SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Integrated 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 Integrated 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 Hazardous 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 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 either 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 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, 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.

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 Integrated Iron and Steel Manufacturing Facilities 

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

local, or tribal entities, or by the Federal government. All these facilities are owned and operated 

by privately-owned, for-profit businesses. The ‘burden’ to the Federal Government is attributed 

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

found 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).
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 standard.

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, Section 

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

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

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

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

health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 

CFR Part 63, Subpart FFFFF.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards 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 test, a record of the 
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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 these standards are used to inform the Agency or delegated 

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

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

installed and operated, that leaks are being detected 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 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 its 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, duplication does 

not exist.

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 (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

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

provisions in the standard, is the Enforcement and Compliance History Online (ECHO), which is 

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

collection, maintenance, and retrieval of all compliance data.

Industry trade associations and other interested parties were provided with an opportunity 

to comment on the burden associated with the standards when they were being developed and 
4

further amended, and these standards have been reviewed previously to determine the minimum 

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

American Iron and Steel Institute, at (202) 452-7100, and the 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 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 

promulgated by 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-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 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, 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).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.
5

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 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 Industrial Classification (SIC) code is 3312 (Steel Works, 

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

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 Facilities (40 CFR Part 63, Subpart FFFFF).

A source must make the following notifications:

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(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)
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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 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.
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(ii) Respondent Activities

Respondent Activities

Familiarization with regulatory requirements.

Perform initial performance test, Reference Method 5, 9, or 6071B tests, 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 

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 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, 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 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 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 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 

and 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 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 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 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. Where 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 18,500 hours (Total 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 previouslyapproved 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 $51.79 ($24.66 + 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 associated with the information collection activities in the 

subject standard is 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 (O&M) costs 

are the ongoing costs to maintain monitors and other costs such 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 $67,000

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 of 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 next three years of the ICR is estimated to be $67,000. 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 

$22,800 (rounded).

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)
11

These rates are from the Office of Personnel Management (OPM), 2014 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 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, 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 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.

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:
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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 Annual Responses is 44. 

The total annual labor costs are $1,860,000. Details regarding these estimates 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 because the typical tasks for managers are to review and approve reports. Clerical burdens 
13

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 approved ICR is due to 

an adjustment. In this ICR, we assume all existing respondents will take some time to refamiliarize 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 updated 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 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.
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An agency may not conduct or sponsor, and a person is not required to respond to, a 

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

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the 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 

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

electronically. When in the system, select “search,” then key in the docket ID number identified 

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), 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 Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center 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, NW,

Washington, DC 20503, Attention: Desk Officer 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.
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 

personhours 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 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 

 v. Notification of actual startup 4 1 4 0 0 0 0 $0 
16

 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 hour for Technical labor, and 

$51.79 per hour for Clerical labor. 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.

c

 We have assumed that existing sources have already complied 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.
17

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. We obtained these 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 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.

† 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 

personhours per 

occurrence

No. of 

occurrences 

per plant 

per year

EPA 

personhours per 

plant per 

year 

(C=AxB)

Plants per 

year a

Technical 

personhours per 

year 

(E=CxD)

Management 

person-hours 

per year 

(Ex0.05)

Clerical 

personhours 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 for 

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 conduct performance test for addon 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 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.

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