# SUPPORTING STATEMENT **ENVIRONMENTAL PROTECTION AGENCY NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese**  **(40 CFR Part 63, Subpart XXX) (**  **Supplemental Proposed**  **R ule** **)**
**1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) , EPA ICR Number 2448.0 2 , OMB Control Number 2060

-NEW

. **1(b) Short C**  **haracterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the regulations published at 40 CFR subpart XXX were proposed on August 4, 1998, promulgated on May 20, 1999, and amended most recently on March 22, 2001. The purpose of this information collection request is to document the expected impacts of proposed addition of proposed changes to subpart XXX that are being developed as part of the risk and technology review process of the current subpart XXX

. Subpart XXX would continue to apply to new and existing ferroallo ys production facilities that manufacture ferromanganese and silicomanganese, and that are either major sources of hazardous air pollutants (HAPs) emissions or are co

- located at major sources of HAPs. The following affected facilities at ferroallo y production plants are subject to this NESHAP rule: submerged arc furnaces; casting operations, metal oxygen refining (MOR) process; crushing and screening operations; and fugitive dust sources. New sources include those that commenced construction or reconstruction after the date of the supplemental proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart XXX. Compared to existing subpart XXX, the proposed changes would increase the number of pollutants and sources regulated and add requirements for continuous monitoring and periodic testing. In addition, the proposed rule would eliminate the startup, shutdown and malfunction (SSM) exemption, remove the SSM plan requirement and add a requirement for electronic submittal of performance tests. In general, all NESHAP standards require initial notifications, performance tests, monitoring and periodic reports by the owners/operators of the affected facilities. 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 th e file for at least 5 years following the date of such measurements,

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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.
Over the next 3 ye ars, an average of two respondent s per year will be subject to the standard, and no additional respondents per year will become subject to the standard. Based on our consultations with industry representatives, there are two plants that are currently subject to subpart XXX and both would be subject to the proposed revisions to XXX

. The facilities subject to this rule have the ability to compl y with the reporting requirements electronically

. The burden to respondents is calculated in Table s 1 , 2, and 3 of Attachment 1 : Annual Respondent Burden and Cost of Reporting and Recordkeeping for Ferroalloys Production: Ferromanganese and Silicomanganese. Since this regulation only affects the ferroallo ys production industry, the burden to the “Federal Government” is attributed entirely to work performed b y Federal employees or government contractors
. This burden is calculated in Ta ble s 5, 6, and 7 of Attachment 1 : Annual Burden and Cost to the Federal Government for Ferroalloys Production: Ferromanganese and Silicomanganese

. **2. Need for and Use of the Collection**  **2(a) Need/Authority for the Collection**  Section 112 of the Clean Air Act (CAA) requires the EPA to establish NESHAP for both major and area sources of HAP that are listed for regulation under CAA section 112(c). A major source is a stationary

source that emits or has the potential to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a stationary source that is not a major source (i.e., an area source does not emit and does not have the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any combination of HAP). For major sources, these technology

-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non

- air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires the EPA to review these technology

-based standards and to revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequentl y than every 8 years. In addition, section 112(f) of the CAA requires the EPA to determine for source categories subject to certain CAA section 112(d) standards whether the emissions limitations provide an ample margin of safety to protect public health. For MACT standards for HAP “classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime excess cancer risks to the individual most exposed to emissions from a source in the category or subcategory

to less than 1

- in

- 1 million,” the EPA must promulgate residual risk standards for the source category

(or subcategory) as necessary to provide an ample margin of safety to protect

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public health. In doing so, the EPA may adopt standards equal to existing MACT standards, if the EPA determines that the existing standards are sufficiently protective. The EPA must also adopt more stringent standards, if necessary, to prevent an adverse environmental effect, but must consider cost, energy, safety, and other relevant factors in doing so. Certain records and reports are necessary for the Administrator to confirm the compliance status of sources subject to NESHAP, identify any new or reconstructed sources subject to the standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specificall y authorized b y section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 ye ars following the date of each occurrence, measurement, maintenance, corrective action, report, or record. **2(b) Practical Utility/Users of the Data**  The recordkeeping and reporting requirements in the standards 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. Performance tests for air pollution devices are required in order to determine an affected facility ’ s initial capability to compl y with the emission standards. Continuous emission monitors are used to ensure that the control equipment is operating properly and therefore, ensure compliance with the standards at all times. During the performance test, a record of the operating parameters under which compliance was achieved may be recorde d and used to determine compliance in place of a continuous emission monitor. The notifications required in the standards 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 ensure that the pollution control devices are properl y installed and operated; that leaks are being detected and repaired; and that the standards are being met. The performance test may also be observed. The required semiannual compliance status reports and quarterly excess emissions reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

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**3. Non** 
**- duplication, Consultations, and Other Collection Criteria**  A computer search of the EPA ’ s ongoing ICR s revealed no duplication of information

gathering efforts. **3(a) Non** 
**- duplication**  If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency

