SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels

(40 CFR Part 6 0

, Subparts AA and AAa ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels

(40 CFR Part 6 0 , Subpart s AA and AAa ) (Renewal), EPA ICR Number 1060.16

, OMB

Control Number 2060

- 0038

.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Steel P lants: E lectric A rc F urnaces

and A rgon O xygen Decarburization V essels were proposed on October 21, 1974, promulgated

on September 23, 1975 , and most recently amended on Febru ary 22, 2005 . These regulations

apply to both new and existing facilities in steel plants that produce carbon, alloy, or specialty

steels: electric arc furnaces (EAFs) , argon oxygen decarburization (AOD) vessels, and dust

handling systems.

NSPS subpart AAa was proposed on August 17, 1983, and promulgated on October 31,

1984. It established new standards applicable to EAFs, AOD vessels

, and dust handling systems

constructed, modified, or reconstructed after August 17, 1983. On March 2, 1999, the Agency

approve daily shop opacity observations as an alternative to static pressure monitoring at an

EAF with a direct shell evacuation system, and clarified some definitions. On February 22,

2005, the Agency approved the use of bag leak detection systems coup le with daily shop opacity

observations as an alternative to continuous opacity monitoring. New facilities include those

that commenced construction, modification, or reconstruction after the date of proposal. This

information is being collected to assu re compliance with 40 CFR part 60, subpart s AA and AAa.

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

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

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

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

inoperative. These notifications, reports, and records are essen tial in determining compliance,

and are required of all affected facilities subject to NSPS.

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

measurements, and retain the file for at least two years following the d ate 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 Agenc y (EPA) regional office.

Based on our consultations with industry representatives, there is an average of two2

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

owner/operator of the plant site).

Over the next three years, an average of 98. 4 respondents per year will be subject to the

standard, and one additional respondent over the next three years will become subject to the

standard.

OMB approved the currently active ICR without any “ Terms of Clearanc e. ”

The “Affected Public” are facilities that produce carbon, alloy, or specialty steels (or

minimills). The burden to the “Affected Public” may be found below in Table 1 : Annual

Respondent Burden and Cost

– NSPS for Steel Plants: Electric Arc Furnaces and Argon

Oxygen Decarburization Vessels (40 CFR Part 60, Subpart s AA and AAa) (Renewal)

. T he burden to the “Federal Government” is attributed entirely to work performed by federal

employees or government contractor s and may be found below in Table 2: Average Annual

EPA Burden and Cost

– NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen

Decarburization Vessels (40 CFR Part 60, Subpart s AA and AAa) (Renewal)

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Co llection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to

establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous

emissions reduction which (taking into consideration the cost of

achieving such emissions reduction, or any non

- air quality health

and environmental impact and energy requirements) the

Administrat or determines has been adequately demonstrated.

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section

111 also requires that the Administrator review and, if appropriate, revise such standards e very four years. 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 moni toring 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 data3

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, particulate matter emissions from electric arc furnaces,

argon

- oxygen decarburization (AOD) vessels, and dust handling systems cause or contribute to

air pollution that may reas onably be anticipated to endanger public health or welfare. Therefore,

the NSPS was promulgated for this source category at 40 CFR part 60, subparts AA and AAa

.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in th e standard ensures 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 test a re cord of the

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

determine compliance in place of a continuous emission monitor.

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

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

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

installed and operated, leaks are being detected and repaired

, and 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 probl ems 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 60, s ubparts

AA and AAa.

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 lo cal 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,

duplicat ion does not exist.4

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 ( 77 FR 63813 ) on October 17, 2012

. No comments were received on t he

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 record

keeping and reporting provisions in the standard, is the Online Tracking Information System

(OTIS) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s

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 standar d as it was being developed and the standard

has been previously reviewed to determine the minimum information needed for compliance

purposes. In devel oping this ICR, we contacted : 1) A STM International

, at ( 800 ) 262

- 1373 ; and

2) the Specialty Steel Indus try of North America

, at ( 202 ) 342

- 8630

.

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

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

case, no comments were rece ived.

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 re ports 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 the Part

70 permit program and the five

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

T he retention of records for five years allow s EPA to establish the compliance history of a5

source

, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EPA has f

ound that the most flagrant violators have violations extending beyond five

years. In addition, EPA would be prevented from pursuing the violators due to either the

destruction or nonexistence of essential records

.

