records of the total smelter charge and the weight percent ( dry basis) of arsenic, antimony, lead and zinc contained in the charge. 60.165( a) 10 Additional Recordkeeping for NSPS Subpart Q Calculations of two hour average sulfur dioxide concentrations that have been recorded daily for the 12 consecutive 2 hour periods of each operating day. 60.175( b)

Additional Recordkeeping for NSPS Subpart R Calculations of two hour average sulfur dioxide concentrations that have been recorded daily for the 12 consecutive 2 hour periods of each operating day. 60.185( b)

Additional Recordkeeping for NSPS Subpart S Daily records of the weight of aluminum and anode produced 60.194( a)

Daily records of production rates of aluminum and anodes, raw material feed rates, and cell or potline voltages 60.194( b)

Additional Recordkeeping for NSPS Subpart Z Daily records of product produced; description of constituents of furnace charge, including the quantity, by weight; time and duration of each tapping period and identification of material tapped; all furnace power input data obtained; all flow rate data or all fan motor power consumption and pressure drop data. 60.265( a) 11 ii. Respondent Activities Respondent Activities Read instructions.

With the exception of Subpart M respondents, install, calibrate, maintain, and operate a CMS. Subparts P, Q, R, and Z respondents shall use a CMS to monitor for opacity. In addition, Subparts P, Q, and R respondents shall use a CMS to monitor sulfur dioxide emissions. Subpart S respondents shall use a CMS to daily weigh aluminum and anode produced. Subpart Z respondents also shall use a CMS to measure and record the furnace power input, the flow rate through each separately ducted hood of the capture system or, alternatively, measure and record all fan motor power consumption and pressure drop across the fan.

Perform initial performance test, Reference: Method 5 for particulate matter concentrations for Subpart M ( during charging and refining, but not during pouring of the heat) and Subparts P, Q, R, and Z, and volumetric flow rate of the effluent gas ( with certain exceptions) for Subpart Z; Reference Method 9 for determination of opacity for all subparts; Reference Methods 13A or B for ducts or stacks and Method 14 for roof monitors to determine total fluoride concentration and volumetric flow rate of effluent gas for Subpart S; Reference the emission rate correction factor, integrated sampling procedure of Method 3B for carbon monoxide concentration for Subpart Z, 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.

Adjust the existing ways to comply with any previously applicable instructions and requirements.

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

Transmit, or otherwise disclose the information.

It is our understanding that many regulatory agencies are allowing sources to submit reports by disk or electronically. 12 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 information required under 40 CFR, Part 60, Subparts M, P, Q, R, S, and Z:

Agency Activities Observe initial performance tests and repeat performance tests if necessary.

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

Audit facility records.

Input, analyze, and maintain data in the Aerometric Information Retrieval System ( AIRS) database.

5( b) Collection Methodology and Management Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are 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 of any excess emissions required by subparts P, Q, R and Z and monthly or annual performance test reports and excess emissions reports of Subpart S are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. Information contained in the reports is entered into AIRS which is operated and maintained by EPA's Office of Air Quality Planning and Standards. AIRS is EPA's database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government owned facilities. EPA uses AIRS for tracking air pollution compliance and enforcement by Local and State regulatory agencies, and EPA Regional Offices and 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 or operator for two years.

5( c) Small Entity Flexibility The majority of sources affected by this ICR are not small businesses. Most of the primary nonferrous facilities are operated by large corporations. Even the smallest primary 13 aluminum plant in the country produces approximately 73,000 metric tons/ year which would not typically be considered a small business. Some of the secondary brass and bronze production sources subject to NSPS Subpart M may qualify as small businesses, but these facilities need to comply only with the basic requirements for all NSPS sources.

The recordkeeping and reporting requirements were selected within the context of these specific NSPS subparts and the specific process equipment and pollutants. The requirements reflect the burden on small businesses. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. Although the recordkeeping and reporting requirements are the same for small and larger businesses, the Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small businesses.

5( d) Collection Schedule The specific frequency for each information collection activity within this request is shown in Table 2a through Table 2d.

Table Index Table 2a NSPS subpart M Table 2b NSPS subparts P, Q, R Table 2c NSPS subpart S Table 2d NSPS subpart Z 6. Estimating the Burden and Cost of the Collection Tables 2a through 2d document the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for each of the subparts 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 ( 40 CFR Part 60, Subpart M, P, Q, R, S and Z). 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 at 5,350.5 person hours. This number represents the 14 addition of the total burden hours from each of the subparts included in this ICR. These hours are based on Agency studies and background documents from the development of the standards or test methods, Agency knowledge and experience with the NSPS program, previous ICRs, and any comments received.

6( b) Estimating Respondent Costs ( i) Estimating Labor Costs This ICR uses a technical labor rate of $ 54.94 per hour. These rates are from the United States Department of Commerce Bureau of Labor Statistics, March 1999, Table 10: Employment Costs for Private Industry by Occupational and Industry Group. The rates are from column 1: Total compensation. The wage rates have been loaded by adding 110% overhead. Only technical labor rates are used because most of these standards' requirements involve initial reporting of performance tests for new sources which is not anticipated to occur in the next three years or recordkeeping at existing sources of startups, shutdowns and malfunctions. In addition, most of the measurements and calculations required for monthly performance tests under Subpart S are consistent with the respondents' normal recordkeeping practices.

