SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Secondary Lead Smelter Industry (40 CFR Part 63, Subpart X)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for the Secondary Lead Smelter Industry (40 CFR Part 63, Subpart
X) (Renewal)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 63, subpart X, were
proposed on June 9, 1994, (59 FR 29750), and promulgated on June 23,
1995, (60 FR 32587).  In response to industry petitions to reconsider,
the final rule was amended on June 13, 1997 (62 FR 32209).  Entities
potentially affected by this rule are owners or operators of secondary
lead smelters that operate furnaces to reduce scrap lead metal and lead
compounds to elemental lead.  The rule applies to secondary lead
smelters that use blast, reverberatory, rotary, or electric smelting
furnaces to recover lead metal from scrap lead, primarily from used
lead-acid automotive-type batteries.  The rule provides protection to
the public by requiring all secondary lead smelters to meet emission
standards reflecting the application of the maximum achievable control
technology (MACT).  This information is being collected to assure
compliance with 40 CFR part 63, subpart X.

In general, all NESHAP 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 of all sources subject to
NESHAP.

Any owner or operator subject to the provisions of this part will
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

Approximately 23 sources are currently subject to the regulation, and no
additional sources are expected to become subject to the standard in the
next three years.  It is further assumed that there is an average of one
affected facility per plant respondent.

	The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

The reports required by this rule are submitted directly to state and
local pollution control Agencies, rather than the Federal Government.
The Government Paperwork Elimination Act applies only to Federal
Agencies.

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost.  The burden to the “Federal Government”
is attributed entirely to work performed by federal employees or
government contractors; this burden may be found in Table 2: Average
Annual EPA Burden.

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 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, 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, metal (i.e., containing lead compounds)
and organic hazardous air pollutants (HAPs) emissions from secondary
lead smelting processes cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare.
Therefore, the NESHAP was promulgated for this source category at 40 CFR
part 63, subpart X.

2(b)  Practical Utility/Users of the Data

The control of metal and organic HAPs emissions from secondary lead
smelting processes requires not only the installation of properly
designed equipment, but also the operation and maintenance of that
equipment.  Emissions of metal and organic HAPs emissions from secondary
lead smelting processes are the result of operation of the affected
facilities (i.e., smelting furnaces, refining kettles, agglomerating
furnaces, dryers and fugitive dust).  The subject standards are achieved
by the capture of source and fugitive emissions containing total
hydrocarbons and lead compounds by adhering to the leak detection and
repair plan for baghouses or use of wet scrubbers to control particulate
matter and metal hazardous air pollutants.

The notifications required in the applicable regulations are used to
inform the Agency or delegated authority when a source becomes subject
to the requirements of the regulations.  The reviewing authority may
then inspect the source to check if the pollution control devices are
properly installed and operated and/or leaks are being detected and
repaired and the regulations are being met.  The semiannual, or as
determined by the Administrator, emissions reports, i.e., are used for
problem identification, as a check on source operation and maintenance,
and for compliance determinations.

The information generated by the (monitoring, recordkeeping and
reporting) requirement described in this ICR is used by the Agency to
ensure that facilities affected by the NESHAP continue to operate the
control equipment in compliance with the regulation.  Adequate
monitoring, recordkeeping, and reporting are necessary to ensure
compliance with the applicable regulations, 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 requested recordkeeping and reporting are required under 40 CFR part
63, subpart X.

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 their 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 at 74 FR 38004 on July 30, 2009.
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

It is our policy to review any comments received since the last ICR
renewal including those submitted in response to the first Federal
Register notice and respond appropriately.  In this case, no comments
were received.  During a previous renewal of this ICR, the Agency’s
internal industry experts have been consulted.  The Agency’s internal
data sources and any projections of industry growth over the next three
years have also been considered.