3(f) Confidentiality

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

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

subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902,

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities in steel

plants that produce carbon, alloy, or specialty steels . The United States S tandard Industrial

Classification ( SIC ) code for the respondents affected by the standards is SIC 3312 : Steel Works,

Blast Furnaces (Including Coke Ovens), and Rolling Mills (except coke ovens not integrated

with steel mills), which corresponds to the Nort h American Industry Classification System

(NAICS ) code 331111 for Iron and Steel Mills.

4(b) Information Requested

(i) Data Items

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

Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR P art 60,

Subparts AA and AAa)

.

A source must make the following reports:

Notifications

Notification of date of construction/reconstruction 60.7(a)(1)

Notification of demonstration of compliance with the particulate

matter standard 60.276(c)6

Notifications

Notification of actual startup 60.7(a)(3)

Notification of initial performance test 60.8(d)

Report of performance test results 60.8 (a)

Notification of demonstration of the continuous monitoring system

performance commences 60.7(a)(5)

Notification of procedures to be followed during performance tests

if emissions is combined with non

- affected facilities 60.276(b)(2)

Physical or operational change 60.7(a )(4)

Use of opacity or visible emissions observations during

performance test 60.7(a)(6

- 7)

Provide semiannual reports of operational values that exceed (i.e.,

furnace static pressure, fan motor amperes) or are below (i.e., flow

rates) those established during the performance test, and of all shop

opacity observations in excess of the emission li mit 60.7(c), 60.276(a),

60.276(d), 60.276 a(c),

60.276a (g)

A source must keep the following records:

Recordkeeping

Startups, shutdowns, and malfunctions, periods where the

continuous monitoring system is inoperative. 60.7(b)

Furnace static pressure measurements or daily observations of shop

opacity by a certified visible emission observer if EAF is equipped

with a direct shell evacuation system (DEC). 60.273(d),60.274(f),

60.276(d), 60.274a (f)

Daily records of operational parameters, such as time and duration

of each charge, time and duration of each tap, flow rate data,

pressure data. 60.274(a

- b), 60.274a (b)

Note deficiencies during monthly control system fan motor

amperes operational status check. 60.274(f), 60.274a (f)

Maintain a file of all measurements including, performance test

measurements, and all other information required by this part

recorded in a permanent file suitable for inspection. The file shall

be retained for at least two years. 60.7(f), 60.276a (a)

Record of time an d duration of each charge and tap (NSPS subpart

AA only). 60.274(a)7

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records

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

automation has significantly reduced the burden associated with monitoring and recordkeeping

at a plant site.

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

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

widely used. At this time, it i s estimated that approximately 10 percent of the respondents use

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

supply pressure for measurement of daily monitoring of the opacity of visible emissions.

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.

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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide 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.8

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 could inspect the source

to determine whether the pollution control devices are p roperly installed and operated.

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

com ply with the emission standard. Data and records maintained by the respondents are

tabulated and published for use in compliance and enforcement programs. The semiannual

reports are used for problem identification, as a check on source operation and maintenance,

and for compliance determinations.

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

maintained by EPA's Office of Compliance. OTIS is EPA’s datab ase for the collection,

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

government

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

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

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

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

years.

5(c) Small Entity Flexibility

A majority of the respondents are small entities (i.e., small businesses). T he

recordkeeping and reporting requirements are the same for both small and large entities

(minimills) since the process operations and the types of control equipment employed by

them are similar, independently of their size. However , EPA reduced the reporting frequency9

for this information from quarterly to semiannually in a December 1990 Federal Register

notice to reduce the impact of reporting burden on small businesses. The reduction in reporting

frequency was in response to OMB's previous questions regarding the need for quarterly versus

semiannual reporting. The Agency considers these to be the minim um 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.

In EPA’s 1979 Review of Standards of Performance for Electric Arc Furnaces in the

Steel Industry, it was noted that approximately 84 percent of the facilities subject to the standards

were small entities 1 . It is assumed that 84 percent of the current respondents subject to stan dards

(or 8 3 of the 98 respondents) are small entities.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost

– NSPS for Steel Plants: Electric

Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR Part 60, Subparts AA and

AAa) (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 consi stent with

the concept of burden under the Paperwork Reduction Act. Where ver 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 t he next three years from these recordkeeping

and reporting requirements is estimated to be 61, 3 10 (Total Labor Hours from Table 1 below )

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

the regulation, Agency know ledge and experience with the NSPS program, the previously

approved ICR, and any comments received.

