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N E W Y O R K , N Y

C H I C A G O , I L

S T A M F O R D , C T

P A R S I P P A N Y , N J

B R U S S E L S , B E L G I U M

A F F I L I A T E O F F I C E S

M U M B A I , I N D I A

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July 23, 2010

VIA ELECTRONIC MAIL

Dr. Donna Lee Jones

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

Re: Proposed Information Collection Request Under Clean Air Act

Section 114 - Electric Arc Furnace Steelmaking; Comments of the

Specialty Steel Industry of North America

Dear Dr. Jones:

On behalf of the Specialty Steel Industry of North America (“SSINA”), we are

pleased to provide the following comments regarding the agency’s proposed Information

Collection Request (“ICR”) for the electric arc furnace (“EAF”) steelmaking industry sector.

These comments focus on general concerns that the specialty steel sector has with respect to the

proposed ICR. In a separate submission filed jointly with the Steel Manufacturers Association,

SSINA provides specific comments on the questions and data requests in the proposed ICR.

The purpose of these comments is to express SSINA’s concern about the

disproportionate representation of specialty steel mills among the nine EAF steelmaking

facilities tentatively slated to receive the ICR. With three companies scheduled to receive the

ICR, specialty steel companies account for 33 percent of the survey population. This level of

representation contrasts strikingly with the fact that specialty steel represents only 2-3 percent of

steel production. Given the costs of responding to the survey, including the need to conduct

extensive testing, SSINA objects to placing these burdens disproportionately on the specialty

steel sector.

Further, SSINA urges EPA to consider collecting data separately for (1) the

MACT-based mercury standard and (2) the New Source Performance Standards (“NSPS”) (data

for particulate matter, carbon monoxide, and other parameters). The facilities selected for
Dr. Donna Lee Jones

July 23, 2010

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K E L LEY D R Y E & W AR R E N LLP

provision of mercury data are not necessarily the best facilities for providing data on the NSPS

pollutants and parameters. In fact, one of the facilities is not even subject to the existing NSPS.

While individual companies likely will provide additional comments on the

proposed ICR, SSINA requests that the agency consider spreading the burden of the data

collection in a way that better reflects the economic realities of the industry. SSINA appreciates

the opportunity to review the draft ICR and help ensure a rational rulemaking process.

Please let me know if you would like to discuss these comments. I can be reached

at 202.342.8849 or JGreen@KelleyDrye.com.

Respectfully submitted,

Joseph J. Green

Counsel to the Specialty Steel Industry of North

America