. If a state or local agency has adopted its own similar standards to implement the f ederal standards, a cop y of the report su bmitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the f ederal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB**  The preamble to the proposed rule wi ll provide public notice

. **3(c) Consultations** 
The proposed rule amendments were developed using extensive consultation with individual companies and s tate agencies. Several of the key non - EPA persons consulted on the information collection activities are identified in Table 1

. Additional meetings and contacts are documented in the project docket for this proposed rule, Docket No. EPA

- HQ

- OAR

- 2009

- 0734.
**TABLE 1** 
**. P** **ERSONS CONSULTED ON THE**  **INFORMATION COLLECTION ACTIVITIES** 
**Contact Organization**  **Telephone Number** Jeffrey McKinney Eramet Marietta, Inc. 740

- 374

- 1143 John Konrady Felman Production 304

- 882

- 1181 James Robertson West Virginia Department of Environmental

Protection 304

- 926

- 0499 Christina Wieg Ohio EPA 740

- 380

- 5223

**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 b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the

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possibility

of detecting violations would be less likely

. **3(e) General Guidelines**  None of the guidelines in 5 CFR 1320.6 are being exceeded. **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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1 978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**  The reporting or recordkeeping requirements in the standard do not include sensitive questions.
**4. The Respondents and the Information Requested**  **(a) Respondents/** **NAICS Codes**  The respondents to the recordkeeping and reporting requirements are the owners or operators of all new and existing ferroallo ysproduction facilities that are major sources or are
co - located at major sources. The affected facilities produce either ferromanganese or silicomanganese. The North American Industry Classification System (NAICS) code is 331112,

“ Electrometallurgical Ferroalloy Product Manufacturing

. ” There are two facilities that will be subject to the proposed amendments to the NESHAP

. No new ferroalloys production facilities are expected during the 3

- ye ar period of this ICR. **4(b) Information Requested**  **i) Data Items**  Attachment 2, Information Requirements, summarizes the data items, including recordkeeping and reporting requirements, for the Ferroallo ysProduction source category . The amendments to the NESHAP require that any performance tests performed after the effective date of the final rule be submitted electronicall y t o EPA’s Central Data Exchange b y using the Electronic Reporting Tool (ERT) for test methods that are compatible with ERT. This new requirement to submit the data to the ERT is in addition to the other existing submission requirements for this data.

# 6 **(ii) Respondent Activities**  The respondent activities that will be required b y the proposed amendments to the Ferroallo ysProduction NESHAP are identified in Tables 1 through 3 of Attachment 1 and are introduced in section 6(a). This illustrative estimate is not considered a duplicate estimate of cost under the General Duty to Minimize Emissions clause under § 63.6(e)(1)(i), which states: “At all times, the owner and operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determining whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.”
**5. The Information Collected:**  **Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency**  **Activities** The Agency

activities associated with the proposed amendments to the Ferroalloys Production NESHAP are provided in Tables 5 through 7 of Attachment 1 and are introduced in section (6)(c). **5(b) Collection Methodology and Management**  Following no tification 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 b y the Agency to discern a source ’ s initial capability to comp ly

with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The quarterly excess emissions reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the EPA Air Facility Subsystem (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 data for approximately 125,000 industrial and government

- owned facilities. The EPA uses the AFS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. The EPA and its delegated Authorities can edit, store, retrieve and anal yz e the data.

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The records required b y this regulation must be retained by the owner/operator for 5 ye ars. **5(c) Sm**  **all Entity Flexibility** For this source category, whi ch has the NAICS code 331112 ( i.e., Electrometallurgical ferroalloy product manufacturing), the Small Business Administration ( SBA) small business size standard is 750 employees according to the SBA small business standards definitions. We have determined that there are no small businesses affected by this regulation at this time. The Agency considers the final rule requirements the minimum needed to ensure compliance with the standards. **5(d) Collection Schedule**  The specific frequency

for each information collection activity within this request is shown in Tables 1

- 3 of Attachment 1 for the Ferroalloys Production source c ategory

. **6. Estimating the Burden and Cost of the Collection**  **6(a) Estimating Respondent Burden**  The annual burden estimates for the proposed amendments to the Ferroalloys Production NESHAP are shown in Tables 1 through 3 of Attachment 1. These numbers were derived from estimates based on the EPA’s experience with other standards. No burden estimates are provided for new sources because no new facilities are expected to become affected sources during the 3

- ye ar period of this ICR. **6(b) Estimating Respondent Costs**  **(i) Estimating Labor Costs**  We used May 20 12 mean hourly labor rates from the Bureau of Labor Statistics for the Iron and Steel Mills and Ferroalloy Manufacturing (NAICS 331100)

. 1 

# Lo ading factors (i.e., fringe benefits and overhead rates) were calculated using methodologies referenced in promulgated regulations and their accompanying Information Collection Requests (ICRs), particularl y those used in New Source Review (NSR) regulations. Fringe benefits are calculated as 29% of hourl y earnings, and overhead is calculated using a standard 110% above hourl y earnings. Table 2 presents the labor rates used in the cost anal ys is.

