**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Ferroalloys Production Area Sources**  **(40 CFR Part 63, Subpart YYYYYY) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Ferroalloy s Production Area Sources (Renewal), EPA I CR Number 2303.04 , OMB Control Number 2060

- 0625

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Ferroallo ys Production Area Sources were proposed on September 15, 2008 (73 FR 53163) and promulgated on December 23, 2008 (73 FR 78637). These regulations apply to existing and new ferroalloy production facilities that are an area source of hazardous air pollutant (HAP) emissions. A ferroallo ys production facility manufactures silicon metal, ferrosilicon, ferrotitanium using the aluminum reduction process, ferrovanadium, ferromoly bdenum, calcium silicon, silicomang anese zirconium, ferrochrome silicon, silvery iron, high

- carbon ferrochrome, charge chrome, standard ferromanganese, ferromanganese silicon, calcium carbi d e or other ferroalloy products using electrometallurgical operations including electric arc furnaces (EA Fs) or other reaction vessels. New facilities include th ose that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63 , Subpart YYYYYY

. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operato rs 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Over the next three years, an average of 10 respondents per year will be subject to 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. The require d annual reports are used to determine periods of excess emi ssions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “Terms of Clearance”.2

**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 source s 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. Inaddition, 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 Admini strator may reasonabl y require. In the Administrator's judgment, HAP emissions from ferroallo ys production area sources 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 YYYYYY

. **2(b) Practical Utility/ Users of the Data**  The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which w ere promulgated in acco rdance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. 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. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the re quirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , leaks are being detected and repaired , and the standard is being met. The performance test may

also be observed.3

The require d annual 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 3(a) Nonduplication**  If the subject standards have not been delegated, the in formation is sent directl y 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 Federal standards, a c opy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y 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 I CR was published in the Federal Register ( 79 FR 30117 ) on May 27, 2014

. No comments were received on the burden published in the Federal Register. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the indus try is 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 I CR, we contacted Metallurg Vanadium at (740) 432

- 6534

. 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 f irst Federal Register n otice. Inth is case, no comments were received. **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 are4

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 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 b y OMB under 5 CFR Part 1320, Section 1320.5. Th ese 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 ye ar records retention requirement is consistent with the Part 70 permit program and the five ye ar statute of limitations on whic h the permit program is based. The retention of records for five ye ars allow s 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 vio lations extending beyond five ye ars. 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 b y 43 FR 40000, September 8, 1978; 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 4(a)**  **Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are ferroalloys production facilities . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards and the corresponding North American Industry Classification System (NAI CS ) codes are listed in the table below.
**Standard (40 CFR**  **P art 63**  **, S**  **ubpart YYYYYY )**  **SIC Codes NAICS Codes**  Primary Smelting and Refining of Nonferrous Metal (except Copper and Aluminum) 3339 3314195

Electrometallurgical Ferroalloy Product 3313 331112 All Other Basic Inorganic Chemical Manufacturing 2819 and 2869 325188 **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required by the NESHAP for Ferroalloy s Production Area Sources. A source must make the following reports:
**Notification s**  Notification of applicability 63.9(b)(2) , 63.11529(a) Notification of construction/reconstruction 63.9(b)(5) Notification of special compliance requirements 63.9(d) Notification of performance test 63.9(e) Notification of opacity/VE observations 63.9(f) Additional CMS notifications 63.9(g) Notification of compliance status 63.9(h) , 63.11529(b) Notification of changes in information 63.9(j)
**Reports** SSM plan 63.6(e)(3) Bag leak detection sy stem monitoring plan 63. 11527 ( a)( 5 ) CMS quality

control plan 63. 8 ( d) CMS performance evaluation test plan 63.8(e)(3 ) CMS performance evaluation/report 63.8(e)(5) SSM report 63. 6 (e)( 3 ) Excess emissions reports 63.10(e)(3) Annual compliance certifications 63.11529(c) A source must keep the following records:6 **Recordkeeping** Records of notifications 63.10 , 63.11529(d)(1) Records that demonstrate continuous compliance 63.10 , 63.11529(d)(2) Monitoring information 63.10 , 63.11529(d)(2) 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. **(ii) Respondent Activities Respondent Activities**  Familiarization with the regulatory requirements. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test, Reference Method 22/9(c) test, and repeat performance tests if necessary

