Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; NESHAP for the Secondary Lead Smelter Industry (Renewal)
Agencies
ELI5 AI
The EPA is asking for more time to gather information about factories that recycle lead, like from old car batteries, to make sure they follow pollution rules. They want people to share their thoughts about this until the end of March, 2025.
Summary AI
The Environmental Protection Agency (EPA) has asked for approval to extend an information collection request for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Secondary Lead Smelter Industry. This extension is needed to ensure compliance with regulations that affect entities recovering lead from materials like used car batteries. Public comments about this proposal can be sent until March 31, 2025. The estimated cost of these activities is $2,750,000 per year, involving around 19,900 hours of work from 11 facilities.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), NESHAP for the Secondary Lead Smelter Industry (EPA ICR Number 1686.13, OMB Control Number 2060-0296) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a proposed extension of the ICR, which is currently approved through February 28, 2025. Public comments were previously requested via the Federal Register on May 18, 2023 during a 60-day comment period. This notice allows for an additional 30 days for public comments.
Keywords AI
Sources
AnalysisAI
The Environmental Protection Agency (EPA) has released a notice seeking approval to extend an information collection request (ICR) regarding the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Secondary Lead Smelter Industry. This involves collecting data to ensure compliance with regulations affecting operations that recover lead from scrap materials, such as used car batteries. Public commentary on this proposal is open until March 31, 2025.
General Summary
The document outlines the EPA's request to renew the existing requirements for the industry, highlighting an ongoing need to gather information to ensure facilities are following environmental standards. The focus is primarily on those facilities that extract lead from old automotive batteries, using various types of smelting processes. This renewal aims to continue the oversight of operational procedures at these facilities to ensure they do not exceed set pollution levels.
Significant Issues and Concerns
There are several potential issues and areas for improvement noted in the document:
Clarity and Readability: The redundancy between the abstract and summary can make understanding the document's purpose more challenging for non-experts. Additionally, complex technical terms and regulatory references are used without sufficient explanation, potentially confusing a general audience.
Terminology: Phrases like "Capital and O&M costs" and smelting methods are not defined, which may leave readers unsure about their meanings or significance.
Lack of Context: The document does not fully explain the implications of the decrease in the number of facilities reporting, nor does it discuss how this affects compliance or environmental outcomes.
Informal Language: Phrases such as "our preferred method" for comment submission are casual and may be perceived as informal for an official notice.
Undefined Goals: There is no clear explanation of the desired outcomes or specific goals for the information collection, making it harder to understand its necessity.
Public Impact
The proposed extension affects the public by ensuring continued monitoring and control of emissions from secondary lead smelters, thereby potentially protecting public health and the environment. For the general public, this oversight is crucial as it aims to manage hazardous emissions from industries that might otherwise contribute to environmental degradation.
Stakeholder Impact
The impact on stakeholders, specifically the 11 facilities mentioned, involves both time and financial resources. The estimated burden includes significant operational costs and compliance hours, which may be seen as onerous by some facility operators. However, these measures are essential to maintain industry standards and environmental safety.
For environmental advocacy groups, the continuation of this data collection is likely seen as a positive step toward ensuring that industries adhere to pollution control measures.
In summary, while the EPA's notice addresses crucial regulatory needs, improvements in clarity, defining terms, and explaining changes could help the public and stakeholders better understand and engage with the process.
Financial Assessment
The Federal Register document under review involves the Environmental Protection Agency's (EPA) submission of an information collection request concerning the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Secondary Lead Smelter Industry. A critical part of the document focuses on the financial implications tied to this request.
Financial Summary
The document specifies a total estimated cost of $2,750,000 per year. This figure includes $238,000 in annualized capital or operation and maintenance (O&M) costs. These costs represent the financial resources necessary for implementing and maintaining compliance with the regulations outlined in the information collection request.
Financial Allocation and Context
The financial allocation in this document is earmarked for ensuring compliance with environmental standards set by NESHAP for the Secondary Lead Smelter Industry. This budget encompasses several activities, including initial notifications, performance tests, periodic reports, and ongoing maintenance, all of which are required for facilities operating under these standards.
Issues Related to Financial References
One of the identified issues with this financial reference is the use of technical jargon, such as "capital and O&M costs," without providing layperson-friendly definitions or explanations. This oversight could limit the general audience's understanding of how their tax money is being utilized.
Moreover, the document does not explicitly explain the impact of the decrease from 12 to 11 facilities on the total estimated respondent burden. This reduction in the number of sources has led to a decrease in estimated respondent burden by 1,800 hours and an associated decrease in capital and O&M costs. A comprehensive explanation of these changes would provide clearer insight into how and why financial resources are being adjusted and how these adjustments may affect overall compliance costs or environmental impacts.
Simplification for General Understanding
While discussing financial aspects, the document could benefit from simplifying the language used to explain costs. For instance, clearly stating that "operation and maintenance costs" involve regular expenses required to keep facilities compliant with environmental regulations would enhance accessibility for individuals unfamiliar with industry-specific terms.
Conclusion
The financial allocations outlined in the document highlight the significant investment needed by entities in the secondary lead smelter industry to comply with federal environmental regulations. Although the document outlines these costs, it could offer clearer explanations and context for a broader audience to enhance transparency and understanding of compliance-related expenses.
Issues
• The abstract and summary sections contain repetitive information that could be consolidated to improve clarity and readability.
• The term 'Capital and O&M costs' is used but not explicitly defined or explained in the document for layperson understanding.
• The document references technical terms like 'reverberatory, rotary, or electric smelting furnaces' without additional explanation, which may not be understandable to a general audience.
• The document mentions a decrease in sources but does not explain the implications of this decrease for compliance or environmental impact.
• There is no explanation provided for why the estimated respondent burden decreased from 12 to 11 facilities.
• The language regarding where to submit comments ('our preferred method') seems informal for an official government document.
• The document assumes prior knowledge by referring to specific federal regulations and amendments without providing a context or summary of these regulations for someone unfamiliar with them.
• No specific goals or outcomes for the information collection are stated explicitly, which might make assessing the necessity and efficiency of this activity challenging.