1 May 2012 National Industry

- Specific Occupational Employment and Wage Estimates. Located http://www.bls.gov/oes/current/naics4_331100.htm#11

- 0000

# 8 **T ABLE**  **2**
**. 2012**  **LOADED LABOR RATES**

**Hourly earnings [$**  **20 12**  **] Fringe**  **Overhead Loaded**  **20 12**  **Hourly Earnings ($)**  Professional specialty and technical (environmental engineer) 34.26 1.29 2.10 $ 92.81 Executive, admin, managerial (managers, all other) 55.21 1.29 2.10 $ 149.56 Admin support (office clerk) 16.27 1.29 2.10 $ 44.08 

# To estimate the costs of conducting the initial performance tests , we assumed that facilities would hire a contractor. We show these cost as one

- time expense in the 3

- ye ar IC R period

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**  The capital costs assoc iated with the NESHAP include monitoring s ys tem initial costs; one - time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and conducting stack testing. We assumed that facilities would purchase and begin to operate all required monitoring systems in Year 2 of the ICR, whi ch is also the year we assumed they would conduct their initial performance tests.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**  The estimated capital and O&M costs for the affected units for the first 3 years after promulgation are provi ded. For the two facilities, the total capital costs are $ 360 , 548

. The total annualized capital and O&M costs are $ 1, 798 , 436 for an average of $ 599 , 479 per year. **6(c) Estimating Agency Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. The overall compliance and enforcement program of EPA includes activities such as the examination of records maintained b y the respondents, periodic inspection of sources of emissions, and the publication and dis tribution of collected information. The average annual Agency cost during the 3 ye ars of the ICR is estimated to be $ 2,177

. The Agency

labor rates are from the Office of Personnel Management (OPM) 201 2 General Schedule, which excludes locality rates of pay . These rates can be obtained from Salary Table 201 2

- GS available on the OPM website, https://www.opm.gov/policy

- data

- oversight/pay

leave/salaries

- wages/2012/general

- schedule/

.

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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 were increased by 60 percent to include fringe benefits and overhead **6(d) Estimating the Respondent Universe and Total Burden and Costs** 
There are two existing facilities that are subject to the proposed Ferroalloys Production NESHAP. No new sources are expected during the 3

- year compliance period. No new facilities are expected to begin operation during the 3

- ye ar compliance period. Over the 3

- year period, it is estimated that these two facilities will have 3 4 responses for an average of 1 1 per year
. **6(e) Bottom Line Burden Hours Burden Hours and Cost Tables**  **(i) Respondent Tally** The bottom line respondent burden hours and costs, presented in Tables 1

- 3 of Attachment 1 are calculated by adding person

- hours per year down each column for technical, managerial, and clerical staff, and b y adding down the cost column. The average annual burden for the recordkeeping and reporting requirements in the proposed amendments to subpart XXX for the two existing facilities that are subject to the Ferroallo ysProduction NESHAP is $ 599 , 479 . This includes 801 annual labor hours. The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 , 2, and 3 of Attachment 1 , respectivel y
. **(ii) The Agency Tally**  The average annual Federal Government cost is $ 2,177 for 48 hours for the proposed amendments to subpart XXX. The bottom line Agency burden hours and costs presented in T ables 5 through 7 of Att achment 1 are calculated by adding person

- hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column. **6(f) Reasons for Change in Burden**  We are requesting an increase in burden of $ 5 43 , 523 over the full 3

- ye ar program due to implementation of these proposed changes to the regulation. **6(g) Burden Statement**  The average annual respondent burden for the proposed amendments to the Ferroalloys Production NESHAP is estimated at 401 hours per facility or 36 hours per response

.

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Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a f ederal 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 th e 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 the EPA regulations are listed at 40 CFR part 9 and 48 C FR 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, the EPA has established a public docket for this ICR under Docket ID Number EPA

- HQ

- O AR

- 2010

- 0 895

. An electronic version of the public docket is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public 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 above. The docket is also available f or in person viewing at the Air and Radiation 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 Air Docket is (202) 566

- 1742. Also, you may send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17 th 

# Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number (EPA

- HQ

- OAR

- 20 10

- 0895 ) in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.

# 11 ATTACHMENT 1

Burden Estimate Tables 1 through 8

Tables 1 through 3: Annual Respondent Burden and Cost of Recordkeeping and Reporting

Requirements of the Proposed Standard , Years 1 through 3 Table 4: Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting of the Proposed Standard Tables 5 through 7: Annual B urden and C ost to the F ederal G overnment of the P roposed

S tandard, Years 1 through 3 Table 8: Summary of Annual B urden and C ost to the F ederal G overnment of the P roposed S tandard(A ) (B ) (C) (D) (E ) (F) (G) (H) (I ) (J) (K ) (L)

