SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF)

(Renewal), EPA ICR Number 2003.05, OMB Control Number 2060-0517

1(b) Short Characterization/Abstract

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

Iron and Steel Manufacturing were proposed on July 13, 2001 (66 FR 36835), promulgated on 

May 20, 2003 (68 FR 27645), and amended on July 13, 2006 (71 FR 39579). These standards 

apply to new and existing sinter plants, blast furnaces, and basic oxygen process furnace (BOPF) 

shops at integrated iron and steel manufacturing facilities that are major sources of hazardous air 

pollutants (HAPs), or are collocated at major sources. Existing facilities include those that 

commenced construction or reconstruction before July 13, 2001. This information is being 

collected to assure compliance with 40 CFR part 63, subpart FFFFF.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is inoperative. 

These notifications, reports, and records are essential in determining compliance, and are required 

of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

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

affected facility at each plant site, and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 18 respondents per year will be subject to the 

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

All of the integrated iron and steel facilities in the United States are owned and operated by

the integrated iron and steel industry (the “Affected Public”). None of the facilities in the United 
2

States are owned by state, local, tribal or the Federal government. They are privately-owned,

for-profit businesses. The burden to the “Affected Public” is listed below in Table 1: Annual 

Respondent Burden and Cost − NESHAP for Integrated Iron and Steel Manufacturing (40 CFR 

Part 63, Subpart FFFFF) (Renewal). The Federal government burden associated with the review 

of reports submitted by the respondent is shown below in Table 2: Average Annual EPA Burden 

and Cost − NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF)

(Renewal).

The active (previous) ICR had the following Terms of Clearance (TOC):

When this ICR is renewed, EPA should review the respondent

 burden, universe, response number, labor rates, and capital costs

and ensure these estimates have been updated.

EPA has addressed each item of concern by consulting with industry representatives 

regarding the burden associated with this ICR (including universe of affected entities, the number 

of responses, the respondent burden, and capital costs) and updating the labor rates using the most 

recent information available from the Bureau of Labor Statistics.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner or operator subject to any requirement 

of this Act to:

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from integrated iron and steel plants 

cause or contribute to air pollution that may reasonably be anticipated to endanger either public 

health or welfare. Therefore, the NESHAP standards were promulgated for this source category at 

40 CFR part 63, subpart FFFFF.
3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance 

with the applicable regulations which were 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 are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to ensure 

compliance with the standard at all times. During the performance tests, a record of the operating 

parameters under which compliance was achieved may be recorded and used to determine 

compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, that leaks are being detected and repaired, and that the standards 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 

FFFFF.

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 directly to the delegated state 

or local agency. If a state or local agency has adopted their own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published in 

the Federal Register (76 FR 26900) on May 9, 2011. 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 
4

information as reported by industry, in compliance with the recordkeeping and reporting 

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

and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, 

maintenance, and retrieval of all compliance data. The growth rate for the industry 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. In developing this 

ICR, we contacted: 1) the American Iron and Steel Institute, at (202) 452-7100; 2) the Association 

for Iron and Steel Technology, at (724) 814-3062; and 3) the Steel Manufacturers Association, at 

(202)-296-1515.

It is our policy to respond after a thorough review of comments received since the last ICR 

renewal as well as to those submitted in response to the first Federal Register notice. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities 

are continuing to meet the standards. Requirements for information gathering and recordkeeping 

are useful techniques to ensure that good operation and maintenance practices are applied and 

emission limitations are met. If the information required by these standards was collected less 

frequently, the proper operation and maintenance of control equipment and the possibility of 

detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to the 

standards. EPA believes that the five-year records retention requirement is consistent with the Part 

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

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

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

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

In addition, EPA would be prevented from pursuing the violators due to either 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 (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, 1979).
5

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 owners or operators 

of integrated iron and steel manufacturing facilities. The United States Standard Industrial 

Classification (SIC) code for the respondents affected by the standard, which correspond to the 

North American Industry Classification System (NAICS) code, is listed below for this source 

category.

