SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, 

Subpart YYYYY) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, 

Subpart YYYYY) (Renewal), EPA ICR Number 2277.04, OMB Control Number 2060-0608.

1(b) Short Characterization/Abstract

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

regulations published at 40 CFR Part 63, Subpart YYYYY were proposed on September 20, 

2007, and promulgated on December 28, 2007. These regulations apply to existing and new 

Electric Arc Furnace (EAF) steelmaking facilities that are area sources of hazardous air 

pollutants (HAP) emissions. The standard establishes particulate matter (PM) emission limits for 

control devices and opacity limits for melt shops, pollution prevention requirements for ferrous 

scrap that is melted in EAFs, and monitoring, reporting, and recordkeeping requirements. New 

facilities include those that commenced construction or reconstruction after the date of proposal. 

This information is being collected to assure compliance with 40 CFR Part 63, Subpart YYYYY.

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 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.

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

affected facility 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 87 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. The 

estimate was obtained by consulting industry during the renewal of this current ICR. 

The Office of Management and Budget (OMB) approved the currently active ICR 
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without any “Terms of Clearance.”

There are approximately 87 EAF steelmaking facilities in the United States, which are all 

owned and operated by the iron and steel mill industry. None of the facilities are owned by state, 

local, tribal or the Federal government. They are all owned and operated by privately owned, 

for-profit businesses. The burden to the “Affected Public” may be found in Table 1: Annual 

Respondent Burden and Cost – NESHAP for Area Sources: Electric Arc Furnace Steelmaking 

Facilities (40 CFR Part 63, Subpart YYYYY) (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 Area Sources: 

Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (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, HAP emissions from EAF steelmaking facilities 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 63,

Subpart YYYYY.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where 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 are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart 

YYYYY.

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 (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

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

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 
4

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

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 and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted both the Steel Manufacturers Association

(SMA) at (202) 296-1515 and the American Iron and Steel Institute at (202) 452-7180. The 

SMA estimated the number of EAF facilities has decreased from 91 to 87 since the last ICR 

renewal period, due to changes in industry (including facility closure as well as startup). We 

have revised the number of respondents based on the comment received.

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.

These standards require the respondents 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 the Part 

70 permit program and the five year statute of limitations on which the permit program is based. 

The retention of records for five years allows EPA to establish the compliance history of a 

source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded 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).
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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 EAF steelmaking 

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

affected by the standards is SIC 3312, which corresponds to the North American Industry

Classification System (NAICS) code 331111 for Iron and Steel Mills.

4(b) Information Requested

(i) Data Items

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

Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY). 

A source must make the following reports:

Notifications/Reports

Scrap management and pollution prevention plan 63.10685(a)(1) 

and (b)(1)

Startup, shutdown, and malfunction plan 63.6(e)(3)

Notification of applicability 63.9(b)(1)

Notification and application of construction or reconstruction 63.9(b)(4)

Compliance extension 63.9(c)

Notification of special requirements 63.9(d)

Notification of performance test 63.9(e)

Notification of opacity and visible emission observations 63.9(f)

Additional COMS notifications 63.9(g)

Notification of compliance status 63.10690(b) and 

63.9(h)

Semiannual compliance report addressing: 1) the number of mercury

switches removed or the weight of mercury recovered from the switches 

and properly managed, the estimated number of vehicles processed, an 

63.10685(c)
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Notifications/Reports

estimate of the percent of mercury switches recovered, and a certification 

that the recovered mercury switches were recycled at RCRA-permitted 

facilities; and 2) the control of contaminants from scrap according to the 

requirements in §63.10(e)

Startup, shutdown, malfunction report 63.10(d)(5)(ii)

A source must keep the following records:

Recordkeeping

Notifications and reports 63.10685(c), 

63.10(b)(2)(xiv)

Startups, shutdowns, malfunctions 63.6(e)(1)(iii)-(v)

Performance tests, performance evaluations, and opacity observations 63.10686, 

63.10(b)(2)(viii)-(ix)

Emission/operating limits 63.10(b)(2)(vii)

Scrap management requirements 63.10685(c) and 

63.10(b)(2)(iii)

Continuous monitoring systems 63.10(b)(2)(vi)-

(vii), (x)-(xi) 

63.10(c); 63.6(h)(7); 

63.8(d)(3)

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
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Respondent Activities

Read instructions.

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

supply pressure.

Perform initial performance test and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, 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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way, e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

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

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

reports, required to be submitted by industry.

Audit facility records.
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Agency Activities

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

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 entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses OTIS 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 five 

years.

5(c) Small Entity Flexibility

A small entity for this industry is defined by the Small Business Administration as a firm 

having no more than 1,000 employees. Of all facilities that will be subject to the rule, only a few 

facilities are considered to be small entities.

Although the standard would not have a significant economic impact on the small 

entities, we tried to reduce the impact of the rule on small facilities. EPA met with industry trade 

associations and company representatives to address any small business concerns during 

development of the final rule. 

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 Area Sources: 

Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal).

6. Estimating the Burden and Cost of the Collection
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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 1,417 (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 $127.43 ($60.68+ 110%) 

Technical $99.16 ($47.22 + 110%)

Clerical $50.88 ($24.23 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

December 2013, “Table 2. Civilian Workers, by occupational and industry group.” The rates are 

from column 1, “Total compensation.” The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

The only type of industry costs associated with the information collection activity in the 

regulations are labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost
10

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 

$7,515. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 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 Area 

Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) 

(Renewal).

