1 **SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **National Emission Standards for Hazardous Air Pollutants for Ferroalloys Production Area Sources**  **(40 CFR P art**  **63, S ubpart**  **YYYYYY) (Renewal) 1. Identification of the Information**  **Collection 1(a) Title of the Information Collection**  **NESHAP for Ferroalloys P roduction Area Sources (40 CFR**  **Part 63, Subpart YYYYYY) (Renewal)**  **, EPA ICR N**  **umber 2303.03, OMB Control Number 2060**
**- 0625.**  **1(b) Short Characterization/Abstract** The National Em ission Standards for Hazardous Air Pollutants (NESHAP) for the Ferroallo ys Production Area Sources ( 40 CFR P art 63, S ubpart YYYYYY ) were proposed on September 15, 2008 (73 FR 53163) , and promulgated on December 23, 2008 (73 FR 78637)

. These regulations ap ply

to existing and new ferroalloys production facilities. 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/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 s ys tem 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 directl y to the United States Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 10 respondents per ye ar will be subject to the standard, and no additional respondents per year will become subject to the standard. The Office of Management and Budget (OMB) approved the currentl y active Information Collection Request (I CR) without any “Terms of Clearance.” All 10 ferroallo ys production facilities in the United States are owned and operated by the ferroalloy s production industry (the “Affected Public”). All of these facilities are privately

owned, for profit businesses; none of them are owned by state, local, tribal or the Federal government. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Ferroalloy s P roduction Area Sources (40 CFR Part2

63, Subpart YYYYYY) (Renewal)

. The burden to the “Federal Government” is attributed entirely to work performed by

federal employees or government contractors; this burden may be found below in Table 2: Annual Agency Burden and Cost

- NESHAP for Ferroallo ys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (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 reduc tion. 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 re cords 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 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 NES HAP was 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 where pro mulgated in accordance 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 delegated3

authority when a source becomes subject to th e requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated and/or 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. Non**
**- duplication,**  **Consultations, and Other Collection Criteria** The requested recordkeeping and reporting are required under (40 CFR part 63, subpart YYYYYY). **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information 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 cop y 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 No tice 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 (76 FR 26900) on May 9, 2011. No comments were received on the burden published in the Federal Regis ter. **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. 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. In developing this I CR, we contacted the Globe Metallurgical In c orporated at (740) 984

- 2 361, the Langeloth Metallurgical Company at (724) 947

- 2201 , and the Metallurg Vanadium at (740) 432

- 6534

. N o comments were received on this I CR

. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well a s those submitted in response to the first Federal Register notice. In this case, no comments were received.4

**3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are conti nuing 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 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. 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

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars 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 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 p olicies 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, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 19 79). **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 Standard Industrial Classification (SI C ) c odes and the corresponding North American Industry

Classification Sy stem (NAICS ) for the respondents affected by the standards are listed in the table below

.5

**Standard (40 CFR Part 63, Subpart YYYYYY) SIC Codes**  **NAICS Codes** Primary Smelting and Refining of Nonferrous Metal (except Copper and Aluminum ) 3339 331419 Electrometallurgical Ferroalloy Product Manufacturing 3313 3 31112 All Other Basic Inorganic Chemical Manufacturing 2819 and 2869 3251 88 **4(b) Information Requested (i) Data Items**  In this ICR, all the data that is recorded or reported is required b y NESHAP for Ferroallo ys P roduction Area Sources (40 CFR Part 63, Subpart YYYYYY). A source must make the following reports:

**Notifications** Notification of applicability 63.9(b)(2) 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 o f compliance status 63.9(h) Notification of changes in information 63.9(j)
**Reports** Reports of exceed e nces N/A Semiannual monitoring reports N/A Initial/repeat performance tests N/A Quality assurance test plan N/A CMS performance evaluation/report 63.8(e)(5) SSM reports 63.6(e)(3) Excess emissions reports 63.10(e)(3) Annual compliance certifications N/A6

A source must keep the following records: **Recordkeeping** Records of notifications 63.10 Records that demonstrate continuous compliance 63.10 Monitoring information 63.10 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 sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 2 0 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. 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 notifications 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. Adjust the existing way s to comply with an y previously applicable instructions and requirements.7 **Respondent Activities** Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. **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, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. 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 the Online Tracking Information Sy stem (OTI S). **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 dis cern a source’s initial capability to compl y with the emission standard. 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.
In formation contained in the reports is entered into the OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars.8

**5(c) Small Entity Flexibility** The majority

of the 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 operation s 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 below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Ferroallo ys Production Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal). **6. Estimating th e 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 each subpart included in this I CR. The individual burdens are expressed under stan dardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major ass umptions 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 3 4 5 ( Tot al 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 I CR uses the following labor rates: Managerial $121.42 ($57.82 + 110%) Technical $99.14 ($47.21 + 110%) Clerical $49.81 ($23.72 + 110%)9

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “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** 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 the regulations is 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 maintained by the respondents, periodic inspection o f 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 $1,757. This cost is based on the average hourl y labor rate as follows: Manag erial $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), 2011 General Schedule, which excludes locality , rate s 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: Annual Agency Burden and Cost

- NESHAP for Ferroallo ys P roduct ion Area Sources (40 CFR Part 63, Subpart YYYYYY) (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 wi ll be subject to the standard. 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.10

The number of respondents is calculated using the follow ing 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 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 10 0 0 10 2 0 10 0 0 10 3 0 10 0 0 10 Average 0 10 0 0 10 1 New respondent 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 ye ar period of this ICR is 10. 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= ( B x C )+ D