. Write the notif

ications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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.7

**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. Input, anal yz e, and maintain data in Integrated Compliance Information System (I CI S) and ECHO. **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y with the emission standard (note the operating conditions under which compliance was achieved)

. Data and records m aintained b y the respondents are tabulated and published for use in compliance and enforcement programs. The annual 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 reported b y state and local governments in the IC IS Air database which is operated and maintain ed by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local and st ate regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) S mall Entity Flexibility**  The majority

of respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations8

and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **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 Ferroallo ys Production Area Sources (Renewal)

. **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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paper work Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 345 ( Total Labor Hours from Table 1). These hours are based on Agency

studies and background documents from the development o f 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 I CR uses the following labor rates: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**9

The only costs to the regulated industry resulting from information collection activities required b y 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 th e regulations are labor costs. There are no capital/startup or operation and maintenance costs. **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. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of so urces 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 $1,256

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 Cos t

– NESHAP for Ferroallo ys Production Area Sources (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 10 existing respondents will be subject to the st andard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 10 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports10 **Number of Respondents**

Year (A) Number of Ne w 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 2 (E)

Number of Respondents (E=A+B+C

- D)

1 0 10 0 0 10 2 0 10 0 0 10 3 0 10 0 0 10 Average 0 10 0 0 10 1 New respondents include sources with constructed, reconstructed and modified affected facilities. 2 C olumn D is subtracted to avoid double

- counting respondents

. The total number of annual responses per ye ar 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

One

- time initial notification 0 1 0 0 One

- time notifications of compliance status 0 1 0 0 Annual compliance certifications 10 1 0 10 Annual reports of exceedances 2 1 0 2 Total 12 The number of Total Annual Responses is 12. The total annual labor costs are $35,000

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Ferroalloy s Production Area Sources (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, respectivel y, and summarized below.11 **(i) Respondent Tally** The total annual labor hours are 350

. Details regarding these esti mates may be found in Table 1. Annual Respondent Burden and Cost

– NESHAP for Ferroallo ys Production Area Sources (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the repor ts, make copies and maintain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 30 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are zero . 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 28 labor hours at a cost of $1,300

. See Table 2: Average Annual EPA Burden and Cost

– NESHAP for Ferroalloy s Production Area Sources (Renewal)

. **6(f) Reasons for Change in Burden** There is a slight increase of five hours in the total estimated respondent burden compared with the I CR current approved by OMB. This is due to the rounding of estimates. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 30 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide informati on to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing infor mation; adjust the existing way s to compl y 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 trans mit 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 provided12

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 I CR under Docket ID Number EPA

- HQ

- OECA

- 201 4

- 0099

. An electro nic 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 sy stem , 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 Av e., 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket ce nter i s (202) 566

- 1927

. Also, you can send comments to the Office of In formation 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 E PA

- HQ

- OECA

- 20 1 4

- 0099 and OMB Control Number 2060

- 0625 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.13

**Table 1: Annual Respondent Burden and Cost**

**– NESHAP for Ferroalloys Production Area Sources (Renewal)** 

REPORTING/RECORDKEEPING REQUIREMENT (A) (B) (C) (D) (E) (F) (G) (H)
Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent Respondents

per year Technical

person hour per year Management

person - hour per year Clerical

person hour per year Cost, $ (a)
(A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10 1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, & Utilization of Tech. & Sy stems 40 1 40 0 0 0 0 $0 4. Reporting Requirements A. Read instructions (b) 4 1 4 0 0 0 0 $0 B. Required Activities One

- time activity, Initial control device Method 22 Planning N/A One

- time activity, Initial control device Method 22 Test N/A Periodic control device Method 22 2 2 4 19 76 3.8 7.6 $8,789.06 Retest control device 2 1 2 1 2 0.1 0.2 $231.29 Weekly VE check (19 control devices) 0.1 52 5.2 19 98.8 4.94 9.88 $11,425.78 One

