SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(Renewal) 

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(Renewal), EPA ICR Number 2267.03, OMB Control Number 2060-0605

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron and 

Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) with the final rule published on 

January 2, 2008 (73 FR 225). Potential respondents are owners or operators of any existing or 

new iron or steel foundry that is an area source of hazardous air pollutants (HAP) emissions. 

Research and development facilities are not covered by the rule. Foundries covered by the rule 

would not be required to obtain a Title V operating permit.

There are different requirements for foundries based on size. Small iron and steel 

foundries are required to comply with pollution prevention management practices for scrap 

materials, the removal of mercury switches, and binder formulations. Large iron and steel 

foundries are required to comply with the same pollution prevention management practices as 

small foundries in addition to emissions limitations for melting furnaces and foundry operations. 

Existing foundries with an annual metal melt production greater than 20,000 tons and new 

foundries with an annual metal melt capacity greater than 10,000 tons are classified as large 

foundries. Existing foundries with an annual metal melt production of 20,000 tons or less and 

new foundries with an annual metal melt capacity of 10,000 tons or less are classified.

For metallic scrap, the pollution prevention management practices require foundries to 

purchase (or otherwise obtain) the motor vehicle scrap only from scrap providers participating in 

an EPA-approved program for the removal of mercury switches or to comply with alternative 

provisions. The requirements for binder formulations require foundries to use on one type of 

production line chemical formulations that do not contain methanol as a specific ingredient of the 

catalyst formulation. The management practices also include a pollution prevention initiative to 

encourage foundries to investigate and switch to non-HAP binders and coating materials by

requiring records of the annual quantity and composition of each HAP-containing chemical 

binder or coating material used to make molds and cores. The NESHAP allows foundries 2

years after promulgation to comply with the management practices for mercury, 1 year to 

comply with the opacity limit for melt shops, and 6 months for other requirements.

Small foundries would submit two types of one-time notifications required by the 

NESHAP general provisions and keep records of specific information to demonstrate compliance 
2

with the rule requirements. The final rule also requires small foundries to calculate for each 

calendar month their 12-month rolling average production rate to ensure that the facility 

continues to meet the size criteria that defines a small iron and steel foundry. Records of the 

monthly production rate and monthly rolling average calculations are required. A small foundry

must report any deviation from these requirements within 30 days. 

Large area source foundries are required to comply with the pollution prevention 

management practices in addition to emissions standards for metal melting furnaces and foundry

operations. The owner or operator may elect to comply with emissions limits for particulate 

matter (PM) or total metal HAP. The final rule contains provisions for demonstrating 

compliance with the limits using emissions averaging. The owner or operator of an existing 

affected source is required to conduct initial and periodic visual inspections of PM control 

devices (baghouses, wet scrubbers, electrostatic precipitators). Foundries using a baghouse to 

comply with the PM emission limit may choose to install and operate a bag leak detection system 

instead of conducting the initial and periodic inspections. Bag leak detection systems are 

required at new foundries. New source foundries must use a continuous parameter monitoring 

system (CPMS) to measure and record pressure drop and scrubber water flow rate for a wet 

scrubber and/or a CPMS to measure and record the hourly average voltage and secondary current 

(or total power input) to an electrostatic precipitator. Monthly inspections of capture systems are 

also be required. An operation and maintenance plan for control devices also is required. 

Foundries also must conduct an opacity test at least every 6 months to demonstrate compliance 

with an opacity limit for fugitive emissions from buildings or structures housing foundry

operations. Alternatively, foundries may conduct semiannual visible emissions observations by

Method 22. The Method 22 test is considered successful if no visible emissions are observed for 

90 percent of a 1-hour test. A Method 9 opacity test is required if the Method 22 test is not 

successful.

Large foundries will demonstrate initial compliance with emissions limits through 

performance tests. The owner or operator of an existing area source may certify initial 

compliance based on the results of a previous performance test that meets the rule requirements. 