( ii) Estimating Capital and Operations and Maintenance Costs The type of industry costs associated with the information collection activity in the standards are labor costs and continuous monitoring device costs. The capital start up costs are one time costs when a facility becomes subject to the standard. The annual operations and maintenance costs are the ongoing costs to maintain the monitors. The total respondent costs have been calculated on the addition of the capital start up costs and the annual operations and maintenance costs.

( iii) Capital/ Start up vs. Operating and Maintenance ( O& M) Costs Capital/ Start up and Operating and Maintenance ( O& M) Costs ( A) Regulation ( B)

Continuous Monitoring device ( C)

Start up cost ($) for 1 affected facility ( D)

# of new affected facilities to start up ( E)

Total start up ( C X D) ( F) Annual O& M costs ($) for 1 affected facility ( G) # of affected facilities with O& M ( H)

Total O& M ( F X G)

Subparts P, Q, R, Z Opacity Monitor $ 36, 000 0 0 $ 7,500 16 $ 120,000 Capital/ Start up and Operating and Maintenance ( O& M) Costs 15 P, Q, R CMS that measures sulfur dioxide emissions $ 25,100 0 0 5,400 15 81,000 Subpart S CMS that daily weighs aluminum and anode produced Unknow n 0 0 5,000 6 30,000 Subpart Z CMS that measures and records furnace power input and flow rate or fan motor power consumptio n and pressure drop across the fan gas flow $ 13,500 pressure drop $ 1300 0 0 900 1 900 There are no Capital/ Start up costs for this ICR as indicated in the total of column E. Total Operating and Maintenance ( O& M) Costs for this ICR are $ 231,900. This is the total of column H. 6( c) Estimating Agency Burden and Cost The only Federal costs are user costs associated with analysis of the reported information. Publication and distribution of the information are part of the AIRS program. Examination of records to be maintained by the respondents will occur as part of the periodic inspection of sources, which is part of EPA's overall compliance and enforcement program. The average annual Federal Government cost during the 3 years of the ICR is estimated to be $ 9,184.74. This cost is based on an average wage of a GS 10, step 1 employee rate ($ 17.09 hour + 110% overhead = $ 35.89). This rate is from OPM's 2000 General Schedule, excluding 16 locality pay, basic rates. Details upon which this estimate is based appear in Tables 1a d: Agency Burden.

6( d) Estimating the Respondent Universe and Total Burden and Costs Summary Table Regulation Title # new sources per year # existing sources total burden hours total labor costs total annual responses Subpart M, Brass and Bronze 0 5 7.5 $ 412.05 0 Subpart P, Primary Copper, Subpart Q, Primary Zinc, Subpart R, Primary Lead 0 15 783.5 $ 43,045.49 30 Subpart S, Primary Aluminum 0 6 4,365 $ 239,813.10 51 Subpart Z, Ferroalloy Production 0 1 194.5 $ 10,685.83 1 TOTAL 0 27 5350.5 $ 293,956.47 82 The number of existing sources subject to NSPS Part 60, Subparts M, P, Q, R, S and Z is 27. The number of new sources subject to Subparts M, P, Q, R, S and Z is zero. The number of total respondents is 27. This is the number of existing sources plus the number of sources anticipated in one year. The total annual response is 82. This number is calculated from the number of new sources multiplied by the number of initial reports, plus the number of existing sources multiplied by the reporting requirements for each subpart included in this ICR. The total annual labor costs are $ 293,956.47, and total annual capital and O& M costs to the regulated entity are $ 231,900. Details upon which these estimates are based appear in Tables 2a  2d: Industry Burden. 17 6( e) Bottom Line Burden Hours And Cost Tables See attached Tables 1a d and 2 a d.

6( f) Reasons for Change in Burden The increase in total burden hours from the most recently approved ICRs is due to a reinstatement of burden hours for Subparts P, Q, R and Z . The previous ICR for Subparts P, Q, R, and the ICR for Subpart Z were inadvertently allowed to lapse several years ago There has been no change in the number of sources. Total annual respondent costs for complying with NSPS subparts M and S have increased slightly due to an increase in the labor rate since the last ICR renewal. Also that the burden represented in this ICR is the result of several previously separate ICRs being combined into one.

SUMMARY OF BURDEN CHANGES Regulation Title Prior OMB Control No. Previously Approved Burden Hrs. Current Burden Hrs. Previous Costs $ Current Costs $

Subpart M 2060 0110 7.5 7.5 263.00 412.05 Subpart P, Q, R 2060 0030 0* 783.5 0* 43,045.49 Subpart S 2060 0031 4365 4365 152,775.00 239,813.10 Subpart Z 2060 0033 0* 194.5 0* 10,685.83 TOTALS 4372.5 5350.5 $ 153,038.00 $ 293,956.47 * The previously approved hours and costs are no longer relevant given the time that has passed since the last ICR renewal. Therefore, the increase in burden is being calculated from a base of 0.

6( g) Burden Statement 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 18 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 currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, Office of Environmental Information ( OEI), U. S. Environmental Protection Agency, Mail Code 2822, 1200 Pennsylvania Ave., NW, Washington, D. C. 20460; and 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. Include the EPA ICR number 1604.06 and OMB control number 2060 0110 in any correspondence.

Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.