SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR ) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR ) (Renewal),

EPA ICR Number 2050.06 , OMB Control Number 2060

- 0538

.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP ) for Taconite

Iro n Ore Processing ( 40 CFR Part 63, Subpart RRRRR ) were proposed on December 18, 2002

, promulgated on October 30, 2003

, and amended on April 20, 2006

. These regulations apply to

existing and new taconite iron ore processing facilities that emit or have the potential to emit a

single hazardous air pollutant (HAP) at a rate of 10 tons or more per year or any combination of

HAP s at a rate of 25 tons or more per year

. The effective sources in this S ub part covers

emissions from ore crushing and handling emission units, ore dryer stacks, indurating furnace

stacks, finished pellet handling emission units, and fugitive dust emissions. New facilities

include those that commenced construction or reconstructi on after the date of proposal. This

information is being collected to assure compliance with 40 CFR Part 63, Subpart RRRRR

.

In general, all NESHAP standards require initial notification report s, performance tests,

and periodic reports by the owners/operat ors 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. Th ese notifications, reports, and records are essential in determining compliance,

and are required of all affected facilities subject to NESHAP.

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

these documents , and retain the file for at least five years following the generation date of such

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.

There are approximately 8 facilities, which are owned and operated by the taconite iron

ore processing industry ( known as the “Affected Public”)

. Of these 8 facilities, 3 facilities are

idle, 1 is partly idle, and 4 are operating with 1 expected to shut down in 2016 1

. None of the se

facilities in the United States are owned by either state, local, tribal or the Federal government.

They are all owned and operated by privately

- owned, for

- profit businesses. The “ burden ” to the

1 Operation at Northshore, United Taconite (UTAC) and Keetac have been idled; operations at Minntac are partially

idled; and Empire, Tilden, Hibbing and Arcelormittal are operational with operations at Empire expected to be shut

down in 2016.2

Affected Public may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR) (Renewal)

. The

Federal Government ’s “ burden ” is attributed entirely to work performed by either F ederal

employees or government contractors and can be found below in Table 2 below : Average Annual

EPA Burden and Cost

– NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subp art

RRRRR) (Renewal).

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

affected facility 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, approximate ly 4 respondents per year will be subject to the se

standard s , and no additional respondents per year will become subject to the se same standard s

. This estimate is based on industry

- specific information that indicates approximately h alf of the

eight facilities are not currently in operation.

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

without any “ Terms of Clearance ”

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish

standards of performance for each category or subcategory of major sources and area sources of

hazardous air pollutants. These standards are applicable to new or existing sour ces of hazardous

air pollutants and shall require the maximu m degree of emission reduction. In addition, section

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

of this Act to:

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

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

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

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

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

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

equipment parameters, production variables or other indirect data

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from taconite iron ore processing plants

either cause or contribute to air pollution t hat may reasonably be anticipated to endanger public3

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

CFR Part 63, Subpart RRRRR

.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with

the applicable regulations which were promulgated in accordance with the Clean Air Act. The

collected information is also used for targeting inspections and as evidence in legal proceedings.

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

capability to comply with the emissio n standard s

. Continuous emission monitors are used to

ensur e compliance with the se standard s 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 notifica tions required in the se standard s 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 p roperly

installed and operated, leaks are being detected and repaired and the standard s are being met.

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions,

identify problems at the facility, verify operation/maintenance procedures and for compliance

determinations.

3. Non

- duplication, Consultations, and Other Collection Criteria

The requested recordkeeping an d reporting are required under 40 CFR Part 63, Subpart

RRRRR

.

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 s imilar standards to implement the

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

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

not exist.

3(b) Public N otice Required Prior to ICR Submission to OMB

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

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

. No comments were received on the

burden published in the Federal Regi ster

.4

3(c) Consultations

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

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

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

provisions in the standard s

, is the Integrated Compliance Information System (ICIS). ICIS is

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

and government

- owne d facilities. The growth rate for the industry is based on our consultations

with the Age ncy’s internal industry experts

.

I ndustry trade associations and other interested parties were provided an opportunity to

comment on the burden associated with the se standard s as they were being developed and that

the standard s ha ve been reviewed previously to determine the minimum information needed for

compliance purposes. In developin g this ICR, we contacted both : 1 ) the National Mining

Asso ciation

, at (202) 463

- 2600 ; and 2 ) the Iron Mining Association of Minnesota

, at (218) 722

-

7724.