Subsequent performance tests for furnaces are to be performed every 5 years. Provisions also are 

included for demonstrating compliance through emissions averaging. A facility that uses 

emissions averaging must conduct monthly compliance determinations by calculating the 

weighted average emissions for furnaces in the emissions averaging group. Consistent with the 

NESHAP General Provisions, large foundries are required to submit one-time notifications; 

comply with requirements for startup, shutdown, and malfunction (SSM) plans and reports; 

submit semiannual excess emissions and monitoring system performance reports; and maintain 

records of specific information to ensure that the rule requirements are being achieved and 

maintained. 

Any owner or operator subject to the provisions of this part will 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 United 

States Environmental Protection Agency (EPA) regional office.
3

Approximately 427 respondents are currently subject to the regulation, and it is estimated 

that no additional respondents per year will become subject to the regulation in the next three 

years. Therefore, the average number of total respondents per year is 142.33.

In the United States, there are approximately 427 iron and steel foundries that are owned 

and operated by the iron and steel foundry industry. None of these 427 facilities are owned by

state, local, tribal, or the Federal government. They are owned and operated by privately owned 

for-profit businesses. You can find the burden to the “Affected Public” listed below in Table 1: 

Annual Respondent Burden and Cost - NESHAP for Iron and Steel Foundry (40 CFR Part 63, 

Subpart ZZZZZ). The Federal government burden does not include work performed by Federal 

employees. The burden refers only to work performed by contractors, which could be found 

listed below in Table 2: Average Annual EPA Burden - NESHAP for Iron and Steel Foundry (40 

CFR Part 63, Subpart ZZZZZ).

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

Collection Request (ICR) without any “Terms of Clearance (TOC).”

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 (HAP). These standards are applicable to new or existing sources of 

HAP 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 cellulose products manufacturing 

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

or welfare. Therefore, the NESHAP for this source category was promulgated at 40 CFR part 

63, subpart ZZZZZ.

2(b) Practical Utility/Users of the Data
4

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where 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 ensure that 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 information generated by the monitoring, recordkeeping, and reporting requirements 

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP 

continue to operate the control equipment in compliance with the regulation.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart 

ZZZZZ.

3(a) Nonduplication

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’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of 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 
5

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. 

After a thorough review of comments, it is our policy to respond to those 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 that 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

None of these reporting or recordkeeping requirements 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 

notification 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 the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.
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4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are iron foundries and 

steel foundries. The North American Industry Classification System (NAICS) codes for the 

respondents affected by the standards are 331511, 331512, and 331513.

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations 

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

(i) Data Items

In this ICR, all the data recorded or reported is required by National Emission Standards 

for Hazardous Air Pollutants for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart 

ZZZZZ).

Source Data and Information Requirements, summarize the data items, including 

recordkeeping and reporting requirements are found in Attachment 1.

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

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

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

a plant site.

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 approximately zero percent of the respondents use 

electronic reporting.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CEMS for opacity, or for pressure drop and liquid 

supply pressure for control device.

Perform initial performance test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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.

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, and 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 might inspect the source to 

determine whether the pollution control devices are properly installed and operational. 

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.

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

maintained by the EPA Office of Compliance. OTIS is the EPA 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 
8

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

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

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

years.

5(c) Small Entity Flexibility

A small entity for this industry is defined by the Small Business Administration as a firm 

having no more than 500 employees. A total of 319 of the 427 iron and steel foundries are small 

entities. Approximately 45 percent (37 of 83) of the large iron and steel foundries (annual metal 

melt production greater than 20,000 tons) are owned by small entities while 85 percent (292 of 

344) of the small iron and steel iron and steel foundries are owned by small entities. The final 

rule includes a specific compliance option for small foundries that provides a maximum degree 

of operational flexibility, and the ICR requirements are the minimum necessary to demonstrate 

compliance. Since proposal, we have further reduced the impacts on small entities by increasing 

the threshold definition for a small foundry from an annual melt production of 10,000 tons to 

20,000 tons. Our analyses show that the final NESHAP will not result in a significant economic 

impact on a substantial number of small entities. No small entities are expected to incur an 

economic impact that is greater than 3 percent of its revenue. The number of foundries that may

incur an economic impact greater than 1 percent of their revenues ranges from an average of 9 to 

a maximum (at the 98th percentile) of 13.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown in Table 2A and 2B: Annual Respondent Burden and Cost, NESHAP for Iron and Steel 

Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (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 6,024 (Total Labor Hours from Table 2A, and 2B). 