The primary source of information as reported by industry, in compliance
with the recordkeeping and reporting provisions in the standard, is the
Air Facility System (AFS) which is operated and maintained by the EPA
Office of Compliance.  AFS is the EPA database for the collection,
maintenance, and retrieval of all compliance data.  Approximately 23
respondents are currently subject to the regulation.  Our consultations
with Agency industry experts and industry representatives regarding the
growth rate for the industry indicated that per year, no additional
respondents will become subject to the regulation over the next three
years.

	During a previous renewal of this ICR, the 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.  The
standard has been previously reviewed to determine the minimum
information needed for compliance purposes.

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 that emission limitations are met.  If the information
required by these standards were collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require affected facilities to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

3(f)  Confidentiality

The required information has been determined not to be confidential.
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 (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).

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 and NAICS Codes

The respondents to the recordkeeping and reporting requirements are
owners or operators of secondary lead smelters that operate furnaces to
reduce scrap lead metal and lead compounds to elemental lead.  The
United States Standard Industrial Classification (SIC) code for the
respondents affected by the standards is 3341, which corresponds to the
North American Industry Classification System (NAICS) 331492 for
Secondary Smelting, Refining, and Alloying of Nonferrous Metal (except
Copper and Aluminum).  Industries other than secondary lead smelters
which are included in this SIC code are not respondents to this ICR.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR 1320.5.

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 63, subpart X.

	A source must make the following reports:

Notification Reports for 40 CFR part 63, subpart X

Construction/reconstruction	63.5

Initial notifications 	63.9(b)

Initial performance test	63.7(b), 63.9(e)

Initial performance test results	63.10(d)(2)

Rescheduled initial performance test	63.7(b)(2)

Approval of smelters fugitive dust control standard operating procedures
manual, and operating procedures manual for baghouses	63.549(b)

Demonstration of continuous monitoring system	63.9(g)

Compliance status	63.9(h)

Physical or operational change	63.9, 63.10

Periodic startup, shutdown, malfunction reports	63.10(d)(5)(i)

Semiannual, or as determined by the Administrator, monitoring/exceedance
summary	63.10(e)(3), 63.550(c)

	A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart X

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	63.10(b)(2)

All reports and notifications	63.10(b)

Record of applicability	63.10(b)(3)

Records of bag leak detection system alarms, including corrective
actions	63.550(a)(2)

Records for sources with continuous monitoring systems	63.10(3)

Records of parametric monitoring data, system maintenance and
calibration	63.550(a)

Initial and annual compliance test results	63.550(a)(1)

Records are required to be retained for five years, however, only the
data of the most recent two years must be kept on-site	63.550(a)

Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site.

Also, regulatory agencies, in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, operate and maintain baghouses, according to, a standard
operating procedures manual and consistent with the manufacturer(s
instructions.

Monitor and record pressure drop and liquid supply pressure at the wet
scrubber at least once every hour when using this control device for
controlling particulate matter and metal HAP emissions from a process
fugitive source.

Install, calibrate, maintain, and operate a CMS for temperature
monitoring of the afterburner or the combined blast furnace and
reverberatory furnace exhaust streams when complying with the total
hydrocarbon emission standard.

Install, calibrate, maintain, and operate a total hydrocarbon CMS for
measuring emissions when complying with the total hydrocarbon emission
standard.

Equip pressurized drying bleaching seals with an alarm to determine seal
malfunctions.

Perform initial performance test and repeat performance tests if
necessary.

Use referenced Methods in Appendix A, part 60, to determine compliance
with the emission standards for lead compound (i.e., Methods 1, 2, 3, 4,
and 12) and to determine compliance with the emission standards for
total hydrocarbons (i.e., Methods 1, 2, 3B, 4, and 25A).

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.

Some state regulatory agencies are setting up electronic reporting
systems to allow sources to report electronically which is reducing the
reporting burden.  However, electronic reporting systems are still not
widely used by the regulatory agencies.  The estimated amount of
electronic reporting is 10 percent.

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,
and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority may inspect
the source to determine whether the pollution control devices are
properly installed and operated.  Data and records maintained by the
respondents are tabulated and published for use in compliance and
enforcement programs.  The semiannual reports of excess emissions 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 the AFS which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
database for the collection, maintenance, and retrieval of compliance
and annual emission inventory data for more than 100,000 industrial and
government-owned facilities.  EPA uses the AFS 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 or
operator for five years.