Pe rs on-hours per oc currenc e Contracto r

cost p er occu rrenc e Other nonlabor c os ts per oc currenc e No. of

oc cu rrenc es per res pondent per year Person-hours

per res pondent per y ear Res pondents

per ye ar Te ch nic al

pers on-hours per year Ma nagement

pers on-hours per y ear Cleric al

pers on-hours per ye ar To tal labor

costs per ye ar Tota l nonlabor costs per y ear Tota l number

of res pons es per ye ar (AxD) (Ex F) (Gx 0. 05) (Gx 0.1) ((B+ C)x Dx F) (Dx F) 1. Ap plications N/A 2. Su rv ey and Studies N/A 3. Reporting Requirements A. Read ins tructions ( b) 20. 00 1.0 20. 0 2. 0 40.0 0. 4 4. 0 $3, 949 $0 0 B. Required ac tiv

ities a . I nit ial Complianc e te st ( PM, H Cl , H g, PAH , f ormaldehy de) - Furnac e PP FF 15. 00 $200,000 3.0 45. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 b . I nit ial Complianc e te st ( PM, H Cl , H g, PAH , f ormaldehy de) - Furnac e NP FF/Scrbr 15. 00 $52,000 2.0 30. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 c. I nit ial Complianc e te st ( PM) -- Bldg Vent./#12 casting/ misc. sou rc es N P FF 20. 00 $5, 000 4.0 80. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 d . We ekly Method 9 ( c) 2.00 156.0 312. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 e . Pres su re drop/liquid flow rate CP MS-scrubber I nit ial Capit al 2.00 $50,000 1.0 2. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 An nual (O&M) 2.00 $18,000 1.0 2. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 f. Bag Leak Detec tion Syste m I nit ial Capit al 4.00 $269,148 0.5 2. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 An nual (O&M) 4.00 $219,078 0.5 2. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 g . D uctw

orkf low r at e monitoring I nit ial Capit al 2.0 $41,400 0.5 1. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 An nual (O&M) 2.0 $4,140 0.5 1. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 h . Furnac e Capture System I ns pec ti on (Quart erly ) 2.0 10.0 20. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 i. An nual Com pliance te st - F urnac e Scrbr (PM, Hg), Furnac e FF ( Hg) 20. 00 $5, 000 1.0 20. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 C. Create information See 3B $0 D. Gather ex istin g information See 3B $0 E. Write r

eport $0 a . I nitial N otif

icatio n N/A b . N otif icatio n of Complianc e Status 4.00 1.0 4. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 c. Ann ual Compliance Cert if ic at ion (d) 10. 00 1.0 10. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 d . Report of Exceedenc es (e) 10. 00 1.0 10. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 e . Dev elop process f

ugiv es v entilation plan 80. 00 $250,000 1.0 80. 0 2. 0 160.0 1. 0 16. 0 $15, 704 $500, 000 2 f. U pdate fugit iv

e dus t co nt rol plan 10. 00 1.0 10. 0 2. 0 20.0 1. 0 2. 0 $2, 094 $0 2 g . U pdat e baghous e mo nitoring plan 10. 00 1.0 10. 0 2. 0 20.0 1. 0 2. 0 $2, 094 $0 2 h . Dev elop bagleakd etec tion sy stem SOP 20. 00 1.0 20 2. 0 40 1 4 $4, 038 $0 2 **Re porting Subt** 

**ota l**  188.0 681. 0 10. 0 280.0 4. 4 28. 0 $27, 879 $500, 000 8. 0 4. Rec ordk eeping Requirement s A. Read ins tructions See 3A $0 0 B. I mplementa ctiv

ities N/A $0 0 C. Dev elop rec ord s yste m N/A $0 0 D. Time to enter inf

ormation E. Rec ords of all inf

o. required bysta ndards (f) 1.00 60.0 60. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 F. T ime to train personnel 20. 00 1.0 20. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 G. Time f

or audits N/A 0. 0 0. 0 $0 $0 0 **Re cordke**  **ep ing Subt** 

**ota l**  61.0 80. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 **TOTAL** 249.0 761. 0 12. 0 320.0 5. 4 32. 0 $31, 917 $500, 000 8. 0 Tota l Hours Labor Cos t Non-Labor Tot al Su mma ry of res pondent burden 357 $31, 917 $500, 000 531,917 $ Ini tia l capital and s ta rtup $0 An nualized Capital/startup and O&M $500, 000 N/A = N otApplicable. (a) Cos ts a re based on t he fol lowing hourly rates: te chnical at $71.95, management at $115.94, and clerical at $34.17. (b) One-time activ

ity. There are an es timated 2 existing f erroalloy s p roduc tion f

ac ilities and no new

f acilities are expected. (c ) Weekly method 9, wit h initial tes ts estimated to occur in Year 2 of

I CR. Assu mes in -hous e readers

. (d) Th e 2 ex istin g plant s w ould be required to su bm it a n Annual Compliance Cert ific ation at the end of Year 2 of

th e IC R and each year th ereafter. (e) Assu mes th at 2f

ac ilities p er ye ar would hav e tosu bmit a R

eport of exceedence. (f) Rec ordk eeping requirements begin in Year 2 of I CR cle aranc e period for all existing plants. **TA BLE**  **1 . Y** **EAR 1**  **ANNUAL RES**  **PONDENT BURDEN AND COST OF RE**  **PORTING AND RE CO**  **RDKEEP IN**  **G RE QU**  **IR EM**  **ENT S FOR FE**  **RROALLOYS PRODUCTI**  **ON: FERROMANGANES E**  **AND SILICOMA** **NGANESE**

