SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Integ rated Iron and Steel Manufacturing Facilities (40 CFR Part 63, Subpart

FFFFF) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for I nte grated Iron and Steel Manufacturing Facilities (40 CFR Part 63, Subpart

FFFFF) (Renewal), EPA ICR Number 2003.06, OMB Control Number 2060

- 0517.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardou s Air Pollutants (NESHAP) for Integrated

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

proposed on July 13, 2001 (66 FR 36835), promulgated on May 20, 2003 (68 FR 27645), and

most

- recently amen ded 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

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

commenced either construction or recons truction before July 13, 2001. This information is being

collected to assure compliance with 40 CFR Part 63, Subpart FFFFF.

In g eneral, all NESHAP standards require initial notification reports , 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, shutdo wn, 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 su bject 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 lea st 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

. Environmen tal Protection Agency (EPA) regional office.

The term “Affected Public” applies to owners or operators of integrated iron and steel

plants , and the ‘burden’ for the Affected Public may be found below in Table 1: Annual

Respondent Burden and Cost

– NESHAP for Inte grated Iron and Steel Manufacturing Facilities

(40 CFR Part 63, Subpart FFFFF) (Renewal) . None of the facilities are owned by either state, or

l ocal

, or tribal entities

, or by t he Federal government. All these facilities are owned and oper ated

by privately

- owned, for

- profit businesses. The ‘ burden ’ to the Federal Government is attributed

entirely to work performed by either F ederal employees or government contractors, and may be

found below in Table 2: Average Annual EPA Burden and Cost

– N ESHAP for Integrated Iron

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

.2

Over the next three years, approximately 18 respondents per year will be subject to the

standard . No additional respondents will become subject to the s tandard.

The Office of Management and Budget (OMB) approved the currently active ICR

without any “Terms of Clearance.”

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, S ection

114(a) states that the Administrator may requir e any owner/operator subject to any requirement

of this Act to:

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

(C) install, us e, 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

Administrat or 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) provid e such other information as the Administrator may

reasonably require.

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

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

health and/ or w elfare. Therefore, th e NESHAP were promulgated for this source category at 40

CFR Part 63, Subpar t FFFFF

.

2(b) Practical Utility/Users of the Data

T he recordkeeping and reporting requirements in the se standards 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 i n legal proceedings.

Performance tests are required in order to determine an affected facility ’ s initial

capability to comply with the emission standar d. Continuous emission monitors are used to

ensure compliance with the standard at all times

. During the performance test

, a record of the3

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

determine compliance in place of a continuous emission monitor.

The notifications requi red in the se standard s are used to inform the Ag ency or delegated

authority when a source becomes subject to the r equirements 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 detect ed and repaired

, and that the standard is 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 an d reporting are required under 40 CFR Part 63, Subpart

FFFFF

.

3(a) Non

- duplication

If the subject standards have not b een delegated, the information is sent directly to the

ap propriate EPA regional office. Otherwise, the information is sent directly to the de legated state

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

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

Administrator in lieu of the report requ ired by the Federal standards. Therefore, duplication does

not exist.

3(b) Public Notice Required Prior to ICR Submiss ion to OMB

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

in the Federal Register (80 FR 32116) o n June 5, 2015

. No comments were received on the

burden published in the Federal Register

.

3(c) Consultations

The Agency has consulted i ndustry 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 the Enforcement and Compliance History Online (ECHO)

, which is

operated and maintained by EPA's Office of Complianc e. ECHO is EPA’s database for the

collection, maintenance, and ret rieval of all compliance data.

