SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese

(40 CFR Part 63, Subpart XXX) (Supplemental Proposed Rule)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, 

Subpart XXX), EPA ICR Number 2448.02, OMB Control Number 2060-NEW.

1(b) Short Characterization/Abstract

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

regulations published at 40 CFR subpart XXX were proposed on August 4, 1998, promulgated 

on May 20, 1999, and amended most recently on March 22, 2001. The purpose of this 

information collection request is to document the expected impacts of proposed addition of 

proposed changes to subpart XXX that are being developed as part of the risk and technology 

review process of the current subpart XXX. Subpart XXX would continue to apply to new and 

existing ferroalloys production facilities that manufacture ferromanganese and silicomanganese, 

and that are either major sources of hazardous air pollutants (HAPs) emissions or are co-located 

at major sources of HAPs. The following affected facilities at ferroalloy production plants are 

subject to this NESHAP rule: submerged arc furnaces; casting operations, metal oxygen refining 

(MOR) process; crushing and screening operations; and fugitive dust sources. New sources 

include those that commenced construction or reconstruction after the date of the supplemental 

proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart 

XXX.

Compared to existing subpart XXX, the proposed changes would increase the number of 

pollutants and sources regulated and add requirements for continuous monitoring and periodic 

testing. In addition, the proposed rule would eliminate the startup, shutdown and malfunction 

(SSM) exemption, remove the SSM plan requirement and add a requirement for electronic 

submittal of performance tests.

In general, all NESHAP standards require initial notifications, performance tests, 

monitoring and periodic reports by the owners/operators of the affected facilities. 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 of these 

measurements, and retain the file for at least 5 years following the date of such measurements, 
2

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

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

Over the next 3 years, an average of two respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. Based on 

our consultations with industry representatives, there are two plants that are currently subject to 

subpart XXX and both would be subject to the proposed revisions to XXX. The facilities subject 

to this rule have the ability to comply with the reporting requirements electronically.

The burden to respondents is calculated in Tables 1, 2, and 3 of Attachment 1: Annual 

Respondent Burden and Cost of Reporting and Recordkeeping for Ferroalloys Production: 

Ferromanganese and Silicomanganese. Since this regulation only affects the ferroalloys 

production industry, the burden to the “Federal Government” is attributed entirely to work 

performed by Federal employees or government contractors. This burden is calculated in Tables

5, 6, and 7 of Attachment 1: Annual Burden and Cost to the Federal Government for Ferroalloys 

Production: Ferromanganese and Silicomanganese.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

Section 112 of the Clean Air Act (CAA) requires the EPA to establish NESHAP for both 

major and area sources of HAP that are listed for regulation under CAA section 112(c). A major 

source is a stationary source that emits or has the potential to emit more than 10 tons per year 

(tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a 

stationary source that is not a major source (i.e., an area source does not emit and does not have 

the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any 

combination of HAP). For major sources, these technology-based standards must reflect the 

maximum degree of emission reductions of HAP achievable (after considering cost, energy 

requirements, and non-air quality health and environmental impacts) and are commonly referred 

to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires the 

EPA to review these technology-based standards and to revise them “as necessary (taking into 

account developments in practices, processes, and control technologies)” no less frequently than 

every 8 years. In addition, section 112(f) of the CAA requires the EPA to determine for source 

categories subject to certain CAA section 112(d) standards whether the emissions limitations 

provide an ample margin of safety to protect public health. For MACT standards for HAP 

“classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime 

excess cancer risks to the individual most exposed to emissions from a source in the category or 

subcategory to less than 1-in-1 million,” the EPA must promulgate residual risk standards for the 

source category (or subcategory) as necessary to provide an ample margin of safety to protect 
3

public health. In doing so, the EPA may adopt standards equal to existing MACT standards, if 

the EPA determines that the existing standards are sufficiently protective. The EPA must also

adopt more stringent standards, if necessary, to prevent an adverse environmental effect, but 

must consider cost, energy, safety, and other relevant factors in doing so.

Certain records and reports are necessary for the Administrator to confirm the compliance

status of sources subject to NESHAP, identify any new or reconstructed sources subject to the

standards, and confirm that the standards are being achieved on a continuous basis. These

recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean

Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The

recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 

40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 

years following the date of each occurrence, measurement, maintenance, corrective action, 

report, or record.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance with 

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

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

Performance tests for air pollution devices 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 that the control equipment is operating properly and therefore, ensure 

compliance with the 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 the 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 ensure that the pollution control devices are properly 

installed and operated; that leaks are being detected and repaired; and that the standards are 

being met. The performance test may also be observed.

