SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

(40 CFR Part 60, 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 60, Subparts 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 Plants: Electric Arc Furnaces

and Argon Oxygen Decarburization Vessels were proposed on October 21, 1974, promulgated 

on September 23, 1975, and most recently amended on February 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 couple 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 assure compliance with 40 CFR part 60, subparts 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 essential 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 date of such measurements, 

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

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

Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of two 
2

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 Clearance.”

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, Subparts AA and AAa) (Renewal). 

The burden to the “Federal Government” is attributed entirely to work performed by federal 

employees or government contractors 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, Subparts AA and AAa) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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 

Administrator 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 every 

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 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 
3

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 reasonably 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 the 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 record of the 

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

determine compliance in place of a continuous emission monitor. 

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

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

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

installed and operated, 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 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 60, subparts 

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 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.
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 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 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 standard as it was being developed and the standard 

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

purposes. In developing this ICR, we contacted: 1) ASTM International, at (800) 262-1373; and 

2) the Specialty Steel Industry 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 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 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 
5

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 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 Standard 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 North 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 Part 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 limit 

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 and 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 is 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 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. 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 database 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). The 

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 frequency 
9

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 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.

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 entities1. It is assumed that 84 percent of the current respondents subject to standards 

(or 83 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 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 61,310 (Total Labor Hours from Table 1 below). 

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

the regulation, Agency knowledge and experience with the 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 

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

the benefit packages available to those employed by private industry.

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

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

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

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

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

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

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

This ICR assumes that: 40 percent of respondents using negative baghouses (39.5), 

66 percent (26.1) of these use COMS to measure stack emissions and 33 percent (13.0) have 

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

observations instead of using COMS; 51.7 percent (51.0) of respondents have elected to comply 

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

continuously; all respondents (98.7) 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.
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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 $195,750

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 $195,750. 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 $201,240. 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 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 

$82,502. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)
12

These rates are from the Office of Personnel Management (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. 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 standards initially, and it 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 0 197.4

Total 198.66

The number of Total Annual Responses is 199 (rounded).

The total annual labor costs are $5,936,587. 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 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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 61,310 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 308 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $201,240. 

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

Maintenance (O&M) Costs.
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(ii) The Agency Tally

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

1,831 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 reflect 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, this 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 308 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 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 and 

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 Public 
15

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-2012-0653 and OMB Control Number 2060-0038 in any 

correspondence. 

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. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read instructions ------------------------Included in 3B----------------------------

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 4E----------------------------

D. Gather Existing Information ------------------------Included in 3B and 4E----------------------------

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 3B----------------------------

Semiannual reports f 16 2 32 98.7 3,158.4 157.92 315.84 $351,697.32

Subtotal for Reporting Requirements (rounded) 3,785 $366,489

4. Recording Requirements

A. Read instructions ------------------------Included in 3A----------------------------

B. Plan activities ------------------------Included in 3B----------------------------

C. Implement activities ------------------------Included in 3B----------------------------

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 $2,885,017.59
17

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 8,342.25 417.11 834.22 $928,934.01

Records of COMS g,i 0.5 350 175 26.06 4,560.5 228.02 456.05 $507,824.74

Records of BLDS h, i 0.5 350 175 13.03 2,280.25 114.01 228.02 $253,912.12

Records of static furnace h 0.5 350 175 51.03 8,930.25 446.51 893.02 $994,409.57

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements

(rounded) 57,525 $5,570,098

TOTAL LABOR BURDEN AND COST (rounded) 61,310 $5,936,587

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 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%). 

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 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 Clerical 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 would 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 pressure data. In addition, sources 

are required to conduct monthly operational status 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 equipped 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 perform 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 pressure, 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 system 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 51.03 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 (BLDS). We have assumed that approximately 51.7 percent 

of the respondents (or 51.03 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 (BLDS).

i We have assumed that approximately 40 percent of respondents use negative pressure baghouses. Of these, 66 percent (26.06) use COMS to measure stack 

emissions and 33 percent (13.03) have elected to use the alternative option of using BLDS monitoring couple with visible emissions observations instead of using 

COMS.
19

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)

REPORTING/RECORDKEEPING 

REQUIREMENT

(A)

EPA Hours 

per 

Occurrence 

(B)

Number of 

Occurrences 

per Plant

Per

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 12 0.3 0.6 0.03 0.06 $31.10

Notification of actual startup 1 1 1 0.3 0.3 0.015 0.03 $15.61

Notification of performance test c0.5 1.2 0.6 0.3 0.18 0.009 0.018 $9.33 

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

Repeat Performance test c24 0.2 4.8 0.3 1.44 0.072 0.144 $74.62

Review Performance Test results c8 1.2 9.6 0.3 2.88 0.144 0.29 $149.30

Notification of COMS Demonstration 0.5 1 0.5 0.3 0.15 0.007 0.015 $7.73

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 average 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.