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 

Iron 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 

HAPs at a rate of 25 tons or more per year. The effective sources in this Subpart 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 reconstruction 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 reports, performance tests, 

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

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

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

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

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file 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 20161. None of these

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 Federal 

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, Subpart 

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, approximately 4 respondents per year will be subject to these

standards, and no additional respondents per year will become subject to these same standards.

This estimate is based on industry-specific information that indicates approximately half 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 sources of hazardous 

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

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

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

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

either cause or contribute to air pollution that may reasonably be anticipated to endanger public 
3

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 emission standards. Continuous emission monitors are used to 

ensure compliance with these standards 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 these standards are used to inform the Agency or delegated 

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

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

installed and operated, leaks are being detected and repaired and the standards 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 and 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 similar standards to implement the 

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

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

not exist.

3(b) Public Notice Required Prior to ICR Submission to OMB

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

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

burden published in the Federal Register.
4

3(c) Consultations

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

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

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

provisions in the standards, 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-owned facilities. 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 these standards as they were being developed and that 

the standards have been reviewed previously to determine the minimum information needed for 

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

Association, 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 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 these standards. Requirements for information gathering and 

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of a 

source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

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

nonexistence of essential records.
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, 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 these standards 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

In 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:

Notifications/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

Notifications/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 monitoring 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 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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 
7

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 tests, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

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 comply 

with the emission standards. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

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

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

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

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

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

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

years.

5(c) Small Entity Flexibility

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 standardized headings believed to be consistent with the 

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

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

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

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

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 
9

and reporting requirements is estimated to be 276 hours (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 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 $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

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

the benefit packages available to those employed by private industry.

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

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

subject standard 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 such 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 tests1

$0 0 $0 $42,167 4 $168,668

Total2 $0 $298,000

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 $506,000 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 of 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 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 

$2,680.

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

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

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

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

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

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

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for 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 these standards. It is estimated that no additional

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 4 per year.

The number of respondents is calculated using the following table that addresses the three 
11

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.

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 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 13
12

The number of Total Annual Responses is 13 (rounded).

The total annual labor costs are $27,800. 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. Clerical burdens 

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

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

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

information is estimated to average 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 be 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 take 10% of the time required for technical tasks because the typical duties of 

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

6(f) Reasons for Change in Burden

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

responses as currently identified in the OMB Inventory of Approved Burdens. The decrease is 
13

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. There is not an 

actual increase in cost; rather, the 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 21 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-2012-0693. 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 information, submit or view public comments, access the index listing of the 

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

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

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

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

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

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

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

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-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) 

Hours 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 $0 
16

requirements

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

Subtotal for Reporting Requirements 267 $26,830

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 276 $27,800 

Total Capital and O&M Costs 

(rounded)k $298,000 

Grand Total (rounded)k $326,000 

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

 This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). 

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

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

employed by private industry. 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 repeated 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 

RRRRR)

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 

plane 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 $1,674.88 

 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 $2,680 
19

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

 This 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 available 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.