The required semiannual compliance status reports and quarterly excess emissions reports 

are used to determine periods of excess emissions, identify problems at the facility, verify 

operation/maintenance procedures and for compliance determinations.
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3. Non-duplication, Consultations, and Other Collection Criteria

A computer search of the EPA’s ongoing ICRs revealed no duplication of informationgathering efforts.

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, no duplication 

exists.

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

The preamble to the proposed rule will provide public notice.

3(c) Consultations

The proposed rule amendments were developed using extensive consultation with 

individual companies and state agencies. Several of the key non-EPA persons consulted on the 

information collection activities are identified in Table 1. Additional meetings and contacts are 

documented in the project docket for this proposed rule, Docket No. EPA-HQ-OAR-2009-0734.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION 

ACTIVITIES

Contact Organization Telephone Number

Jeffrey McKinney Eramet Marietta, Inc. 740-374-1143

John Konrady Felman Production 304-882-1181

James Robertson West Virginia Department of Environmental 

Protection

304-926-0499

Christina Wieg Ohio EPA 740-380-5223

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 
5

possibility of detecting violations would be less likely.

3(e) General Guidelines

None of the guidelines in 5 CFR 1320.6 are being exceeded. 

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

(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are the owners or 

operators of all new and existing ferroalloys production facilities that are major sources or are 

co-located at major sources. The affected facilities produce either ferromanganese or 

silicomanganese. The North American Industry Classification System (NAICS) code is 331112, 

“Electrometallurgical Ferroalloy Product Manufacturing.”

There are two facilities that will be subject to the proposed amendments to the NESHAP. 

No new ferroalloys production facilities are expected during the 3-year period of this ICR.

4(b) Information Requested

i) Data Items

Attachment 2, Information Requirements, summarizes the data items, including 

recordkeeping and reporting requirements, for the Ferroalloys Production source category. The 

amendments to the NESHAP require that any performance tests performed after the effective 

date of the final rule be submitted electronically to EPA’s Central Data Exchange by using the 

Electronic Reporting Tool (ERT) for test methods that are compatible with ERT. This new 

requirement to submit the data to the ERT is in addition to the other existing submission 

requirements for this data.
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(ii) Respondent Activities

The respondent activities that will be required by the proposed amendments to the 

Ferroalloys Production NESHAP are identified in Tables 1 through 3 of Attachment 1 and are 

introduced in section 6(a).

This illustrative estimate is not considered a duplicate estimate of cost under the General

Duty to Minimize Emissions clause under §63.6(e)(1)(i), which states: “At all times, the owner 

and operator must operate and maintain any affected source, including associated air pollution 

control equipment and monitoring equipment, in a manner consistent with safety and good air 

pollution control practices for minimizing emissions. Determining whether such operation and 

maintenance procedures are being used will be based on information available to the 

Administrator which may include, but is not limited to, monitoring results, review of operation 

and maintenance procedures, review of operation and maintenance records, and inspection of the 

source.”

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

The Agency activities associated with the proposed amendments to the Ferroalloys 

Production NESHAP are provided in Tables 5 through 7 of Attachment 1 and are introduced in 

section (6)(c). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to 

determine whether the pollution control devices are properly installed and 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 quarterly excess emissions 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 the EPA Air Facility Subsystem 

(AFS) which is operated and maintained by the EPA Office of Compliance. AFS is the EPA 

database for the collection, maintenance, and retrieval of compliance data for approximately 

125,000 industrial and government-owned facilities. The EPA uses the AFS for tracking air 

pollution compliance and enforcement by local and state regulatory agencies, EPA regional 

offices and EPA headquarters. The EPA and its delegated Authorities can edit, store, retrieve and 

analyze the data.
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The records required by this regulation must be retained by the owner/operator for 5

years.

5(c) Small Entity Flexibility

For this source category, which has the NAICS code 331112 (i.e., Electrometallurgical 

ferroalloy product manufacturing), the Small Business Administration (SBA) small business size 

standard is 750 employees according to the SBA small business standards definitions. We have 

determined that there are no small businesses affected by this regulation at this time. The Agency 

considers the final rule requirements the minimum needed to ensure compliance with the 

standards.

5(d) Collection Schedule

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

shown in Tables 1-3 of Attachment 1 for the Ferroalloys Production source category.