These hours are based on Agency studies and background documents from the development of 
9

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

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

This ICR uses the following labor rates:

Managerial $97.99 ($46.66 + 110%) 

Technical $72.09 ($34.33 + 110%)

Clerical $33.16 ($15.79 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, May

2006, "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

As shown in Table 2B, the estimate of capital costs for large foundries is $59,620 with no 

O&M costs. This cost does not include the cost of any monitoring equipment because the final 

rule requires visual inspections instead of automated monitoring equipment at existing affected 

sources. This cost does include the cost of a file cabinet for data storage. 

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

The estimate of capital/startup costs versus O&M costs is shown in Table 2B. No O&M 

costs would occur over the 3-year period of this ICR.

(iv) Annualizing Capital Costs

Table 2B shows an estimate of the annualized cost of capital to be $8,490 per year.

6(c) Estimating Agency Burden and Cost

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

information. The EPA 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 

$32,917.

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

Managerial $58.18 (GS-13, Step 5, $36.36 + 60%) 

Technical $47.97 (GS-12, Step 1, $26.98 + 60%)
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Clerical $22.66 (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) “2007 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 in Table 2: Average Annual EPA Burden, NESHAP for Iron and Steel 

Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

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

There are 427 existing iron and steel foundries. No new sources are expected during the 

next 3 years. Consequently, the average annual number of respondents during the 3 year period 

of this ICR is 142.33. A total of 344 of the 427 facilities are foundries with a metal melting rate 

of 20,000 tpy or less and 83 have metal melting rates greater than 20,000 tpy. Consequently, the 

average annual number of small foundries during the 3-year period of this ICR is 114.67 and the 

average annual number of large foundries is 27.67.

The only components of the total annual responses for small foundries attributable to this 

ICR are two one-time initial notifications for each facility. Large foundries are required to 

submit two one-time initial notifications; prepare an operation and maintenance plan and a 

startup, shutdown, and malfunction plan, and submit semiannual compliance reports. The 

number of total annual responses for Subpart ZZZZZ is estimated as: (114.67 annual average 

respondents × 1 notification) + (114.67 annual average respondents × 1 notification) + (27.67

annual average respondents x 1 deviations report) + (27.67 annual average respondents × 2 

written plans) + (27.67 annual average respondents x 2 semiannual reports). Therefore, the 

number of total annual responses for Subpart ZZZZZ is 367.7.

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 2A, 2B, and 3, respectively, and summarized below. 

(i) Respondent Tally

The bottom line respondent burden hours and costs, presented in Table 2 are calculated 

by adding person-hours per year down each column for technical, managerial, and clerical staff, 

and by adding down the cost column.

The average annual burden for the monitoring, recordkeeping, and reporting requirements 

in Subpart ZZZZZ for small foundries is 3,555 person hours with an annual average cost of 

$248,288 with no capital and O&M costs. The average annual burden for the monitoring, 

recordkeeping, and reporting requirements in Subpart ZZZZZ for large foundries is 2,469 person 

hours with an annual average cost of $172,430; the annualized capital cost is $8,490 with no 

operation and maintenance costs. The average annual burden for the monitoring, recordkeeping, 

and reporting requirements in Subpart ZZZZZ for all iron and steel foundry area sources is 6,024
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person hours with an annual average cost of $420,718 with annualized capital costs of $8,490 

and no O&M costs. 