5(c)  Small Entity Flexibility

A majority of the affected facilities are small businesses.  However,
the impact on small entities was taken into consideration during the
development of the regulation.  The current number of small entities
affected by this rule could not be determined, based on review of the
following sources: the proposed rule notice in the Federal Register (59
FR 63941) on June 9, 1994; the promulgated rule notice in the Federal
Register (60 FR 32587) on June 23, 1995; EPA’s Industry Profile for
the Secondary Lead Smelters NESHAP (EPA-453/R-94-040, June 1994); and a
search of publicly available current data sources.  Based on historical
data provided in EPA’s Industry Profile for the Secondary Lead
Smelters NESHAP, approximately 50 percent of affected facilities may be
small businesses.

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 and large entities.  The Agency
considers these requirements the minimum needed to ensure compliance
and, therefore, cannot reduce them further for small entities.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost.

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 16,034
(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: $89.94 per hour for Executive,
Administrative, and Managerial labor; $61.66 per hour for Technical
labor, and $38.39 per hour for Clerical labor.  These rates are from the
United States Department of Labor, Bureau of Labor Statistics, September
2002, Table 10. Private industry, by occupational and industry group.
The rates are from column 1, Total compensation.  The rate has been
increased by 110 percent to account for the benefit packages available
to those employed by private industry.

Managerial	$89.94  ($42.83 + 110%)

Technical	$61.66  ($29.36 + 110%)

Clerical	$38.39  ($18.28 + 110%)

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

The types of industry cost associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup cost is an one-time cost when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitors 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)

Startup Cost ($) for One Affected Facility	(C)

Number of New Affected Facilities to Startup	(D)

Total Startup

(B X C)	(E)

Annual O&M Costs ($) for One Affected Facility	(F)

Number of Affected Facilities with O&M	(G)

Total O&M Costs ($)

(E X F)

Temperature monitor for afterburners 	1,200	0	0	0	0	$0

Continuous particulate monitor 	0	0	0	7,500	20	$150,000

*  NOTE:  This assumes that the O&M costs for temperatures monitors are
negligible.  Twenty of the 23 existing sources have continuous
particulate monitors.

The total capital/startup costs for this ICR is zero.  This is the total
of column D in the above table.  The total operation and maintenance
(O&M) costs for this ICR are $150,000.

The average annual cost for capital/startup and operation and
maintenance cost to industry over the next three years of the ICR is
estimated to be $150,000.

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 $53,058.  This cost is based on the following average
hourly labor rates, times a 1.6 benefits multiplication factor to
account for government overhead expenses:

Managerial	$53.22   (GS-13, Step 5, $33.26 x 1.6)

Technical	$39.49   (GS-12, Step 1, $24.68 x 1.6)

Clerical	$21.38   (GS-6, Step 3, $13.36 x 1.6)

These rates are from the Office of Personnel Management (OPM) 2003
General Schedule which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: NESHAP for the Secondary
Lead Smelter Industry (40 CFR part 63, subpart X).

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

Approximately 23 sources are currently subject to the regulation, and it
is estimated that per year, no additional source will become subject to
the regulation in the next three years.

Respondent Universe and Number of Responses Per Year

Information Collection Activity	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(F)

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

Total Annual Responses =

(AxB)+(CxD)+F

Notification of reconstruction *	1	1	0	0	0	1

Semiannual reports	N/A	N/A	23	2	0	46

Notification of operational changes	N/A	N/A	23	1	0	23

TOTAL

70

*  NOTE:  One furnace may be rebuilt over the three-year period of this
ICR.

The number of total respondents is 23.  This represents the number of
existing sources which is 23, plus the number of new sources which is
(zero) averaged over the three-year period (i.e., the total of the
number of new respondents over the three-year period divided by three
years).

The number of Total Annual Responses is 70.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table above.