1 Review of Standards of Performance for Electric Arc Furnaces in Steel Industry . EPA

- 450 3

- 79

- 033. October,

1979.10

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $121.44 ($57.83 + 110%)

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from

colu mn 1, “Total compensation.” The rates have been increased by 110 percent to account for

the benefit packages available to those employed by private industry.

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

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

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

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

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

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

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

This ICR assumes that: 40 percent of respondents using negative baghouses (39. 5 ),

66 percent (2 6.1 ) of these use COMS to measure stack emissions and 33 percent (1 3.0 ) have

elected to use the alternative option of using BLDS monitoring couple with visible emissions

observations instead of using COMS ; 51.7 percent (5 1.0 ) of respondents have elected to comply

with the fugitive emissions monitoring requirements by measuring the furnace static pressure

continuously; all respondent s (9 8.7 ) are required to installed flow rate monitors as part of the

monitoring of operations rule requirements; and that the operating and maintenance costs

associated with the pressure and flow monitors are negligible.11

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)

Continuous

Opacity

Monitors $25,000 0 $0 $7,500 26. 1 $195, 750

Furnace

Static

Pressure

Monitors $300 0.3 $90 $0 51.0 $0

Volumetric

Flow Rate

Monitor $18,000 0.3 $5,400 $0 98. 7 $0

TOTAL $5,490 $195, 75 0

The total capital/startup costs for this ICR are $5,490. This is the total of column D in the

above table.

The total operation and maintenance (O&M) costs for this ICR are $195, 75 0. This is the

total of column G.

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

costs to industry over the next three years of the ICR is estimated to be $20 1

, 24 0. These

are the 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 inspe ction 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

$82, 502

.

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

Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% )

Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% )

Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% )12

These rates are from the Office of Personnel Management (OPM), 201 2 General Schedule,

which excludes localit y

, 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

– NSPS for Steel Plants:

Electric Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR Part 60, Subparts

AA and AAa) (Renewal)

.

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

Based on our research for this ICR, approximately 98. 4 existing respondents will be

subject to the standard s initially, and i t is estimated that an additional 0.3 respondents per year

will become subject during the three

- year period . The overall average number of respondents,

as shown in the table below

, is approximately 98. 7 per year.

The number of respondents is calculated using the following table that addresses the three

years covered by this ICR.

Number of Respondents

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 0.3 98.1 0 0 98. 4

2 0.3 98. 4 0 0 98. 7

3 0.3 98. 7 0 0 99.0

Average 0.3 98. 4 0 0 98. 7

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

Column D is subtracted to avoid double

- counting respondents. As shown above, the

average Number of Respondents over the three year period of this ICR is 98. 7

.

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

below :13

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 actual startup 0.3 1 0 0.3

Notification of construction/

modification 0.3 1 0 0.3

Notification of performance

test 0.3 1 0 0.3

Reports of performance test

results 0.3 1.2 0 0.36

Semiannual reports 98. 7 2 0 19 7.4

Total 198. 6 6

The number of Total Annual Responses is 19 9 (rounded)

.

The total annual labor costs are $5,9 36

, 587 . Details regarding these estimates may be

found below in Table 1: Annual Respondent Burden and Cost

– NSPS for Steel Plants: Electric

Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR Part 60, Subparts AA and

AAa) (Renewal)

.

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

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

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

(i) Respondent Tally

The total annual labor hours are 61, 3 10 hours at a cost of $5,936, 587 . Details regarding

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

– NSPS for

Steel Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels (40 CFR Part

60, Subparts AA and AAa) (Renewal)

.

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

of information is estimated to average 30 8 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $20 1

, 2 40

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and

Maintenance (O&M) Costs.14

(ii) The Agency Tally

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

1,8 31 labor hours at a cost of $82, 502 . See Table 2 below : Average Annual EPA Burden and

Cost

– NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen Decarburization Vessels

(40 CFR Part 60, Subparts AA and AAa) (Renewal)

.

6(f) Reasons for Change in Burden

There is an increase in the total estimated burden as currently identified in the OMB

Inventory of Approved Burdens. This increase is not due to any program changes. The

increases in burden, including labor hours, labor costs, and O&M costs refle ct an increase

in the number of respondents. The new number of respondents accounts for the one new source

that is subject to the rule since the last ICR period. Further, t his ICR uses updated labor rates to

calculate burden costs , which results in an increase in labor costs for both the respondents and

the Agency

.

6(g) Burden Statement

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

is estimated to average 30 8 hours per response. Burden means the tot al 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 technolo gy 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

requ irements; train personnel to be able to respond to a collection of information; search data

sources; complete and review the collection of information; and transmit or otherwise disclose

the information.