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 712

labor hours at a cost of $32,917. See Table 3. Annual Agency Burden and Cost: NESHAP for 

Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents 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 according to the industry sources is very low, negative or non-existent, so there is no 

significant change in the overall burden. There are no new facilities expected to be constructed 

over the next three years of this ICR. Therefore, the labor hours and cost figures in the previous 

ICR reflect the current burden on the respondents and are reiterated in this ICR.

6(g) Burden Statement

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

is estimated to average 16 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.

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 the 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-2011-0229. 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, 
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Room 3334, 1301 Constitution Avenue, N.W., Washington, D.C. 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, D.C. 20503, 

Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA2011-0229 and OMB Control Number 2060-0605 in any correspondence.

Part B of the Supporting Statement

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

information.
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ATTACHMENT 1. INFORMATION REQUIREMENTS 

Requirement for new and existing sources Citation for small 

foundries

Citation for large 

foundries

Citation for NESHAP 

general provisions 

Initial and periodic inspections for baghouses, wet scrubber, and electrostatic precipitator at existing 

source; 

NA §63.10897(a) NA

CPMS for wet scrubber at new source NA §63.10897(b) NA

CPMS for electrostatic precipitator at new source NA §63.10897(c) NA

BLDS or inspections for baghouse at existing source; BLDS for baghouse at new source. NA §63.10897(d) NA

Monthly capture system inspections NA §63.10897(e) NA

Semiannual opacity tests NA §63.10898(i) NA

CMS performance evaluation NA NA

Metal melting furnaces and fugitive emissions NA §63.10898 40 CFR 63.7

CMS performance evaluation NA NA 40 CFR 63.8(e)(3)

Notification of applicability §63.10890(b) §63.10900(a), Table 3 40 CFR 63.9(b)(2)

Notification of construction/ reconstruction 1§63.10890(f) §63.10900(a), Table 3 40 CFR 63.9(b)(5)

Notification of special compliance requirements 1§63.10890(f) §63.10900(a), Table 3 40 CFR 63.9(d)

Notification of performance test NA §63.10900(a), Table 3 40 CFR 63.9(c)

Notification of opacity/VE observations NA §63.10900(a), Table 3 40 CFR 63.9(f)

Additional CMS notifications NA NA 40 CFR 63.9(g)

Notification of compliance status §63.10890(c) §63.10900(a), Table 3 40 CFR 63.9(h)(1)

Notification of changes in information 1§63.10890(f) §63.10900(a), Table 3 40 CFR 63.9(j)

Scrap management material specifications §63.10885(b),(c) NA

Operation and maintenance plan NA §63.10896(a) NA

Startup, shutdown, and malfunction plan NA §63.10900(a), Table 3 40 CFR 63.6(e)(3)

Performance test plan NA §63.10900(a), Table 3 40 CFR 63.7(c)(2)

CMS quality control plan NA §63.10900(a), Table 3 40 CFR 63.8(d)

CMS performance evaluation test plan NA NA 40 CFR 63.8(e)(3)

Information to support notifications §63.10890(e)(1) §63.10900(a), Table 3 40 CFR 63.10(b)(2)

Material specifications §63.10890(e)(2) §63.10899(b)(1) NA

Mercury §63.10890(e)(3)-(4) §63.10899(b)(2)-(3) NA

Nonmethanol binder chemical formulations §63.10890(e)(5) §63.10899(b)(4) NA

Annual quantity and composition of each HAP-containing chemical binder or coating material §63.10890(e)(6) §63.10899(b)(5) NA

Metal melt production §63.10890(e)(7) §63.10899(b)(6)

Operation and maintenance plan NA §63.10899(b)(7) NA

If applicable, emissions averaging plan NA §63.10899(b)(8) NA

Bag leak detection system (new sources) NA §63.10899(b)(9) NA

Capture system inspections NA §63.10899(b)(10) NA

CPMS specifications NA §63.10899(b)(11) NA

Corrective action NA §63.10899(b)(12) NA

PM control device log of inspections/maintenance NA §63.10899(b)(13) NA

Semiannual excess emissions/deviation reports §63.10890(f) §63.10899(c), Table 3 40 CFR 63.10(e)(3)