One

- time initial notification 10 1 0 10 One

- time notifications of compliance status 10 1 0 10 Annual compliance certifications 10 1 0 10 Annual reports of exceedances 2 1 0 2 TO TAL 32 The number of Total Annual Responses is 32.11

The total annual labor costs are $3 3 , 035 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Ferroalloy s P roduction Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal). There are no capital/startup or operation and maintenance costs. The average annual Agency burden and cost over the next three years is estimated to be 39 labor hours at a cost of $1,75 7. See below Table 2: Annual Agency Burden and Cost

- NESHAP for Ferroalloy s P roduction Area Sources (40 CFR Part 63, Subpart YYYYYY) (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 (below), respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 345 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Ferroalloy s P roduction Area Sources (40 CFR Part 63, Subpart YYYYYY) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of info rmation is estimated to average 1 1 hours per response. There are no capital/startup or operation and maintenance costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 39 labor hours at a cost of $1,757. See below Table 2: Annual Agency Burden and Cost

- NESHAP for Ferroalloy s P roduction Area Sources (40 CFR Part 63, Subpart YYYYYY) (Rene wal)

. **6(f) Reasons for Change in Burden** There is a decrease in respondent labor and cost from the most recentl y approved ICR

. The decrease is due to a reduction in initial compliance costs as existing respondents are already expected to be in compliance with the regulations. However, there is an increase in Agency costs due to an adjustment in labor rates

. The labor rates have increase d over the past three ye ars and the cost calculations in this I CR have been updated to reflect the most recent labor rates. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 1 hours per response. Burden means the total time, effort, or financial12

resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

a pplicable 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 co nduct 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 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

–2011

–0236. 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 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 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center is (202) 566

- 17 52 . Also, you can send comments to the Office of In formation and Regulatory Aff airs, 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

–2011

–0236 and OMB Control Number 2060

–0625 in any correspondence. **Part B of the Suppor ting 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 (40 CFR Part 63,**  **Subpart YYYYYY) (Renewal)**

REPORTING/RECORDKEEPING REQUIREMENT (A) Person

hours per occurr e nce (B)

No. of occurrences per respondent per year (C)

Person

hours per respondent (A) x (B) (D)

Respondents per year (E)

Technical person hour per year (C) x (D) (F)

Management person - hour per year (E) x 0.05 (G)

Clerical person hour per year (E) x 0.10 (H)

Cost, $ (a)

1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, & Utilization of Tech. & Systems 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 $8,374.6 0 Retest control device 2 1 2 1 2 0.1 0.2 $220.3 8 Weekly VE check (19 control devices) 0.1 52 5.2 19 98.8 4.94 9.88 $ 10 , 886

. 96 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 $4,407. 68 Retest building opacity Method 9 10 0 0 0 $0 C. Create information See 4B D. Gather existing information See 4B14

**Table 1. Annual Respondent Burden and Cost**
**- NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63,**  **Subpart YYYYYY) (Renewal)**

REPORTING/RECORDKEEPING REQUIREMENT (A) Person

hours per occurr e nce (B)

No. of occurrences per respondent per year (C)

Person

hours per respondent (A) x (B) (D)

Respondents per year (E)

Technical person hour per year (C) x (D) (F)

Management person - hour per year (E) x 0.05 (G)

Clerical person hour per year (E) x 0.10 (H)

Cost, $ (a)

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 $4,407. 68 Report of Exceedencess (e) 2 1 2 2 4 0.2 0.4 $440.7 6 Reporting Subtotal 2 99.92 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 $3, 966.92 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 $ 330.57 I. Time for audits N/A Recordkeeping Subtotal 44.8515

**Table 1. Annual Respondent Burden and Cost**
**- NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63,**  **Subpart YYYYYY) (Renewal)**

REPORTING/RECORDKEEPING REQUIREMENT (A) Person

hours per occurr e nce (B)

No. of occurrences per respondent per year (C)

Person

hours per respondent (A) x (B) (D)

Respondents per year (E)

Technical person hour per year (C) x (D) (F)

Management person - hour per year (E) x 0.05 (G)

Clerical person hour per year (E) x 0.10 (H)

Cost, $ (a)

**GRAND TOTAL (rounded)**  **344.77 345 (rounded)**  **$3 3**  **, 035** 
Assumptions: (a) Costs are based on the following hourly rates: technical at $99.14, management at $121.42, and clerical at $49.81. (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 and each year thereafter. (e) Assumes that 2 facilities per year would have to submit a report of exceedence. (f) Recordkeeping requirements b egin in Year 1 of ICR clearance perio d for all existing plants. (g) Transmittals would include Annual Compliance Certifications for 10 plants. (h) The total annual number of response is calculated by summing the produc t of columns B and D for each of the reports listed in 4B. N/A = Not Applicable.16

**Table 2: Annual Agency Burden and Cost**
**- NESHAP for Ferroalloys Production Area Sources (40 CFR Part 63,**  **Subpart YYYYYY) (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 3.3 3.3 0.17 0.33 $171. 3 2 Notification of Compliance Status (c) 2 1 2 3.3 6.6 0.33 0.66 $342.0 5 Annual Compliance Certification (d) 2 1 2 10 20 1 2 $1,036.49 Annual Report of Deviations (e) 2 1 2 2 4 0.2 0.4 $207. 29 **SUBTOTAL ANNUAL BURDEN 33.9**  **1.7 3.39**  **$1,75 7**  **GRAND TOTAL (rounded)**  **3 9** 
(a) Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01. 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 will submit the initial notification, leading to an average annual burden of 3 plants/yr. (c) All 10 plants will submit the notification of compliance status, leading to an average annual burden of 3 plants/yr. (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