In dustry trade associations and other interested parties were provided with an opportunity

to comment on the burden associated with the standard s when they were being developed and4

further amended, and the se standard s ha ve been reviewed previously to determi ne the minimum

information needed for compliance purposes. For the current renewal, EPA contacted both th e

American Iron and Steel Institute

, at ( 202 ) 452

- 7100

, and th e Association for Iron & Steel

Technology

, at (724) 814

- 3000

. No comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that

facilities are cont inuing 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

T hese reporting or recordkeeping requirements do not violate any of the regulations

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

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

notifica tions for at least five years. This is consistent with the General Provisions as applie d 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 whic h the permit program is

based. T he retention of records for five years allow s EPA to establish the compliance history of

a source

, any pattern of non

- compliance

, and to determine the appropria t e level of enforcement

action. EPA has found that the most flagrant violators have violation s extending beyond five

years. 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, C hapter 1, P art 2,

S ubpart 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).

3(g) Sensitive Questions

T he reporting or recordkeeping requirements in the standard do not include s ensitive

questions.5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeepin g and reporting requirements are ow ners or operators

of integrated iron and steel plants. The United States North American Industry Classification

System ( NAICS) code for respondents affected by the standard is 331111 ( Integrated Iron and

Steel Mills, Steel Companies, Sinter Plants, Blast Furnaces, Basic Oxygen Process Furnace

Shops)

. The corresponding Standard Indust rial Classification (SIC) code is 3312 ( Steel Works,

Blast Furnaces (including Coke Ovens), and Rolling Mills )

.

4(b) Information Requested

(i) Data Items

I n this ICR , all the data that is recorded or reported is required b y the NESHAP for

Inte grated Iron and Steel Manufacturing Facilities (40 CFR Part 63, Subpart FFFFF)

.

A source must make the following notifications :

Notification s

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( h ), 63.7840(a)

A source must make the following reports:

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)( 2 )

Performance test results 63.10(d)(2),

63. 7840(e)(2)6

Reports

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) (11)

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)

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 r espondents 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.7

(ii) Respondent Activities

Respondent Activities

Familiarization with regulatory requirements.

Perform initial performance test, Reference Metho d 5, 9, or 6071B test s , 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, acq uiring, 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.

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 respon d 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, analysis,

storage, and distribution of the required information :

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, inc luding performance test reports and excess emissions

reports, required to be submitted by industry.8

Agency Activities

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) 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 properly installed and operated. Performance

test reports are used by the Agency to discern a source ’ s initial capabi lity 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 compli ance and

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

source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the

ICIS Air database

, which is operated and maintained by EPA's Office of Compliance. ICIS is

EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial

an d government

- owned facilities. EPA uses ICIS 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.

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

years.

5(c) Small Entity Flexibility

The majority of the respondents are large enti ties (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 ne eded to ensure compliance and, therefore, cannot reduce th em 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 Facilities (40 CFR Part 63, Subpart FFFFF) (Renewal )

.9

6. Estimating the Burden and Cost of the Collection

Table 1 below documents the computation of individual burdens for the recordkeeping

and reporting requirements applicable to the industry fo r the subpart in cluded in th is ICR. The

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

concept of burden unde r the Paperwork Reduction Act. Where appropriate, specific tasks and

major ass umptions have been identified. Responses to this information collection are mandato ry.

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 requirement s is estimated to be 18,500 hours ( Total Labor Hours from Table 1).

T hese hours are based on Agency studies and background documen ts from the development of

the regulation, Agency knowled ge and experience with t he 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:

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 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 a ssociated with the information collection activities in the

subject standard is both labor costs

, which are addressed elsewhere in this ICR

, and the costs

associat ed with continuous monitoring. The capital/startup costs are one

- time costs when a

facility beco mes subject to the regulation. The annual operation and maintenance (O&M) costs

are the ongoing costs to maintain monitors and other costs su ch as photocopying and postage.10

(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 1 $37,000 0 0 $8,000 3 $24,000

Total 2 $67,00 0

1 We assume 3 respondents have continuous opacity monitors.

2 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are zero

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $67,000

. This is the

total of column G.

The average annual cost for both capital/startup and operation and maintenance

costs to industry over the ne xt three years of the ICR is estimated to be $67,000. These are

recordkeeping cost s.

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and e nforcement program i ncludes activities such as the

examination of records maint ained 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

$ 22,800 (rounded)

.