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 f irst Federal Registe r n otice. 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 se standards. Requirements for information gathering and

recordkeeping are useful techniques to ensure that good operation and maintenance practices are

applied and emission limitations are met. If the information required by these standards was

collected less frequently, the proper operation and maintenance of control equipment and the

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR Pa rt 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

- y ear 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. T he retention of records for five years allow s EPA to establish the compliance history of a

sourc e

, 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 t o the destruction or

nonexistence of essential records

.5

3(f) Confidentiality

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

will be safeguarded according to the Agency policies set forth in Title 40, C hapter 1, P art 2,

S ubpart B

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

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

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

3(g) Sensitive Questions

T he reporti ng or recordkeeping requirements in the se standard s 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 taconite iron ore

processing facilities

. The United States Standard Industrial Classification ( SIC ) code for the

respondents affected by the standards is SIC 1011

, which corresponds to North American

Industry Classification System (NAICS ) code 212210 for Iron Ore Mining

.

4(b) Information Requested

(i) Data Items

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

Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR)

.

A source must make the following reports:

Notification s /Reports

Initial notification 63.9640( a )

- (c),

63.9(b)

Notification of intent to conduct a performance test 63.9640( d)

, 63.7(b)(1)

Notification of compliance status 63.9640 (a),(e),

63.9(h)

Request to conduct a new performance test 63.9622(f)6

Notification s /Reports

Semiannual compliance report 63.9641(a), (b),

63.8(c)(7)

- (8),

63.10( e )( 3)

Startup, shutdown, or malfunction report 63.9641(c),

63.10(d)(5)(ii)

Corrective action report 63.9641(e)

A source must keep the following records:

Recordkeeping

Notifications and reports 63.9642(a)(1),

63.10(b)(2)(xiv)

Startups, shutdowns or malfunctions, periods where the continuous

monitoring system is inoperative. 63.9642(a)(2),

63.6(e)(3)(iii)

- (v)

Performance tests 63.9642(a)(3),

63.10(b)(2)(viii)

Records for continuous opacity mo nitoring system (COMS) 63.9642(b),

63.10(b)(2)(vi)

- (xi)

, 63.6(h)(7)(i)

- (ii)

, 63.8(d)(3)

Records required to demonstrate continuous compliance 63.9642(c),

63. 10(b)(2)(vii)

Electronic Reporting

Some of the r espondents are using monitoring equipment that automatically records

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

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

a plant site.

(ii) Respondent Activiti es

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid7

Respondent Activities

supply pressure for control device.

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 2F, 2G, 3, 3A, 3B,

4, 5, 5D, or 17 test s , and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, 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 info rmation.

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.

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

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 Enforcement and Compliance History Online (ECHO)

and ICIS.8

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 com ply

with the emission standard s

. 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.

Inform ation contained in the reports is reported by state and local governments in the

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is

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

and government

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

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

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

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

years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses ) affected by this regulation

.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Taconite Iron Ore

Processing (40 CFR Part 63, Subpart RRRRR) (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 stan dardized headings believed to be consistent with the

concept of “ burden ” under the Paperwork Reduction Act. Where appropriate, specific tasks and

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency ma y 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 f rom these recordkeeping9

and reporting requirement s is estimated to be 276 hours ( Total Labor Hours from Table 1

below ). T hese hours are based on Agency studies and background documen ts from the

development of the regulation, Agency knowledge and experience with the NESHAP program,

the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 66 + 110%)

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

2014

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

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

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the informat ion collection acti vities 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 monitor(s) and other costs su ch as photocopying and postage.

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

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

(A)

Continuous

Monitoring

Device (B)

Capital/Startup

Cost for One

Respondent (C)

Number of

New

Respondents (D)

Total

Capital/Startup

Cost, (B X C) (E)

Annual O&M

Costs for One

Respondent (F)

Number of

Respondents

with O&M (G)

Total O&M,

(E X F)

Scrubbers $150,000 0 $0 $12,900 4 $ 51,600

Baghouses $225,000 0 $0 $19,300 4 $ 77,200

Contractor

Method 5

PM test s 1 $0 0 $0 $ 42,167 4 $ 168,668

Total 2 $0 $ 29 8 ,000

1 We have assumed that over the three years of this ICR, contractors will complete the following performance tests :

( 27 indurating furnaces and ore dryer Method 5 PM tests @$8,000/test) + ( 58 OCH and PH Method 5 PM tests @10

$5,000/test) for a total of $ 506,00 0 for three years. Therefore, the average contractor costs will be $ 168,668 per year ($ 506 ,000/3 years).

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

The total capital/startup costs for this ICR are $0

. This is the total o f column D in the

above table.

The total operation and maintenance ( O&M) costs for this ICR are $ 298 ,000

. 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 $ 298 ,000

. 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 i ncludes activities such as the

examination of records maint ained by the respondents, periodic inspection of sources of

emissions, and the publication and distribution of collected information.

The average annual Agenc y cost during the three years of the ICR is estimated to be

$ 2, 680

.