Standard (40 CFR, part 63 subpart FFFFF)

SIC 

Codes

NAICS 

Codes

Integrated Iron and Steel Mills, Steel Companies, Sinter Plants, Blast 

Furnaces, Basic Oxygen Process Furnace Shops 3312 331111

4(b) Information Requested

(i) Data Items

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

Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF).

A source must make the following reports:

Notifications

Applicability 63.5(b), 63.7840(a)

Commencement of construction or reconstruction 63.9(b)(4), 63.7840(a)

Actual startup 63.9(b)(4), 63.7840(a)

Intention to construct/reconstruct 63.9(b)(4)-(5), 63.7840(a)

Compliance dates/extension 63.9(c), 63.7840(a) 

Performance test/opacity observations 63.9(e), 63.7840(a)

Compliance status 63.9(g), 63.7840(a)

Reports

Application for approval of the construction or 

reconstruction of a new major affected source, or 

reconstruction of a major affected source

63.5(d)(6)
6

Reports

Performance test results 63.10(d)(2), 63.5755

Operation and maintenance plan 63.7800(b)

Immediate startup, shutdown, and malfunction report 63.6(e)(3), 63.7841(c)

Periodic startup, shutdown and malfunction reports 63.10(d)(5)(i), 63.7841(c)

Progress reports for compliance extension (if applicable) 63.6(i)

Semiannual report of compliance 63.7841(a)

A source must keep the following records:

Recordkeeping 

Notifications and reports 63.10(b)(2)(xiv), 63.7842(a)(1)

Startup, shutdown, and malfunction plan/events 63.6(e)(3)(iii)-(v), 63.7842(a)(2)

Performance test and opacity observations 63.10(b)(2)(viii), 63.7842(a)(3)

Continuous monitoring systems 63.10(b)(2)(vi)-(xi), 63.8(d)(3), 

63.6(h)(7)(i)-(ii), 63.10(b)(2)(i)-(ii)

Visual observations 63.6(h)(6), 63.7842(c)

Records required to demonstrate continuous compliance 63.10(b)(2)(vii), 63.7842(d)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not widely 

used. At this time, it is estimated that approximately10 percent of the respondents use electronic 

reporting. 

(ii) Respondent Activities

Respondent Activities

Read instructions.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.
7

Respondent Activities

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

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way (e.g., continuous parameter monitoring system). Although personnel at the source 

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

burden associated with monitoring and recordkeeping.

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, 

and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

required to be submitted by industry.

Audit facility records.

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

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard and note the operating conditions under which compliance was achieved. Data 

and records maintained by the respondents are tabulated and published for use in compliance and 

enforcement programs. The semiannual reports are used for problem identification, as a check on 

source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS, which is operated and 

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

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

government-owned facilities. EPA uses OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.
8

The records required by this regulation must be retained by the owner or operator for five

years.

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 operations 

and the types 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 Integrated Iron and Steel 

Manufacturing (40 CFR Part 63, Subpart FFFFF) (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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 18,421 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 
9

Managerial $121.42 ($57.82 + 110%)

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

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 by 110 percent to account 

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

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

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total Capital /

Startup Cost, 

(B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total 

O&M,

(E X F)

Leak detectors $9,000 0 $0 $2,389 18 $43,002

Continuous Opacity 

Monitors $37,000 0 $0 $8,000 3 $24,000

Total $67,002

The total capital/startup costs for this ICR are zero. This is the total of column D in the 

above table.

The total operation and maintenance (O&M) costs for this ICR are $67,002. This is the 

total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry 

over the next three years of the ICR is estimated to be $67,002. These are recordkeeping costs. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA’s overall compliance and enforcement program includes activities such as the

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be 

$22,595.
10

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

Managerial $62.27 (GS-13, Step 5, $38.92 x 1.6)

Technical $46.21 (GS-12, Step 1, $28.88 x 1.6)

Clerical $25.01 (GS-6, Step 3, $15.63 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2011 General Schedule”

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost − NESHAP for Integrated 

Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately 18

existing respondents will be subject to the standard. It is estimated that no additional respondents 

per year will become subject. The overall average number of respondents, as shown in the table 

below, is 18 per year.