Initial performance test report NA §63.10900(a), Table 3 40 CFR 63.7(e)(1)
14

CMS performance evaluation report NA NA 40 CFR 63.8(e)(5)

SSM reports NA §63.10900(a), Table 3 40 CFR 63.6(e)(3) 1 Requirement is not expected to occur during the 3-year term of this ICR
15

Table 2A: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR 

Part 63, Subpart ZZZZZ) (Renewal)

Burden item (A) 

Person-hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent

(C)

Personhours per 

respondent 

(C=A*B)

(D) 

Respondents 

per yeara

(E) 

Technical 

person-hours 

per year 

(E=C*D)

(F) 

Management 

person-hours 

per year

(E*0.05)

(G) 

Clerical 

personhours per 

year (E*0.1)

(H) 

Costb, $ 

1. Applications N/A 

2. Surveys and Studies N/A 

3. Acquisition, Installation, and 

Utilization of Technology and Systems

N/A 

4. Reporting Requirements 

A. Read instructions 4 1 4 114.67 458.68 22.934 45.868 $36,836 

B. Required activities 

 Scrap specifications 4 1 4 114.67 458.68 22.934 45.868 $36,836 

Monthly rolling average calculation 0.25 12 3 114.67 344.01 17.2005 34.401 $27,627 

 No methanol binder formulation c0 0 0 0 0 0 0 $- 

C. Create information See 4B 

D. Gather existing information See 4B 

E. Write report See 4B 

 Initial notification of applicability 2 1 2 101 202 10.1 20.2 $16,222 

 Notification of compliance status 4 1 4 114.67 458.68 22.934 45.868 $36,836 

Deviations report 1 1 1 57.34 57.34 2.867 5.734 $4,605 

 Notification of 

construction/reconstruction

N/A 

 Notification of anticipated startup N/A 

 Notification of actual startup N/A 

 Notification of special compliance 

requirements

N/A 

 Request for compliance extension N/A 

 Notification of performance test N/A 

 Site specific test plan N/A 

 Notification of performance evaluation N/A 

 Quality assurance plan for 

CEMS/COMS

N/A 

 NESHAP waiver request N/A 

 Startup, shutdown, and malfunction 

plan/reports

N/A 

 Semiannual excess emissions reports N/A 

Subtotal for Reporting Requirements 2,276.4185

5. Recordkeeping Requirements 
16

Burden item (A) 

Person-hours 

per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent

(C)

Personhours per 

respondent 

(C=A*B)

(D) 

Respondents 

per yeara

(E) 

Technical 

person-hours 

per year 

(E=C*D)

(F) 

Management 

person-hours 

per year

(E*0.05)

(G) 

Clerical 

personhours per 

year (E*0.1)

(H) 

Costb, $ 

A. Read instructions See 4A 

B. Plan activities See 4A 

C. Implement activities See 4A 

D Develop record system 2 1 2 114.67 229.34 11.467 22.934 $18,418 

E. Time to enter information d0.1 52 5.2 114.67 596.284 29.8142 59.6284 $47,886 

F. Time to transmit or disclose 

information

0.25 2 0.5 114.67 57.335 2.86675 5.7335 $4,604 

G. Time to adjust existing ways 2 1 2 114.67 229.34 11.467 22.934 $18,418 

F. Time to train personnel e N/A 

G. Time for audits N/A 

Subtotal for Recordkeeping Requirements 1,279.14385

TOTAL LABOR BURDEN AND COST 3,555 $248,288 

 Annualized cost of capital $0

 Operation and maintenance (O&M) $0

 Total (capital recovery plus O&M) $0

N/A = not applicable.