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

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

, 20 1 4 General Schedule

, which excludes locality rates of pay. The rates have been increased by 60 percent to account for

the benefit packages available to governme nt employees

. Details upon which this estimate is

based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Taconite

Iron Ore Processing (40 CFR Part 63, Subpart RRRRR) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 4

existing respondents will be subject to the se standard s

. It is estimated that no additional

respondents per year will become subject. The overall av erage number of responden ts, as shown

in the table below, is 4 per year.

The number of respondents is calculated using the following table that addresses the three11

years covered by this ICR :

Number of Respondents

Respondents That Submit Reports Respondents That Do

Not Submit Any Reports

Year (A)

Number of New

Respondents 1 (B)

Number of

Existing

Respondents (C)

Number of Existing

Respondents that keep

records but do not

submit reports (D)

Number of

Existing

Respondents That

Are Also New

Respondents (E)

Number of

Respondents

(E=A+B+C

- D)

1 0 4 0 0 4

2 0 4 0 0 4

3 0 4 0 0 4

Average 4 4

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

C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the

average Number of Respondents over the three year period of this ICR is 4

.

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

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

Initial notification 0 1 0 0

Compliance extension requests 0 1 0 0

Site

- specific test plan 0. 32 1 0 0. 32

Operation and maintenance plan 0 1 0 0

Fugitive dust emission control

plan 0 1 0 0

Site

- specific monitoring plan 0 1 0 0

Semiannual compliance reports 4 2 0 8

Petition for alternative monitoring

requirements 0 1 0 0

Notification of performance tests 1.6 3 0 4.8

Total 1312

The number of Total Annual Responses is 13 (rounded)

.

The total annual labor costs are $ 27

, 8 00

. Details regarding these estimates may be found

below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Taconite Iron Ore

Processing (40 CFR Part 63, Subpart RRRRR) (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 below in Tables 1 and 2 below , respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 276 hours

. Details regarding these estimates may be

found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Taconite Iron Ore

Processing (40 CFR Part 63, Subpart RRRRR) (Renewal).

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

tasks because the typical tasks for managers are to review and approve reports. Cleri cal burdens

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

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

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

information is estimated to averag e 21 hours per response

.

The total annual capital/startup and O&M costs to the regulated entity are $ 298 ,000

. The

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to b e 59

labor hours at a cost of $ 2, 680

. See below in Table 2: Average Annual EPA Burden and Cost

–

NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR) (Renewal).

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

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens

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

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

6(f) Reasons for Change in Burden

There is an adjustment decrease in the respondent labor hours a nd the number of

responses as currently identified in the OMB Inventory of Approved Burdens. The decrease is13

due to a decline in the number of respondents. The previous ICR estimated eight functioning

facilities. Recent industry information indicates that only half of these facilities are currently in

operation.

There is , however, an adjustment increase in the respondent O&M costs. Th ere is not an

actual increase in cost; rather, t he increases occurred because this ICR accounts for contractor

costs associated with Method 5 PM tests as an O&M cost , while the previous ICR accounted for

this cost as a labor cost.

6(g) Burden Statement

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

is estimated to average 2 1 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; develo p,

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 pre viously 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 m ay 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 t his ICR under

Docket ID Number EPA

- HQ

- OECA

- 2012

- 0693

. 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 informat ion, 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 identif ied

in this document. The documents are also available for public viewing at the Enforcement and

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

Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Cen ter Public

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal

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

- 1744, and the telephone

number for the docket center 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

- 2012

- 0693 and OMB Control Number 2060

- 0538 in any

correspondence.14

Part B of the Supporting Statement

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

information.15

Table 1: Annual Respondent Burden and Cost

– NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart

RRRRR) (Renewal)

Burden Item (A)

Respondent

Hours per

Occurrence (B)

Number of

Occurrences

per

Respondent

per Year (C)

Hou rs per

Respondent

per Year

(C=AxB) (D)

Number of

Respondents

per Year a (E)

Technical

Hours

per Year

(E=CxD) (F)

Management

Hours per

Year

(F=Ex0.05) (G)

Clerical

Hours per

Year

(G=Ex0.1) (H)

Total

Labor

Costs

per

Year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Familiarize with regulatory