The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

Year

(A)

Number of 

New

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(D)

Number of Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 18 0 0 18

2 0 18 0 0 18

3 0 18 0 0 18

Average 0 18 0 0 18

1 New respondent include sources with constructed, reconstructed and modified facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 18.

The total number of annual responses per year is calculated using the following table:
11

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

Notification of compliance status 0 1 0 0

Notification/application of construction 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of performance test and test 

plans 0 1 0 0

Report of performance test results 18 0.4 0 7.2

Report of semiannual compliance 

reports 18 2 0 36

Report of startup, shutdown, 

malfunction 1 1 0 1

Total 44.2

The number of Total Annual Responses is 44 (rounded).

The total annual labor costs are $1,765,120. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost − NESHAP for Integrated Iron and 

Steel Manufacturing (40 CFR Part 63, Subpart FFFFF) (Renewal).

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 18,421 hours at a cost of $1,765,120. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost − NESHAP 

for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF) (Renewal). 

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

information is estimated to average 419 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $67,002. 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 501
12

labor hours at a cost of $22,595. See below Table 2: Average Annual EPA Burden and Cost −

NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF)

(Renewal).

6(f) Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the previous ICR. This is due 

to two considerations: 1) the regulations have not changed over the past three years and are not 

anticipated to change over the next three years; and 2) the growth rate for the industry is very low, 

negative or non-existent, so there is no significant change in the overall burden. However, there is 

an increase in the total labor and Agency costs as currently identified in the OMB Inventory of 

Approved Burdens. This increase is not due to any program changes. The change in cost 

estimates reflects updated labors rates available from the Bureau of Labor Statistics. 

6(g) Burden Statement

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

estimated to average 419 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose or provide information to or 

for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing information; 

adjust the existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA’s 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 ICR under Docket 

ID Number EPA-HQ-OECA-2011-0271. 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 content of the docket, 

and to access those documents in the public docket that are available electronically. When in the 

system, select “search” than 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 Avenue, N.W., 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 

Enforcement and Compliance Docket and Information Center Docket is (202) 566-1752. Also, 

you can send comments to the Office of Information and Regulatory Affairs, Office of 

Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer 
13

for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0271 and OMB 

Control Number 2060-0517 in any correspondence.

Part B of the Supporting Statement

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

information.
14

Table 1: Annual Respondent Burden and Cost – NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63,

Subpart FFFFF) (Renewal)

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read instructions 2 1 2 0 0 0 0 $0