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(A ) (B ) (C) (D) (E ) (F) (G) (H) (I ) (J) (K ) (L)

Pe rs on-hours per oc currenc e Contrac to r

co st p er occu rrenc e Other nonlabor c os ts per oc currenc e No. of

oc cu rrenc es per res pondent per year Person-hours

per res pondent per y ear Res pondents

per ye ar Te ch nic al

pers on-hours per year Ma nagement

pers on-hours per y ear Cleric al

pers on-hours per ye ar To tal labor

costs p er ye ar Tota l nonlabor co sts per y ear Tota l number

of res pons es per ye ar (AxD) (Ex F) (Gx 0. 05) (Gx 0.1) ((B+ C)x Dx F) (Dx F) 1. Ap plications N/A 2. Su rv ey and Studies N/A 3. Reporting Requirements A. Read ins tructions ( b) 20. 00 1.0 20. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 B. Required ac tiv

ities a . I nit ial Complianc e te st ( PM, H Cl , H g, PAH , f ormaldehy de) - Furnac e PP FF 15. 00 $200,000 3.0 45. 0 1. 0 45.0 0. 5 4. 5 $4, 450 $600, 000 3 b . I nit ial Complianc e te st ( PM, H Cl , H g, PAH , f ormaldehy de) - Furnac e NP FF/Scrbr 15. 00 $52,000 3.0 45. 0 1. 0 45.0 0. 5 4. 5 $4, 450 $156, 000 3 c. I nit ial Complianc e te st ( PM) -- Bldg Vent./#12 cas ting/ misc. sou rc es N P FF 20. 00 $5, 000 3.5 70. 0 2. 0 140.0 1. 0 14. 0 $13, 760 $35, 000 7 d . We ekly Method 9 (c) 2.00 156.0 312. 0 2. 0 624.0 1. 0 62. 4 $60, 814 $0 0 e . Pres su re drop/liquid flow rate CP MS-scrubber I nit ial Capit al 2.00 $50,000 1.0 2. 0 1. 0 2.0 0. 5 0. 2 $269 $50, 000 0 An nual (O&M) 2.0 $18,000 1.0 2. 0 1. 0 2.0 0. 5 0. 2 $269 $18, 000 0 f. Ba g Leak Detec tion Syste m I nit ial Capit al 4.0 $269,148 0.5 2. 0 2. 0 4.0 1. 0 0. 4 $538 $269, 148 0 An nual (O&M) 4.0 $219,078 0.5 2. 0 2. 0 4.0 1. 0 0. 4 $538 $219, 078 0 g . D uctw

orkf low r at e monitoring I nit ial Capit al 2.0 $41,400 0.5 1. 0 2. 0 2.0 1. 0 0. 2 $344 $41, 400 0 An nual (O&M) 2.0 $4,140 0.5 1. 0 2. 0 2.0 1. 0 0. 2 $344 $4, 140 0 h . Furnac e Capture System I ns pec ti on (Quart erly ) 2.0 10.0 20. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 i. An nual Com pliance te st - F urnac e Scrbr (PM, Hg), Furnac e FF ( Hg) 20. 00 $5, 000 1.0 20. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 C. Create information See 3B $0 D. Gather ex istin g information See 3B $0 E. Write r

eport $0 a . I nitial N otif

icatio n N/A b . N otif icatio n of Complianc e Status 4.0 1.0 4. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 c. Ann ual Compliance Cert if ic at ion (d) 10.0 1.0 10. 0 2. 0 20.0 1. 0 2. 0 $2, 094 $0 2 d . Report of Excee denc es (e) 10.0 1.0 10. 0 2. 0 20.0 1. 0 2. 0 $2, 094 $0 2 e . D ev elop process f

ugiv es v entilation plan 80.0 $250,000 1.0 80. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 f. U pdate fugit iv

e dus t co nt rol plan 10.0 1.0 10. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 g . U pdat e baghous e mo nitoring plan 10.0 1.0 10. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 h . D ev elop bagleak d etec tion sy stem SOP 20.0 1.0 20 0. 0 0 0 0 $0 $0 0 **Re porting Subt** **ota l**  188.5 686. 0 22. 0 950.0 11 95. 0 $94, 002 $1, 032, 218 17. 0 4. Rec ordk eeping Requirement s A. Read ins tructions See 3A $0 0 B. I mplementa ctiv

ities N/A $0 0 C. D ev elop rec ord s yste m N/A $0 0 D. Time to enter inf

ormation E. Rec ords of all inf

o. required by sta ndards (f) 1.0 60.0 60. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 F. Time to train personnel 20.0 1.0 20. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 G. Time f

or audits N/A 0. 0 0. 0 $0 0 **Re cordke**  **ep ing Subt** **ota l**  61.0 80. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 **TOTAL** 249.5 766. 0 24. 0 990.0 12. 0 99. 0 $98, 040 $1, 032, 218 17. 0 Tota l Hours Labor Cos t Non-Labor Tot al Su mma ry of res pondent burden 1,101 $98, 040 $1,032, 218 1, 130,258 $ Ini tia l capital and s ta rtup $360, 548 An nualized Capital/startup and O&M $1,032, 218 N/A = N otApplicable. (a) Cos ts a re based on t he fol lowing hourly rates: te chnical at $71.95, management at $115.94, and clerical at $34.17. (b) One-time activ

ity. There are an es timated 2 existing f erroalloy s p roduc tion f

ac ilities and no new

f acilities are expected. (c ) Weekly method 9, wit h initial tes ts e stimated to occur in Year 2 of