- time activity, initial building opacity Method 9 (c) N/A Periodic (semi

- annual) building VE Method 22 2 2 4 10 40 2 4 $4,625.82 Retest building opacity Method 9 10 0 0 0 $0 C. Create information See 4B D. Gather existing information See 4B E. Write Report See 4B Initial Notification 2 1 2 0 0 0 0 $0 Notification of Compliance Status 4 1 4 0 0 0 0 $0 Annual Compliance Certification (d) 4 1 4 10 40 2 4 $4,625.82 Report of Exceedances (e) 2 1 2 2 4 0.2 0.4 $462.58 **Reporting Subtotal 300**  **$30,160.35**14

REPORTING/RECORDKEEPING REQUIREMENT (A) (B) (C) (D) (E) (F) (G) (H)
Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent Respondents

per year Technical

person hour per year Management

person - hour per year Clerical

person hour per year Cost, $ (a)
(A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10 5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities See 5E C. Implement activities See 5E D. Develop record system See 5E E. Time to enter information Records of all info. required by standards (f) 0.3 12 3.6 10 36 1.8 3.6 $4,163.24 F. Time to train personnel N/A G. Time to adjust existing ways to comply w/ prev. appl. req. N/A H. Time to transmit or disclose information (g) 0.3 1 0.3 10 3 0.15 0.3 $346.94 I. Time for audits N/A **Recordkeeping Subtotal 45**  **$4,510.17 Total Labor Burden and Cost**  **345 $34,670.52**  Capital and O&M Cost $0 **GRAND TOTAL 1,2**  **$34,671** Assumptions: (a) Costs are based on the following 2014 OPM General Schedule hourly rates: technical at $103.97, management at $129.93, and clerical at $51.79. (b) One

- time activity. There are an estimated 10 existing ferroalloys production facilities and no new facilities are expected. (c)One

- time activity. Assume the facilities hire a contractor. (d) The 10 existing plants would be required to submit and Annual Compliance Certification at the end of Year 1 of the ICR an d each year thereaf ter. (e) Assumes that 2 facilities per year would have to submit a report of exceedance

. (f) Recordkeeping requirements begin in Year 1 of ICR clearance period for all existing plants.15

(g) Transmittals would include Annual Compliance Certifications for 10 plants. N/A = Not Applicable. Note: Totals in the text have been rounded to 3 significant values. Figures may not add exactly due to rounding.16

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Ferroalloys Production Area Sources (Renewal)** 

REPORTING/RECORDKEEPING REQUIREMENT (A) (B) (C) (D) (E) (F) (G) (H) Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent Respondents

per year Technical

person hours Managerial

person hours Clerical

person hours Cost, $

(a)
(A) x (B) (C) x (D) (E) x 0.05 (E) x 0.10 Report Review: Initial Notification of applicability (b) 1 1 1 0 0 0 0 $0 Notification of Compliance Status (c) 2 1 2 0 0 0 0 $0 Annual Compliance Certification (d) 2 1 2 10 20 1 2 $1,046.80 Annual Report of Deviations (e) 2 1 2 2 4 0.2 0.4 $209.36 **GRAND TOTAL (rounded) 28**  **$1,256** Assumptions: (a) Costs are based on the following 2014 OPM General Schedule hourly rates: technical at $46.67, management at $62.90, and clerical at $25.25. Management person - hours and clerical person

- hours are assumed to be 5 percent and 10 percent of technical person

- hours, respectively. (b) All 10 plants have submitted initial noti fication during the initial compliance period. (c) All 10 plants have submitted the notification of compliance status during the initial compliance period. (d) All 10 plants will submit an annual compliance certification each year. (e) Assumes that 2 facilities per year would have to submit an exceedance report per year. N/A = Not applicable
Note: Totals in the text have been rounded to 3 significant values. Figures may not add exactly due to rounding.