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

87 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 87 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 87 0 0 87

2

0 87 0 0 87
11

Number of Respondents

3

0 87 0 0 87

Average 0 87 0 0 87

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 87. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Prepare scrap plan and scrap 

specifications 0 0 N/A 0

Initial performance tests 0 0 N/A 0

Notification of compliance 

status 0 0 N/A 0

Request for compliance 

extension 0 0 N/A 0

Notification of performance 

test 0 0 N/A 0

SSM report 29 1 N/A 29

Semiannual excess emissions 

reports 87 2 N/A 174

TOTAL (rounded) 203

The number of Total Annual Responses is 203.

The total annual labor costs are $136,341. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: 

Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (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
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The total annual labor hours are 1,417. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Electric Arc 

Furnace Steelmaking Facilities (40 CFR Part 63, Subpart YYYYY) (Renewal). 

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

information is estimated to average 7 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. The cost 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 167

labor hours at a cost of $7,515. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 CFR Part 63, Subpart 

YYYYY) (Renewal).

6(f) Reasons for Change in Burden

There is a decrease in the respondent burden and an increase in Agency burden. These 

changes occurred due to the following adjustment: 1) This ICR revises the number of 

respondents from 91 to 87 based on input provided from industry trade association; and 2) This 

ICR corrects the frequency of semiannual report review from one to two in Table 2. This 

correction results in an increase in the estimated Agency burden. 

6(g) Burden Statement

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

is estimated to average 7 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 
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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–2013–0323. 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-2013–0323 and OMB Control Number 2060-0608 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 

CFR Part 63, Subpart YYYYY) (Renewal)

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person hours 

per 

respondent 

per year (A x 

B)

(D) 

Respondents 

per year 

a

(E) 

Technica

l personhours 

per year 

(C x D)

(F) 

Management 

person hours 

per year (E

x0.05)

(G) 

Clerical 

person 

hours 

per year 

(E x 0.1)

(H) 

Total Cost 

per year b

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization 

of Technology and Systems 

N/A

4. Reporting Requirements

A. Read instructions d

8 1 8 0 0 0 0 $0 

B. Required activities 

 Prepare scrap plan and scrap 

specifications d 4 1 4 0 0 0 0 $0 

 Initial performance tests c

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

 Initial notification of applicability d

2 1 2 0 0 0 0 $0 

 Notification of compliance status d

2 1 2 0 0 0 0 $0 

 Request for compliance extension N/A

 Notification of performance test c

 Startup, shutdown, and malfunction 

plan/reports 4 1 4 29 116 5.8 11.6 $12,832.12 

Semiannual excess emissions reports 2 2 4 87 348 17.4 34.8 $38,496.35 

Subtotal for Reporting Requirements 533.6 $51,328.47 

5. Recordkeeping Requirements 
15

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person hours 

per 

respondent 

per year (A x 

B)

(D) 

Respondents 

per year 

a

(E) 

Technica

l personhours 

per year 

(C x D)

(F) 

Management 

person hours 

per year (E

x0.05)

(G) 

Clerical 

person 

hours 

per year 

(E x 0.1)

(H) 

Total Cost 

per year b

A. Read instructions See 4A

B. Plan activities See 4A

C. Implement activities See 4A

D. Develop record system d

4 1 4 0 0 0 0 $0 

E. Time to enter information 0.5 52 26 29 754 37.7 75.4 $83,408.76 

F. Time to transmit or disclose information 0.25 2 0.5 29 14.5 0.73 1.45 $1,604.01 

G. Time to adjust existing ways d

2 1 2 0 0 0 0 $0 

F. Time to train personnel d

4 1 4 0 0 0 0 $0 

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 883.8 $85,012.78 

TOTAL ANNUAL BURDEN AND COST

(ROUNDED) 1,417 $136,341.25 

N/A = Not Applicable.

Assumptions:

a There are 87 EAF steelmaking facilities. The average number of respondents per year for one-time events over the 3-year period of the ICR is 29.

b This ICR uses the following labor rates: $127.43 for managerial labor, $99.16 for technical labor, and $50.88 for clerical labor. These rates are from the U.S. 

Department of Labor, Bureau of Labor Statistics, December 2013. The rates have been increased by 60 percent to account for overhead.

c

 All plants have conducted performance tests during the implementation period of the rule. 

d After full implementation, existing facilities are not expected to experience any burden from these activities and no new facilities are expected to become subject 

to the rule over the 3-year period.
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Area Sources: Electric Arc Furnace Steelmaking Facilities (40 

CFR Part 63, Subpart YYYYY) (Renewal)

Activity

(A) EPA 

personhours per 

occurrence

(B) No. of 

occurrences 

per plant per 

year

(C) EPA 

personhours 

per 

plant 

per year 

(AxB)

(D) 

Plants 

per 

year 

a

(E) 

Technical 

personhours per 

year (CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

personhours 

per year 

(Ex0.1)

(H) 

Cost, $ b

Report Review

Initial notification of applicability c

1 1 1 0 0 0 0 $0

Startup, shutdown, malfunction plan/report 2 1 2 29 58 2.9 5.8 $3,005.82

Notification of compliance status c

1 1 1 0 0 0 0 $0

Semiannual excess emissions report 0.5 2 0.5 87 87 4.35 8.7 $4,508.73

TOTAL ANNUAL BURDEN 167 $7,515 

Assumptions:

a There are 87 EAF steelmaking facilities. The average number of respondents per year for one-time events over the 3-year period of the ICR is 29.

b This ICR uses the following average hourly labor rates: $62.27 for managerial (GS-13, Step 5, $38.92 × 1.6), $46.21 (GS-12, Step 1, $28.88 × 1.6) for technical 

and $25.01 (GS-6, Step 3, $15.63 × 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) “2013 General Schedule” which excludes 

locality rates of pay.

c After full implementation, the agency is not expected to experience any burden from these activities because existing facilities are not longer expected to submit 

Initial notifications of applicability or Notifications of compliance status. No new facilities are expected to become subject to the rule over the 3-year period.