a We have assumed that there are 427 existing iron and steel foundries that area sources. No new sources are projected during the 3-year term of this ICR. Therefore, the average number 

of total respondents per year is 142.33. A total of 344 of the 427 facilities are small foundries and 83 are large foundries. Consequently, the average number of small foundries during the 

3-year period of this ICR is 114.67 and the average number of large foundries is 27.67. No new sources are expected during the next 3 years. For the purposed of deviation reports, 1 

report per year is estimated for one-half (50.5) of the 114.67 respondents per year.

b This ICR uses the following labor rates: The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $72.09, management at $97.99, and clerical at 

$33.16. Technical, management, and clerical average hourly rates for private industry workers in the foundry industry (NAICS 331500) were taken from the United States Department of 

Labor, Bureau of Labor Statistics, May 2006 available at http://www.bls.gov. The rates have been increased by 110% to account for the benefit packages available to those employed by 

private industry.

c We have assumed that no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.

d We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations.

e

 We have assumed that no cost would be incurred to train personnel.
17

TABLE 2B. Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 

CFR Part 63, Subpart ZZZZZ) (Renewal)

Burden item (A) 

Person-hours 

per 

occurrence

(B) 

No. of 

occurrences 

per respondent

(C) 

Person-hours 

per 

respondent 

(C=A*B)

(D)

Respondents 

per yeara

(E) 

Technical personhours per year 

(E=C*D)

(F) 

Management 

person-hours 

per year 

(E*0.05)

(G) 

Clerical 

person-hours 

per year 

(E*0.1)

(H) 

Costb, $ 

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and 

Utilization of Technology and Systems 

N/A

4. Reporting Requirements

A. Read instructions 8 1 8 27.67 221.4 11.1 22.1 $17,777

B. Required activities 

 Scrap material specifications 4 1 4 27.67 110.7 5.5 11.1 $8,889

 Prepare operation & maintenance plan 8 1 8 27.67 221.4 11.1 22.1 $17,777

 No methanol binder formulation c4 1 4 0.67 2.68 0.134 0.268 $215

Initial/subsequent performance tests d0 0 0 0 0.0 0.0 0.0 $0

Initial and periodic inspections of PM 

control devices, monthly inspection of 

capture systems d

0 0 0 0 0.0 0.0 0.0 $0

Monthly emissions averaging 

calculations d

0 0 0 0 0.0 0.0 0.0 $0

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

 Initial notification of applicability 4 1 4 27.67 110.7 5.5 11.1 $8,889

 Notification of compliance status 8 1 8 27.67 221.4 11.1 22.1 $17,777

 Notification of 

construction/reconstruction

N/A

 Notification of anticipated startup N/A

 Notification of actual startup N/A

 Notification of special compliance 

requirements

N/A

 Request for compliance extension N/A

 Notification of performance test d1 1 1 27.67 27.7 1.4 2.8 $2,222

 Site specific test plan d0 0 0 0 0.0 0.0 0.0 $0

 Notification of performance evaluation N/A

 Quality assurance plan for 

CEMS/COMS

N/A
18

Burden item (A) 

Person-hours 

per 

occurrence

(B) 

No. of 

occurrences 

per respondent

(C) 

Person-hours 

per 

respondent 

(C=A*B)

(D)

Respondents 

per yeara

(E) 

Technical personhours per year 

(E=C*D)

(F) 

Management 

person-hours 

per year 

(E*0.05)

(G) 

Clerical 

person-hours 

per year 

(E*0.1)

(H) 