I CR. Assu me s in -hous e readers

. (d) Th e 2 ex istin g plant s w ould be required t o su bm it a n Annual Compliance Cert ific ation at the end of Year 2 of

th e IC R and each year th ereafter. (e) Assu me s th at 2f

ac ilities p er ye ar would hav e tosu bmit a Report of exceedence. (f) Rec ordk eeping requirements begin in Year 2 of I CR cle aranc e period for all existing plants. **TA BLE**  **2 . Y** **EAR 2**  **ANNUAL RES**  **PONDENT BURDEN AND COST OF RE**  **PORTING AND RE CO**  **RDKEEP IN**  **G RE QU**  **IR EM**  **ENT S FOR FE**  **RROALLOYS PRODUCTI**  **ON: FERROMANGANES E**  **AND SILICOMA** **NGANESE**

# 14

(A ) (B ) (C) (D) (E ) (F) (G) (H) (I ) (J) (K ) (L)

Pe rs on-hours per oc currenc e Contrac to r

co st p er occu rrenc e Other nonlabor c os ts per oc currenc e No. of

oc cu rrenc es per res pondent per year Person-hours

per res pondent per y ear Res pondents

per ye ar Te ch nic al

pers on-hours per year Ma nagement

pers on-hours per y ear Cleric al

pers on-hours per ye ar To tal labor

costs p er ye ar Tota l nonlabor co sts per y ear Tota l number

of res pons es per ye ar (AxD) (Ex F) (Gx 0. 05) (Gx 0.1) ((B+ C)x Dx F) (Dx F) 1. Ap plications N/A 2. Su rv ey and Studies N/A 3. Reporting Requirements A. Read ins tructions ( b) 20. 00 1.0 20. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 B. Required ac tiv

ities a . I nit ial Complianc e te st ( PM, H Cl , H g, PAH , f ormaldehy de) - Furnac e PP FF 15. 00 $200,000 3.0 45. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 b . I nit ial Complianc e te st ( PM, H Cl , H g, PAH , f ormaldehy de) - Furnac e NP FF/Scrbr 15. 00 $52,000 3.0 45. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 c. I nit ial Complianc e te st ( PM) -- Bldg Vent./#12 cas ting/ misc. sou rc es N P FF 20. 00 $5, 000 3.5 70. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 d . We ekly Method 9 (c) 2.00 156.0 312. 0 2. 0 624.0 1. 0 62. 4 $60, 814 $0 0 e . Pres su re drop/liquid flow rate CP MS-scrubber I nit ial Capit al 2.00 $50,000 1.0 0. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 An nual (O&M) 2.0 $18,000 1.0 2. 0 1. 0 2.0 0. 5 0. 2 $269 $18, 000 0 f. Ba g Leak Detec tion Syste m I nit ial Capit al 4.0 $269,148 0.5 0. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 An nual (O&M) 4.0 $219,078 0.5 2. 0 2. 0 4.0 1. 0 0. 4 $538 $219, 078 0 g . D uctw

orkf low r at e monitoring I nit ial Capit al 2.0 $41,400 0.5 0. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 An nual (O&M) 2.0 $4,140 0.5 1. 0 2. 0 2.0 1. 0 0. 2 $344 $4, 140 0 h . Furnac e Capture System I ns pec ti on (Quart erly ) 2.0 10.0 20. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 i. An nual Com pliance te st - F urnac e Scrbr (PM, Hg), Furnac e FF ( Hg) 20. 00 $5, 000 5.0 100. 0 1. 0 100.0 0. 5 10. 0 $9, 797 $25, 000 5 C. Create information See 3B $0 D. Gather ex istin g information See 3B $0 E. Write r

eport $0 a . I nitial N otif

icatio n N/A b . N otif icatio n of Complianc e Status 4.0 1.0 4. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 c. Ann ual Compliance Cert if ic at ion (d) 10.0 1.0 10. 0 2. 0 20.0 1. 0 2. 0 $2, 094 $0 2 d . Report of Excee denc es (e) 10.0 1.0 10. 0 2. 0 20.0 1. 0 2. 0 $2, 094 $0 2 e . D ev elop process f

ugiv es v entilation plan 80.0 $250,000 1.0 80. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 f. U pdate fugit iv