The total annual labor costs are $975,913.  Details regarding estimates
on the total hours requested and total annual labor costs may be found
in Table 1. Annual Respondent Burden and Cost, NESHAP for the Secondary
Lead Smelter Industry (40 CFR part 63, subpart X).

Note that the total annual capital and O&M costs to the regulated entity
are $150,000.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information are estimated to average 229
hours per response.

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this
ICR compared to the previous ICR.  This is due to two considerations.
First, the regulations have not changed over the past three years and
are not anticipated to change over the next three years.  Second, the
growth rate for respondents is very low, negative, or non-existent.
Therefore, the labor hours and cost figures in the previous ICR reflect
the current burden to the respondents and are reiterated in this ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 229 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA regulations are listed
at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2009-0533.  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 Avenue, N.W., Washington, D.C.  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<PHONE_NUMBER>, and the telephone number
for the docket center is<PHONE_NUMBER>.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention:
Desk Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0533 and OMB Control Number 2060-0296 in any
correspondence.

Part B of the Supporting Statement

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

Table 1.  Annual Respondent Burden and Cost:  NESHAP for Secondary Lead
Smelter Industry (40 CFR part 63, subpart X)

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	(E)

Technical person-	hours per year

(E=CxD)	(F)

Management person-hours per year

(Ex0.05)	(G)

Clerical person-hours per year

(Ex0.1)	(H)

Total Cost Per Year $ a

1. Applications	N/A

	2. Survey and Studies	N/A

	3. Reporting Requirements

  A. Read instructions  b	4	1	4	0	0	0	0	$0.00

  B. Required activities

	0	0	0	$0.00

     Annual performance test 	330	1	330	23	7,590	380	759	$531,314.61

     Monitoring requirements:

     - CPM  c	1	52	52	20	1,040	52	104	$72,795.84

     - Baghouse inspection: d	0	0	0	0	0	0	0	$0.00

     - Inspections of capture hoods  e 	8	1	8	23	184	9.2	18.4	$12,879.27

     - Revise SOP Manual  f	20	1	20	1	20	1	2	$1,399.92

C. Create information	See 3B

0	0	0	$0.00

D. Gather existing information	See 3B

0	0	0	$0.00

E. Write report

	0	0	0	$0.00

      Initial notification report  b	3	1	3	0	0	0	0	$0.00

    Notification of reconstruction  d	2	1	2	1	2	0.1	0.2	$123.32

   Notification of actual startup	2	1	2	0	0	0	0	$0.00

   Notification of SOP manuals  h	8	1	8	0	0	0	0	$0.00

   Notification of performance test b	2	1	1	0	0	0	0	$0.00

   Notification of compliance test  b	4	1	4	0	0	0	0	$0.00

   Report of performance test	8	1	8	0	0	0	0	$0.00

   Notification of CMS demonstration  b	2	1	2	0	0	0	0	$0.00

   Semiannual reports  g	16	2	32	23	736	36.8	73.6	$51,517.05

   Notification of physical/ operational changes  f	8	1	8	23	184	9.2
18.4	$12,879.27

SUBTOTAL REPORTING

	11,220 (rounded)	$682,909.28

4. Recordkeeping Requirements

A.  Read instructions	See 3A

0	0	0	$0.00

B.  Plan activities	See 3B

0	0	0	$0.00

C.  Implement activities	See 3B

0	0	0	$0.00

D.  Develop record system	N/A

	E.  Develop Record System   b	3.5	52	182	23	4,186	209.3	418.6
$293,003.25

F.  Time to enter and transmit information

  Record monitoring parameters	See 4E

0	0	0	$0.00

  Record of performance tests	See 4E

0	0	0	$0.00

  Record of periodic inspections	See 4E

0	0	0	$0.00

G.  Time to train personnel	N/A

0	0	0	$0.00

H.  Time to adjust existing ways to comply with previously applicable
requirements	N/A

0	0	0	$0.00

I.  Time for audits	N/A

0	0	0	$0.00

SUBTOTAL RECORDKEEPING

	4,814 (rounded)	$293,003.25

Subtotal labor burden and cost

	13,942	697	1,395	$975,912.53

TOTAL LABOR BURDEN AND COST (Rounded)