 B. Required activities c, d

 i. Method 5 performance test e40 7.6 304 18 5,472 273.6 547.2 $602,977.74 

 ii. Method 9 performance test e8 3.6 28.8 18 518.4 25.9 51.8 $57,124.21 

 iii. Method 6071B performance test 2 365 730 7 5,110 255.5 511 $563,087.76 

 iv. Startup, shutdown, malfunction plan 40 1 40 0 0 0 0 $0

 v. Inspection and maintenance of capture

 systems and control devices 2 12 24 18 432 21.6 43.2 $47,603.51

 C. Gather existing information See 5D, 5E

 D. Write report c, d

 i. Notification of applicability 2 1 2 0 0 0 0 $0

 ii. Notification of compliance status 2 1 2 0 0 0 0 $0

 iii. Notification of intent to construct a major

 source and review application 4 1 4 0 0 0 0 $0

 iv. Notification of initial construction/

 reconstruction 4 1 4 0 0 0 0 $0

 v. Notification of actual startup 4 1 4 0 0 0 0 $0

 vi. Notification of performance test 4 1 4 0 0 0 0 $0

 vii. Reports of performance test results See 4B, 5E

 viii. Semiannual compliance reports c40 2 80 18 1,440 72 144 $158,678.35 

 ix. Startup, shutdown, malfunction report f4 1 4 1 4 0.2 0.4 $440.77 

Subtotal for Reporting Requirements 14,922.8

4. Recordkeeping Requirements

 A. Read instructions See 4A

 B. Plan activities 10 1 10 0 0 0 0 $0
15

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

 C. Implement activities See 4B

 D. Develop record system N/A

 E. Time to enter and transmit information g3.25 52 169 18 3,042 152.1 304.2 $335,208.02 

 F. Time to train personnel 3 1 3 0 0 0 0 $0

 G. Time for audits N/A

Subtotal for Recordkeeping Requirements 3,498.3

TOTAL LABOR BURDEN AND COST 

(rounded) 18,421 $1,765,120

Assumptions:

a

 We have assumed that there are approximately 18 existing sources currently subject to this rule. There will be no additional new source that will become subject to the 

rule each year over the three-year period of this ICR.

b

 This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per 

hour for Clerical labor. 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 by 110 percent to account for the benefit packages 

available to those employed by private industry.

c

 We have assumed that existing sources have already compiled with initial rule requirements and are in full compliance with periodic requirements including semiannual 

reports. New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices.

d

 Monitoring and recordkeeping of operations for respondents will include monthly inspection of capture and control systems; daily testing of oil content for the sinter 

plant feed (7 plants [from the composite of three samples taken at 8-hour intervals]) to compute the 30-day rolling average oil content for each operating day; and every 

2.5 years, each emission point must be sample by Method 5 for particulate matter and Method 9 for opacity observations to determine the opacity of fugitive emissions.

e

 Based on the average for the 18 respondents, we have assumed that there is an average of 7.6 emission points per respondent that need to be sampled using Method 5 

and 3.6 emission points per respondent to need to be sampled using Method 9.

f

 We have assumed that one respondent per year will have at least one startup, shutdown, or malfunction (SSM) that is not managed according to the SSM plan.

g

 We have assumed that it takes each respondent approximately 3.25 hours per week to record and transmit information.
16

Table 2: Average Annual EPA Burden and Cost − NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, 

Subpart FFFFF) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours 

per plant 

per year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

person-ho

urs per 

year

(Ex0.1)

(H)

Cost, $ b

New Respondents c

i. Notification of compliance status 4 1 4 0 0 0 0 $0

ii. Notification of intent to construct a major

 source and review application 4 1 4 0 0 0 0 $0

iii. Notification of start of construction 2 1 2 0 0 0 0 $0

iv. Notification of actual startup 2 1 2 0 0 0 0 $0

v. Notification of initial performance test

 and test plan 4 1 4 0 0 0 0 $0

Existing Respondents

i. Performance test report for Method 5 and

 Method 9 d 20 0.4 8 18 144 7.2 14.4 $7,462.43

ii. Review semiannual compliance reports e8 2 16 18 288 14.4 28.8 $14,924.85

iii. Review of startup, shutdown, malfunction

 reports e 4 1 4 1 4 0.2 0.4 $207.29

Subtotals Labor Burden and cost 436 21.8 43.6 $22,594.57

TOTAL ANNUAL BURDEN AND COST 

(rounded) 501 $22,595

Assumptions:

a

 We have assumed that there are approximately 18 existing sources currently subject to this rule. There will be no additional new source that will become subject to the 

rule each year over the three-year period of this ICR.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from the 

Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c

 We have assumed that existing sources have to comply with the initial rule requirements. New respondents are required to conduct performance test for add-on control 

equipments, submit initial notifications and prepare startup, shutdown and malfunction (SSM) plans.

d

 Every 2.5 years (or about 0.4 times per year, if average over the three year period of ICR), respondents must sample each emission point using Method 5 for particulate 
17

matter and Method 9 for opacity observations, and submit a report with results.

e

Sources are required to submit semiannual compliance reports and startup, shutdown, and malfunction (SSM) reports if there is an occurrence that is not managed 

according to the SSM plan.