e dus t co nt rol plan 10.0 1.0 10. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 g . U pdat e baghous e mo nitoring plan 10.0 1.0 10. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 h . D ev elop bagleak d etec tion sy stem SOP 20.0 1.0 20. 0 0. 0 0 0 0 $0 $0 0 **Re porting Subt** **ota l**  192.5 761. 0 14. 0 812.0 7 81. 2 $79, 988 $266, 218 9. 0 4. Rec ordk eeping Requirement s A. Read ins tructions See 3A $0 0 B. I mplementa ctiv

ities N/A $0 0 C. D ev elop rec ord s yste m N/A $0 0 D. Time to enter inf

ormation E. Rec ords of all inf

o. required by sta ndards (f) 1.0 60.0 60. 0 0. 0 0.0 0. 0 0. 0 $0 $0 0 F. Time to train personnel 20.0 1.0 20. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 G. Time f

or audits N/A 0. 0 0. 0 $0 0 **Re cordke**  **ep ing Subt** **ota l**  61.0 80. 0 2. 0 40.0 1. 0 4. 0 $4, 038 $0 0 **TOTAL** 253.5 841. 0 16. 0 852.0 8. 0 85. 2 $84, 026 $266, 218 9. 0 Tota l Hours Labor Cos t Non-Labor Tot al Summary of

r espondent burden 945 $84, 026 $266, 218 350,244 $ In itial c apit al and star

tu p $0 Annualized Capit al/s ta rtup and O&M $266, 218 N/A = N otApplicable. (a) Cos ts a re based on t he fol lowing hourly rates: te chnical at $71.95, management at $115.94, and clerical at $34.17. (b) One-time activ

ity. There are an es timated 2 existing f erroalloy s p roduc tion f

ac ilities and no new

f acilities are expected. (c ) Weekly method 9, wit h initial tes ts e stimated to occur in Year 2 of

I CR. Assu me s in -hous e readers

. (d) Th e 2 ex istin g plant s w ould be required t o su bm it a n Annual Compliance Cert ific ation at the end of Year 2 of

th e IC R and each year th ereafter. (e) Assu me s th at 2f

ac ilities p er ye ar would hav e tosu bmit a Report of exceedence. (f) Rec ordk eeping requirements begin in Year 2 of I CR cle aranc e period for all existing plants. **TA BLE**  **3 . Y** **EAR 3**  **ANNUAL RES**  **PONDENT BURDEN AND COST OF RE**  **PORTING AND RE CO**  **RDKEEP IN**  **G RE QU**  **IR EM**  **ENT S FOR FE**  **RROALLOYS PRODUCTI**  **ON: FERROMANGANES E**  **AND SILICOMA** **NGANESE**

# 15

Ye ar Te ch nic al H ours Cl eri ca l H ours Managem ent Hours Tota l L abor

Hours Labor Cos t Non-Labor (annual iz ed Capi ta l/Sta rt up and O&M)Cos ts Tota l Cos ts 1 320 32 5 357 $31, 917 $500, 000 $531, 917 2 990 99 12 1, 101 $98, 040 $1, 032, 218 $1, 130, 258 3 852 85 8 945 $84, 026 $266, 218 $350, 244 Tota l 2, 162 216 25 2, 404 $213, 984 $1, 798, 436 $2, 012, 420 Av erage 721 72 8 801 $71, 328 $599, 479 $670, 807 **TA BL**  **E 4.**  **SU MMA** **RY OF**  **ANNUAL R**  **ES PO**  **NDE NT** **B URDEN**  **AND CO**  **ST OF R EP**  **OR TI**  **NG A**  **ND RE**  **CORDKE EP**  **IN G**  **REQ UI**  **REM ENT**  **S FOR FE**  **RRO AL**  **LOY**

**S PR OD**  **UCT IO**  **N: FE**  **RROM ANG**  **ANES E**  **AND SIL**  **IC OM**  **ANGANE SE** 

# 16

**TA BLE 5. YEA** **R 1 A NNUA** **L BURDEN A ND COST TO THE FEDERA** **L GOVERNMENT FOR FERROA LLOYS PRODUCTION: FERROMA** **NGA NESE A** **ND SILICOMA NGA** **NESE** (A) (B) (C) (D) (E) (F) (G) (H)EPA personhours per occurrence No. of

occurrences per plant per ye ar EPA personhours per plant per year Plants per year Technical person-hours per year Managem ent

person-hours per year Clerical personhours per year Cost,$ (a) Activity (C=AxB) (CxD) (Ex0.05) (Ex0.1) Report Review Initial Notification (b) 1.0 1.0 1.0 0.7 0.7 0.0 0.1 $35 Notification of Compliance Status (c) 10.0 1.0 10.0 0.7 6.7 0.3 0.7 $345 Annual Com pliance Certification (d) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $207 Report of Exceedence (e) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $207 Review com pliance m onitoring plans prepared by plants 10.0 0.0 0.0 2.0 0.0 0.0 0.0 $0 TO TAL BURDEN AND COST (SALARY) 15.3 0.8 1.5 $795 (a) Costs are based on the following hourly rates: technical at $53.17, m anagement at $62.90, and clerical at $37.87. Managem ent person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively

. (b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/y r i n Year 1. (c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/y r in Year 1. (d) The affected 2 plants will submit an annual compliance certification each y ear. (e) Assumes that 2 facilities per y ear would have to subm it an exceedance report per y ear. N/A = Not applicable.