	16,034	$975,913

Assumptions:

a  Costs are based on the following hourly rates:  $89.94 per hour for
Executive, Administrative, and Managerial labor; $61.66  per hour for
Technical labor, and $38.39 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, September 2002, (Table 10. Private industry, by occupational
and industry group.(  The rates are from column 1, (Total compensation.(
 The rates have been increase by 110 percent to account for the benefit
packages available to those employed by private industry.  Management
person-hours and clerical person-hours are assumed to be 5 percent and
10 percent of technical person-hours, respectively.

b  One-time only activity.  This assumes no new sources over the next
three years.

c  Three facilities already have continuous particulate monitors (CPM).
This assumes 1 hour per week to monitor and respond to alarms.

d  Since baghouses requirements are part of the normal plant operations,
inspections are not attributed to this rule.  We have determined that
there are approximately 23 existing sources currently subject to this
rule and that no new plants will be constructed over the next three
years of this ICR.  However, we have assumed that one furnace will be
rebuilt per year over the period of this ICR.

e  Sources must perform this inspection when starting-up and once per
year thereafter.

f  We assume that each facility will make a major adjustment once per
year.  In each instance, SOP must be revised.

g  Sources are required to submit semiannual reports of excess emissions
or no excess emissions.

h  The owner or operator shall submit fugitive dust control and baghouse
SOP, along with a notification requesting review and approval.

Table 2.  Average Annual EPA Burden:  NESHAP for Secondary Lead Smelter
Industry (40 CFR part 63, subpart X)

Activity	A

EPA person- hours per occurrence	B

No. of occurrences per plant per year	C

EPA technical person-hours per plant per year (AxB)  	D

Plants per year	E

EPA management hours per year	F

EPA technical hours per year	G

EPA clerical hours per year	H

Employee hours per year

(E+F+G)	I

Cost, $ a

Review initial notification reports  b	2	1	2	0	0	0	0	0	$0.00

Review notifications of compliance status	10	1	10	0	0	0	0	0	$0.00

Review quarterly summary reports 	10	1	10	92	46	920	92	1058	$40,745.88

Review notifications of actual startups	2	1	2	0	0	0	0	0	$0.00

Review notices of physical/operational changes  c	4	1	4	23	4.6	92	9.2
105.8	$4,074.59

Review notification of performance tests	4	1	4	0	0	0	0	0	$0.00

Review notifications of demonstration of CMS 	2	1	2	0	0	0	0	0	$0.00

Review notifications of construct/reconstruction	2	1	2	1	0.1	2	0.2	2.3
$88.58

Review and approve SOP manual 	8	1	8	0	0	0	0	0	$0.00

Attend initial performance tests	120	1	120	0	0	0	0	0	$0.00

Attend repeat performance tests 	120	1	120	0	0	0	0	0	$0.00

Review annual compliance test results  d	8	1	8	23	9.2	184	18.4	211.6
$8,149.18

TOTAL LABOR BURDEN AND COST 	 	 	 	 	 	 	 	1,378

(rounded)	$53,058.22

Assumptions:

a  This cost is based on the average hourly labor rate as follows:
Managerial $53.22 (GS-13, Step 5, $33.26 x 1.6); Technical $39.49
(GS-12, Step 1, $24.68 x 1.6); and Clerical $21.38 (GS-6, Step 3, $13.36
x 1.6).  This ICR assumes that Managerial hours are 5 percent of
Technical hours, and Clerical hours are 10 percent of Technical hours.

b  We have determined that there are approximately 23 existing sources
currently subject to this rule and that no new plants will be
constructed over the next three years of this ICR.  However, we have
assumed that one furnace may be rebuilt per year over the period of this
ICR.

c  This assumes that each plant will make at least one major adjustment
per year.

d  We assume that it will take 8 hrs to review annual compliance test.

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