Costb, $ 

 NESHAP waiver request N/A

 Startup, shutdown, and malfunction 

plan/reports

4 1 4 27.67 110.7 5.5 11.1 $8,889

 Semiannual excess emissions reports d2 2 4 27.67 110.7 5.5 11.1 $8,889

Subtotal for Reporting Requirements 1,307.982

5. Recordkeeping Requirements 

A. Read instructions See 4A

B. Plan activities See 4A

C. Implement activities See 4A

D Develop record system 4 1 4 27.67 110.7 5.5 11.1 $8,889

E. Time to enter information e 0.5 52 26 27.67 719.4 36.0 71.9 $57,775

F. Time to transmit or disclose 

information

0.25 2 1 27.67 13.8 0.7 1.4 $1,111

G. Time to adjust existing ways 2 1 2 27.67 55.3 2.8 5.5 $4,444

F. Time to train personnel f4 1 4 27.67 110.7 5.5 11.1 $8,889

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 1,161.4

TOTAL LABOR BURDEN AND COST 2,469 $172,430

 Annualized cost of capital g

$8,490

 Operation and maintenance (O&M) h

$0

 Total (capital recovery plus O&M) g $8,490

N/A = not applicable.

a We have assumed that there are 427 existing iron and steel foundries that area sources. No new sources are projected during the 3-year term of this ICR. Therefore, the average number 

of respondents per year is 142.33. A total of 344 of the 427 facilities are small foundries and 83 are large foundries. Consequently, the average number of small foundries during the 3-

year period of this ICR is 114.67 and the average number of large foundries is 27.67

b This ICR uses the following labor rates: The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $72.09, management at $97.99, and clerical at 

$33.16. Technical, management, and clerical average hourly rates for private industry workers in the foundry industry (NAICS 331500) were taken from the United States Department of 

Labor, Bureau of Labor Statistics, May 2006 available at http://www.bls.gov. The rates have been increased by 110% to account for the benefit packages available to those employed by 

private industry.

c We assumed that two large area source foundries (2 foundries over 3 years = 0.67 foundries per year) are expected to have to change formulations to meet the no methanol requirement.

d We have assumed that these activities are not expected to occur during the first 3 years of this ICR.

e We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations and 

information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of the General Provisions

(40 CFR part 63, subpart A). 

f We have assumed that large foundries are expected to monitor visible emissions using a trained employee.

g Based on capital cost of $59,620 for file storage cabinets, 7 percent interest, and 20-year equipment life (capital recovery factor = 0.142). No costs for monitoring equipment are 

estimated because no monitoring equipment is required for existing foundries.
19

Total Burden Hours, Costs and Annualized Cost of Capital From 2A and 2B:

Tables Burden Hours Burden Cost Annualized Cost of Capital

2A 3,555 $248,288 $0

2B 2,469 $172,430 $8,490

Totals 6,024 $420,718 $8,490
20

Table 3: Average Annual EPA Burden - NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(Renewal)

Burden Item (A)

Person hours per 

occurrence

(B) 

Occurrences per 

respondent

(C) 

Plants per 

year a

(D) 

Technical 

hours/year 

(D=A*B*C)

(E) 

Management 

 hours/year 

(E=0.05*D)

(F) 

Clerical

 hours/year 

(F=0.1*D)

(G)

Costb, $

Report Review:

 Initial notification of applicability 1 1 142.33 142.3 7.1 14.2 $7,564

Deviation reports 1 1 50.1 50.1 2.5 5.0 $2,662

 Startup, shutdown, malfunction plan/report 2 1 142.33 142.3 7.1 14.2 $7,564

 Notification of compliance status 2 1 142.33 142.3 7.1 14.2 $7,564

 Semiannual excess emissions report 2 1 142.33 142.3 7.1 14.2 $7,564

TOTAL BURDEN AND COST 712.3 $32,917

a There are 427 existing iron and steel foundries that are area sources. No new sources are projected during the 3-year term of this ICR. Therefore, the average number of respondents per 

year is 142.33. .

b This ICR uses the following average hourly labor rates: 58.18 for managerial (GS-13, Step 5, $36.36 x 1.6), $43.14 (GS-12, Step 1, $29.98 x 1.6) for technical and $22.66 (GS-6, Step 3, 

$14.16 x 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) A2007 General Schedule@ which excludes locality rates of pay.