requirements c 2 1 2 4 8 0.4 0.8 $925.16

B. Required activities

Performance test

– facility labor e 40 1 40 1.6 64 3.2 6.4 $7,401.31

Startup , shutdown, and

malfunction plan 40 1 40 1.6 64 3.2 6.4 $7,401.31

C. Create information See 4B

D. Gather existing information See 4B

E. Write reports

Initial notification d 2 1 2 0 0 0 0 $0

Compliance extension request d 2 1 2 0 0 0 0 $0

Site

- specific test plan f 40 1 40 0. 32 12.8 0.64 1.28 $1,480.26

Operation and maintenance plan d, g 40 1 40 0 0 0 0 $0

Fugitive dust emission control plan

d, h 20 1 20 0 0 0 0 $0

Site

- specific monitoring plan d, i 80 1 80 0 0 0 0 $0

Semiannual compliance reports 8 2 16 4 64 3.2 6.4 $7,401.31

Petition for alternative monitoring 40 1 40 0 0 0 0 $016

requirements

Notification of performance test j 4 3 12 1.6 19.2 0.96 1.92 $2,220.39

Subtotal for Reporting Requirements 2 67 $ 2 6

, 830

4. Recordkeeping requirements

A. Familiarize with regulatory

requirements c See 3A

B. Plan activities 3 1 3 0 0 0 0 $0

C. Develop record system 16 1 16 0 0 0 0 $0

D. Time to train personnel 3 1 3 0 0 0 0 $0

E. Time to transmit or disclose

information 1 2 2 4 8 0.4 0.8 $925.16

F. Time for audits N/A

Subtotal for Recordkeeping

Requirements 9 $925

Total Labor Burden and Cost

(rounded) k 2 76 $ 27

, 8 00

Total Capital and O&M Costs

(rounded) k $298,000

Grand Total (rounded) k $ 32 6 ,000

Assumptions:

a We have assumed that the average number of respondent that will be subject to the rule will be the eight existing respondents. There will be no additional new

sources per year that will become subject to the rule over the three

- year period of this ICR.

b T his ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $5 1.79 ($24.66 + 110%).

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry

group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those

employed by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

c This ICR assumes all respondents will have to familiarize with the regulatory requirements each year.

d This is a one

- time activity.

e We have assumed that it will take 40 hours for each facility to complete performance test, and that performance tests are repeat ed every two of five years.

Therefore, an average of 3.2 facilities per year will complete performance tests (2 performance test/5 years*8 facilities).

f We have assumed that 20 percent of all sources will send in a site

- specific test plan.

g We have assumed that each respondent will take 40 hours to write the operation and maintenance plan.17

h We have assumed that each respondent will take 20 hours to write the fugitive dust emission control plan.

i We have assumed that each respondent will take 80 hours to complete the site

- specific monitoring plan report.

j We have assumed that each respondent will take 4 hours to complete the notification of performance test report.

k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.18

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart

RRR RR)

Burden Item (A)

EPA Hours

per

Occurrence (B)

Number of

Occurrences

per Plant

per Year (C)

EPA

Hours

per

Plant

per Year

(C=AxB) (D)

Plants

per

Year a (E)

Technical

Hours

per Year

(E=CxD) (F)

Management

Hours per

Year

(F=Ex0.05) (G)

Clerical

Hours per

Year

(G=Ex0.1) (H)

Costs

per

Year

($) b

Initial performance tests c, d 8 7 56 0 0 0 0 $0

Report Review

Initial notification c 2 1 2 0 0 0 0 $0

Notification of initial

performance test c 2 3 6 0 0 0 0 $0

Fugitive dust emissions control

plan e 10 1 10 0 0 0 0 $0

Compliance extension request 2 1 2 0 0 0 0 $0

Site

- specific test plan f 10 1 10 0. 32 3.2 0.16 0.32 $167.49

Operation and maintenance

plan c, f 10 1 10 0 0 0 0 $0

Site

- specific monitoring plan c, f 10 1 10 0 0 0 0 $0

Petition for alternative

monitoring requirements 5 1 5 0 0 0 0 $0

Review of semiannual

compliance report 4 2 8 4 32 1.6 3.2 $1,674.8

8

Review of startup , shutdown,

and malfunction plan g 10 1 10 1.6 16 0.8 1.6 $837.44

Total Labor Burden and Cost

(rounded) h 59 $2, 68 019

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be the eight existing respondents. There will be no additional new

sources per year that will become subject to the rule over the three

- year period of this ICR.

b T his cost is based on the average hourly labor rate as follows: Technical $46.67 (GS

- 12, Step 1, $29.17 + 60%); Managerial $62.90 (GS

- 13, Step 5, $39.31 +

60%); and Clerical $25.25 (GS

- 6, Step 3, $15.78 + 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, 2014 General Schedule, which excludes locality rates of pay. The rates have been increased by 60

percent to account for the benefit packages a vailable to government employees.

c This is a one

- time only activity.

d We have assumed that the initial performance test/occurrences per respondent are based on the following: ( 27 indurating furnaces and ore dryer Method 5 PM

tests + 58 OCH and PH Method 5 PM tests) for a total of 85 Method 5 PM tests over three years. 85 tests/3 years = 28 Method 5 PM tests/year. ( 28 Method 5

PM tests/year)/( 4 plants) = 7 Method 5 PM tests per year per plant.

e We have assumed that each of the fugitive dust emissions control plan will be unchanged.

f We have assumed that it will take each respondent 10 hours to review the plan.

g We have assumed that 40 percent of respondents will submit startup, shutdown, and malfunction plan/reports.

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