# 17

**TA BLE 6. YEA**  **R 2 A NNUA** **L BURDEN A ND COST TO THE FEDERA**  **L GOVERNM ENT FOR FERROA**  **LLOYS PRODUCTION: FERROMA NGA**  **NESE A ND SILICOM**  **AN GA** **NESE** (A) (B) (C) (D) (E) (F) (G) (H)EPA personhours per occurrence No. of

occurrences per plant per year EPA personhours per plant per year Plants per year Technical person-hours per year Management

person-hours per year Clerical personhours per year Cost,$ (a) Activity (C=AxB) (CxD) (Ex0.05) (Ex0.1) Report Review Initial Notification (b) 1.0 1.0 1.0 0.7 0.7 0.0 0.1 $35 Notification of Compliance Status (c) 10.0 1.0 10.0 0.7 6.7 0.3 0.7 $345 Annual Com pliance Certification (d) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $207 Report of Exceedence (e) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $207 Review compliance monitoring plans prepared byplants 10.0 4.0 40.0 2.0 80.0 4.0 8.0 $4,146 TOTAL BURDEN AND COST (SALARY) 95.3 4.8 9.5 $4,940 (a) Costs are based on the following hourlyrates: technical at $53.17, managem ent at $62.90, and clerical at $37.87. Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively

. (b) The affected 2 plants will subm it the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1. (c) The affected 2 plants will subm it the notification of com pliance status, leading to an average annual burden of 0.7 plants/yr in Year 1. (d) The affected 2 plants will subm it an annual com pliance certification each year. (e) Assumes that 2 facilities per y ear would have to submit an exceedance report per y ear. N/A = Not applicable.

# 18

**TA BLE 7. YEA**  **R 3 A NNUA**  **L BURDEN A ND COST**  **TO T HE FEDERA**  **L GOVERNMENT FOR FERROA LLOYS PRODUCTION: FERROMA**  **NGA NESE A** **ND SILICOMA NGA** **NESE** (A) (B) (C) (D) (E) (F) (G) (H)EPA personhours per occurrence No. of

occurrences per plant per ye ar EPA personhours per plant per year Plants per year Te chnical person-hours per year Management

person-hours per year Clerical personhours per year Cost,$ (a) Activity (C=AxB) (CxD) (Ex0.05) (Ex0.1) Report Review Initial Notification (b) 1.0 1.0 1.0 0.7 0.7 0.0 0.1 $35 Notification of Compliance Status (c) 10.0 1.0 10.0 0.7 6.7 0.3 0.7 $345 Annual Compliance Certification (d) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $207 Report of Exceedence (e) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $207 Review compliance m onitoring plans prepared by plants 10.0 0.0 0.0 2.0 0.0 0.0 0.0 $0 TOTAL BURDEN AND COST (SALARY ) 15.3 0.8 1.5 $795 (a) Costs are based on the following hourly rates: technical at $53.17, management at $62.90, and clerical at $37.87. Management person-hours and clerical person-hours are assum ed to be 5 percent and 10 percent of technical person-hours, respectively. (b) T he affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/y r in Year 1. (c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/y r in Year 1. (d) T he affected 2 plants will submit an annual compliance certification each y ear. (e) Assumes that 2 facilities per year would have to submit an exceedance report per year. N/A = Not applicable.

# 19



# Year Technical Hours Clerical Hours Managem ent Hours Total Labor

Hours Labor Cost 1 15 2 1 18 $795 2 95 10 5 110 $4,940 3 15 2 1 18 $795 Total 126 13 6 145 $6,530 Average 42 4 2 48 $2,177 **TA BLE 8. SUM**  **MA RY OF A** **NNUA L BURDEN A** **ND COST TO THE FEDERA**  **L GOVERNMENT FOR FERROA** **LLYS PRODUCTION: FERROM AN**  **GA NES A** **ND SILICOM AN**  **GA NESE** 

# 20

**Attachment 2. Information Requirements**

**– Amendments to the Ferroalloys Production NESHAP**  **Requirement Citation for Existing Sources**  **Citation for New Sources General Provisions Citation**  Emission standards § §63.16 2 3 , 63.1652 § §63.16 2 3 , 63.1652 Operational and work practice standards § §63.16 2 4 , 63.1654 § §63.16 2 4 63.1654

Performance tests § §63.16 2 5 , 63.1 656 § §63.16 2 5 , 63.1656 §63.7 Monitoring § §63.16 2 6 , 63.1657 § §63.16 2 6 , 63.1657 §63.8 Notification § §63.16 2 7 , 63.1658 § §63.16 2 7 , 63.1658 §63.9 Recordkeeping and reporting § §63.16 2 8 , 63.1659, 63.1660 § §63.16 2 8 , 63.1659, 63.1660 §63.10