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

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

Numbers for EPA 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

- 2012

- 0653

. 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 a nd

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West,

Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public15

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 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, Attention: Desk Officer for EPA. Please include the EPA Docket

ID Number EPA

- HQ

- OECA

- 20 12

- 0653 and OMB Control Number 2060

- 0038 in any

cor respondence.

Part B of the Supporting Statement

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

information.16

Table 1: Annual Respondent Burden and Cost

– NSPS for Steel Plants: Electric Arc Furnaces and Argon Oxygen

Decarburization Vessels (40 CFR Part 60, Subparts AA and AAa) (Renewal)

REPORTING/RECORDKEEPING

REQUIREMENT (A)

Respondent

Hours per

Occurrence (B)

Number of

Occurrences

per Respondent

per Year (C)

Hours per

Respondent

per Year

(A x B) (D)

Number of

Respondents

per Year a (E)

Technical

Hours

per Year

(C x D) (F)

Management

Hours per

Year

(E x 0.05) (G)

Clerical

Hours per

Year

(Ex0.1) (H)

Total Labor

Costs per

Year, $ b

1. A pplications N/A

2. S urvey and S tudies N/A

3 . R eporting R equirements

A. Read instructions

------------------------ Included in 3 B

----------------------------

B. Required activities

Initial Performance tests c 364 1 364 0.3 109.2 5.46 10.92 $12,159.75

Repeat Performance tests c 364 0.2 72.8 0.3 21.84 1.09 2.18 $2,431.95

Monitoring of operations and emissions d

, e

------------------------ Included in 4 E

---------------------------- D. Gather Existing Information

------------------------ Included in 3 B and 4 E

---------------------------- E. Write report

Notification of construction/ modification 2 1 2 0.3 0.6 0.03 0.06 $66.81

Notification of actual startup 2 1 2 0.3 0.6 0.03 0.06 $66.81

Notification of initial performance test 2 1 2 0.3 0.6 0.03 0.06 $66.81

Reports of performance test results

------------------------ Included in 3 B

----------------------------

Semiannual reports f 16 2 32 98. 7 3,158.4 157.92 315.84 $351,697.32

Subtotal for Reporting Requirements (rounded) 3,7 85 $36 6

, 489

4 . R ecording R equirements

A. Read instructions

------------------------ Included in 3 A

----------------------------

B. Plan activities

------------------------ Included in 3 B

---------------------------- C. Implement activities

------------------------ Included in 3 B

----------------------------

D. Develop record system N/A

E. Time to enter and transmit information:

Records of daily monitoring of operations d 0.75 350 262.5 98. 7 25,908.75 1,295.44 2,590.88 $2,885,017. 5917

REPORTING/RECORDKEEPING

REQUIREMENT (A)

Respondent

Hours per

Occurrence (B)

Number of

Occurrences

per Respondent

per Year (C)

Hours per

Respondent

per Year

(A x B) (D)

Number of

Respondents

per Year a (E)

Technical

Hours

per Year

(C x D) (F)

Management

Hours per

Year

(E x 0.05) (G)

Clerical

Hours per

Year

(Ex0.1) (H)

Total Labor

Costs per

Year, $ b

Records of daily emissions monitoring by a

certified observer e, h 0.5 350 175 47.67 8,342. 25 417.1 1 834.2 2 $928,9 34

. 01

Records of COMS g

, i 0.5 350 175 26.06 4,5 60

. 5 228.0 2 45 6

. 05 $507, 824

. 74

Records of BLDS h, i 0.5 350 175 13.03 2, 280.25 114.0 1 228.0 2 $253, 912

. 12

Records of static furnace h 0.5 350 175 51.03 8,9 30

. 25 446. 51 89 3

. 02 $994, 40 9. 57

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements

(rounded) 57, 52 5 $5,5 70 ,0 98

TOTAL LABOR BURDEN AND COST (rounded) 61, 3 10 $5,9 36

, 587

Assumptions:

a We have assumed that there are approximately 98. 4 sources currently subject to the NSPS, s ubparts AA and AAa. We have further assumed that one minimill

will become subject to the standard over the three year period of this ICR (0.3 new respondents per year). Therefore, the average number of respondents per year

is estimated to be 98. 7 (rounded).

b This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $121.44 ($57.83+ 110%); and Clerical $50.51 ($24.05 + 110%).