This cost is based on the average hourly 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% )11

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 governme nt 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 Facilities (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, approximatel y

18 existing respondents w ill be subject to the standard. It is estimated that no additional

respondents per year will become subjec t. The overall average number of responden ts, as shown

in the table below, is 18 per year

.

The number of respondents is calculated using the following table that 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 respondents include sources with constructed, reconstructed

, and modified affected facilities.

C olumn 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:12

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 applicability 0 1 0 0

Notification of compliance status 0 1 0 0

Notification of intent to construct

a major source and review

application 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of performance test 0 1 0 0

Report of performance test results 18 0.4 0 7.2

Semiannual compliance reports 18 2 0 36

Startup, shutdown, and

malfunction report 1 1 0 1

Total 44

Note: We assume respondents submit performance test reports once every 2.5 years; therefore, the reporting

frequency is 1 / 2.5 = 0.4.

The number of Total Ann ual Responses is 44.

The total annual labor costs are $1,860,000

. Details regarding these esti mates may be

found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Integrated Iron and

Steel Manufacturing Facilities (40 CFR Part 63, Subpart FFFFF) (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 , respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 18,500 hours

. Details regarding these estimates may be

found in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Integrated Iron and Steel

Manufacturing Facilities (40 CFR Part 63, Subpart FFFFF) (Renewal )

.

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks b ecause the typical tasks for managers are to review and approve reports. Clerical burdens13

are assumed to take 10% of the time required for technical tasks because the typical duties of

clerical staff are to proofread the reports, make copies

, and maintain records.

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

information is estimated to average 420 hours per response

.

The total annual capital/startup and O&M costs to the regulated entity are $67,000

. 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 the next three years is estimated to be

501 labor hours at a cost of $22,800 . See below Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Integrated Iron and Steel Manufacturing Facilities (40 CFR Part 63, Subpart

FFFFF) (Renewal)

.

We assume that burdens for managerial tasks take 5% of the time required for technical

tasks because the typical 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 typical duties of

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

The increase in respondent labor burden from the most recently appro ved ICR is due to

an adjustment

. In this ICR, we assume all existing respondents will take some time to re

familiarize with the regulatory requirement. This assumption results in a small increase in labor

hours and costs. The respondent labor costs also increased due to use of more update d labor

rates. The total estimated cost, including capital and O&M costs, have also been rounded to

three significant figures. The rounding results in a small apparent decrease in the total O&M

cost.

6(g) Burden Statement

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

is estimated to average 420 hours per response. “ Burden ” means the total time, effort, or

financial resources expended by persons to generate, maintain, retain, or disc lose 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 systems for the purposes of collecting,

validating, and verifying information, processing an d 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.14

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

collection of information unless it displa ys a valid OMB Control Num ber. 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 b urden, including the

use of automated collection techniques, EPA has established a public docket for this ICR under

Docket ID Number EPA

- HQ

- OECA

- 20 11

- 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

contents of the docket, and to access those doc uments in the public docket that are available

electronically. When in the system , 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 a nd Information Center in the EPA Docket Center (EPA/DC), WJC 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 Fri day, excluding legal

holidays. The t elephone number for the Reading Room is (202) 566

- 1744, and the telephone

number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW,

Washington, DC 20503, At tention: Desk Officer for EPA. Please include the EPA Docket ID

Number EPA

- HQ

- OECA

- 2011

- 0271 and OMB Control Numbe r 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.15

Table 1 : Annual Respondent Burden and Cost

– NESHAP for Integrated Iron and Steel Manufacturing Facilities (40 CFR Part

63, Subpart FFFFF) (Renewal )

Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Person

hours per

occurrence No. of

occurrences

per

respondent

per year Person

hours per

respondent

per year

(C=AxB) Respondents

per year a Technical

person

hours per

year

(E=CxD) Management

person hours

per year

(Ex0.05) Clerical

person

hours per

year

(Ex0.1) Total Cost

Per year b

1. Applications N/A

2. Survey and Studies N/A

. Reporting Requirements

A. Familiarize with rule requirements 2 1 2 18 36 1.8 3.6 $4,163

B. Required activities c, d

i. Method 5 performance test e 40 7.6 304 18 5,472 273.6 547.2 $632,812.18

ii. Method 9 performance test e 8 3.6 28.8 18 518.4 25.92 51.84 $59,950.63

iii. Method 6071B performance test 2 365 730 7 5,110 255.5 511 $590,948.51

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 $49,958.86

C. Gather existing information See 4D, 4E

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 t o 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

v. Notification of actual startup 4 1 4 0 0 0 0 $016

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

vii. Reports of performance test results See 3B, 4E

viii. Semiannual compliance reports c 40 2 80 18 1,440 72 144 $166,529.52

ix. Startup, shutdown, malfunction report f 4 1 4 1 4 0.2 0.4 $462.58

Subtotal for Reporting Requirements 14,964 $1,504,826

4. Recordkeeping Requirements

A. Familiarize with rule requirements See 3A

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

C. Implement activities See 3B

D. Develop record system N/A

E. Time to enter and transmit information g 3.25 52 169 18 3,042 152.1 304.2 $351,793.61

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 $351,794

TOTAL LABOR BURDEN AND COST

(rounded † ) 18,500 $1,860,000

Capital and O&M Cost † $67,000

GRAND TOTAL † $1,930,000

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: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per h our for Technical labor, and

$51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bur eau 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 increa sed by 110 percent to account

for the benefit packages available to those emp loyed by private industry.

c We have assumed that existing sources have already complied with initial rule requirements and are in full compliance with pe riodic requirements including

semiannual reports. New respondents would have to comply with the ini tial rule requirements including notifications and performance tests for add

- on control

devices.17

d Monitoring and recordkeeping of operations for respondents will include monthly inspection of capture and control systems; da ily 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 t hat need to be sampled using

Method 5 and 3.6 emission points per respondent to need to be sampled using Method 9. We obtained th ese estimates from the previous ICR renewal.

f We have assumed that one respondent per year will have at least one startup, shutdown, or malfunction (SSM) that is not manag ed

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.

† Totals have been rounded to 3 significant figures. Figures may not add exactly

due to rounding.18

Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Integrated Iron and Steel Manufacturing Facilities (40 CFR

Part 63, Subpart FFFFF) (Renewal)

Activity (A) (B) (C) (D) (E) (F) (G) (H)

EPA

person

hours per

occurrence No. of

occurrences

per plant

per year EPA

person

hours per

plant per

year

(C=AxB) Plants per

year a Technical

person

hours per

year

(E=CxD) Management

person

- hours

per year

(Ex0.05) Clerical

person

hours per

year (Ex0.1) 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 0 0 0 $0

i. Performance test report for Method 5

and Method 9 d 20 0.4 8 18 144 7.2 14.4 $7,536.96

ii. Review semiannual compliance

reports e 8 2 16 18 288 14.4 28.8 $15,073.92

iii. Review of startup, shutdown,

malfunction reports e 4 1 4 1 4 0.2 0.4 $209.36

Subtotals Labor Burden and cost 501 $22,820

TOTAL ANNUAL BURDEN AND

COST (rounded † ) 501 $22,800

Assumptions:19

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 hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 f or

Managerial (GS

- 13, Step 5, $39.31 x 1.6), $46.67 for Technical (GS

- 12, Step 1, $29.17 x 1.6) and $25.25 Clerical (GS

- 6, Step 3, $15.78 x 1.6). These rates are

from the Office of Personnel Management (OPM), 2014 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 con duct performance test for add

on control equipment , submit initial notifications and prepare startup, shutdown and malfunction (SSM ) plans.

d Every 2.5 years (or about 0.4 times per year, if averaged over the three

- year period of ICR), respondents must sample each emission point using Method 5 for

particulate matter and Method 9 for opacity observations, and submit a report with res ults.

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.

† Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.