T hese rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers , by occupational and industry

group.” The rate s 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Cle rical hours are 10 percent of Technical hours.

c We have assumed that existing sources are in compliance with initial rule requirements including the initial performance test and notification requirements. We

have assumed that 20 percent of the sources w ould repeat performance tests due to failure.

d Daily monitoring of operations includes time and duration of each charge, time and duration of each tap, flow rate data and p ressure data. In addition, sources

are required to conduct monthly operational st atus checks of the equipment (e.g., physical appearance, pressure sensors, dampers, damper switches)

.

e Daily emissions monitoring includes stack emissions monitoring using a continuous opacity monitor if the source has an EAF eq uipped with a direct shell

evacuation system (DEC) and uses a negative pressure baghouse, and has not elected the alternative option. In addition, the source is required to conduct fugitive

emissions monitoring using a furnace static pressure monitoring device or by electing to pe rform shop opacity observations using a certified visible emissions

observer, it the source has an EAF equipped with a DEC.

f Sources are required to provide semiannual reports of opacity observations and operational values (i.e., furnace static press ure, fan motor amperes) that exceed

or are below (i.e, flow rates) those established during the performance test, and of all shop opacity observations in excess of the emission limit.18

g We have assumed that the new source will equipped its EAFs with a DEC sy stem and use a positive pressure baghouse, and therefore, will not be required to

install a continuous opacity monitor (COMS).

h We have assumed that approximately 51.7 percent of the respondents (or 5 1.03 respondents) will choose to comply with the fugitive emissions monitoring

requirements by measuring the furnace static pressure continuously and 48.3 percent (47. 67 respondents) will choose the alternative option of daily opacity shop

observations by a ce rtified visible emission observer couple with the use of bag leak detection systems (BLDS). We have assumed that approximatel y 51.7 percent

of the respondents (or 5 1.03 respondents) will choose to comply with the fugitive emissions monitoring requirements by measuring the furnace static pressure

continuously and 48.3 percent (47. 67 respondents) will choose the alternative option of daily opacity shop observations by a certified visible emission observer

couple with the use of bag leak detection systems (BLD S).

i We have assumed that approximately 40 percent of respondents use negative pressure baghouses. Of these, 66 percent (2 6.06 ) use COMS to measure stack

emissions and 33 percent (1 3.03 ) have elected to use the alternative option of using BLDS monitorin g couple with visible emissions observations instead of using

COMS.19

Table 2: Average Annual EPA Burden and Cost

– NSPS for Steel Plants: Electri c Arc Furnaces and Argon Oxygen

Decarburization Vessels (40 CFR Part 60, Subparts AA and AAa) (Renewal)

REPORTING/RECORDKEEPING

REQUIREMENT (A)

EPA Hours

per

Occurrence (B)

Number of

Occurrences

per Plant

P er

Year (C)

EPA Hours

per Year

(AxB) (D)

Plants per

Year a (E)

Technical

Hours per

Year

(CxD) (F)

Management

Hours per

Year

(Ex0.05) (G)

Clerical

Hours per

Year

(Ex0.1) (H)

Costs per

Year,

$ b

Notification of construction/modification 2 1 2 0.3 0.6 0.03 0.06 $31. 10

Notification of actual startup 1 1 1 0.3 0.3 0.0 15 0.03 $15. 61

Notification of performance test c 0.5 1.2 0.6 0.3 0.18 0.0 09 0.0 18 $9.33

Initial performance test 24 1 24 0.3 7.2 0.36 0.72 $373.14

Repeat P erformance test c 24 0.2 4.8 0.3 1.44 0.07 2 0.14 4 $74.6 2

Review Performance Test results c 8 1.2 9.6 0.3 2.88 0.14 4 0.29 $149. 30

Notification of COMS Demonstration 0.5 1 0.5 0.3 0.15 0.0 07 0.0 1 5 $7.7 3

Semiannual reports 8 2 16 98.7 1,579.2 78.96 157.92 $81,841.25

TOTAL ANNUAL BURDEN and COST (rounded) 1, 831 $82, 502

Assumptions

a We have assumed that there are approximately 98. 4 sources currently subject to the NSPS, Subparts AA and AAa. We have further assumed that one minimill

will become subject to the standard over the three year period of this ICR (0.3 new respondents per year). Therefore, the ave rage number of respondents per year

is estimated to be 98. 7 (rounded).

b This cost is based on the average hourly labor rate as follows: Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%); Managerial $62.27 (GS

- 13, Step 5, $38.92 +

60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60 %). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10

percent of Technical hours. These rates are from the OPM, 2012 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.

c We have assumed that 20 percent of the sources would repeat performance tests due to failure.