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

The annual burden estimates for the proposed amendments to the Ferroalloys Production 

NESHAP are shown in Tables 1 through 3 of Attachment 1. These numbers were derived from 

estimates based on the EPA’s experience with other standards. No burden estimates are provided 

for new sources because no new facilities are expected to become affected sources during the 3-

year period of this ICR.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

We used May 2012 mean hourly labor rates from the Bureau of Labor Statistics for the 

Iron and Steel Mills and Ferroalloy Manufacturing (NAICS 331100).

1 Loading factors (i.e., 

fringe benefits and overhead rates) were calculated using methodologies referenced in 

promulgated regulations and their accompanying Information Collection Requests (ICRs), 

particularly those used in New Source Review (NSR) regulations. Fringe benefits are calculated 

as 29% of hourly earnings, and overhead is calculated using a standard 110% above hourly 

earnings. Table 2 presents the labor rates used in the cost analysis. 

 

1 May 2012 National Industry-Specific Occupational Employment and Wage Estimates. Located 

http://www.bls.gov/oes/current/naics4_331100.htm#11-0000
8

TABLE 2. 2012 LOADED LABOR RATES

Hourly earnings 

[$2014] Fringe Overhead

Loaded 2012

Hourly 

Earnings ($)

Professional specialty and 

technical (environmental 

engineer) 39.19 1.29 2.10 $106.17

Executive, admin, managerial

(managers, all other) 54.08 1.29 2.10 $146.50

Admin support (office clerk) 14.82 1.29 2.10 $40.15

To estimate the costs of conducting the initial performance tests, we assumed that 

facilities would hire a contractor. We show these cost as one-time expense in the 3-year ICR

period.

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

The capital costs associated with the NESHAP include monitoring system initial costs;

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 conducting stack testing.

We assumed that facilities would purchase and begin to operate all required monitoring systems 

in Year 2 of the ICR, which is also the year we assumed they would conduct their initial 

performance tests.

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

The estimated capital and O&M costs for the affected units for the first 3 years after

promulgation are provided. For the two facilities, the total capital costs are $380,148. The total

annualized capital and O&M costs are $2,322,036 for an average of $774,012 per year.

6(c) Estimating Agency Burden and Cost

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

information. The overall compliance and enforcement program of EPA 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 3 years of the ICR is estimated to be $2,220.

The Agency labor rates are from the Office of Personnel Management (OPM) 2015

General Schedule, which excludes locality rates of pay. These rates can be obtained from Salary 

Table 2015-GS available on the OPM website, https://www.opm.gov/policy-data-oversight/payleave/salaries-wages/2015/general-schedule/.
9

Managerial $63.52 (GS-13, Step 5, $39.70+ 60%)

Technical $47.14 (GS-12, Step 1, $29.46+ 60%)

Clerical $25.50 (GS-6, Step 3, $15.94 + 60%)

These rates were increased by 60 percent to include fringe benefits and overhead 

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

There are two existing facilities that are subject to the proposed Ferroalloys Production 

NESHAP. No new sources are expected during the 3-year compliance period. No new facilities

are expected to begin operation during the 3-year compliance period. Over the 3-year period, it is

estimated that these two facilities will have 34 responses for an average of 11 per year.

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

(i) Respondent Tally

The bottom line respondent burden hours and costs, presented in Tables 1-3 of 

Attachment 1 are calculated by adding person-hours per year down each column for technical, 

managerial, and clerical staff, and by adding down the cost column. The average annual burden 

for the recordkeeping and reporting requirements in the proposed amendments to subpart XXX 

for the two existing facilities that are subject to the Ferroalloys Production NESHAP is 

$782,012. This includes 707 annual labor hours. The detailed bottom line burden hours and cost 

calculations for the respondents and the Agency are shown in Tables 1, 2, and 3 of Attachment 1, 

respectively.

(ii) The Agency Tally

The average annual Federal Government cost is $2,220 for 48 hours for the proposed

amendments to subpart XXX. The bottom line Agency burden hours and costs presented in 

Tables 5 through 7 of Attachment 1 are calculated by adding person-hours per year down each 

column for technical, managerial, and clerical staff, and by adding down the cost column.

6(f) Reasons for Change in Burden

We are requesting an increase in burden of $726,056 over the full 3-year program due to 

implementation of these proposed changes to the regulation. 

6(g) Burden Statement

The average annual respondent burden for the proposed amendments to the Ferroalloys 

Production NESHAP is estimated at 354 hours per facility or 71 hours per response.
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Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information.

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

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

Numbers for the EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, the EPA has established a public docket for this ICR 

under Docket ID Number EPA-HQ-OAR-2010-0895. An electronic version of the public docket 

is available at http://www.regulations.gov. This site can be used to submit or view public 

comments, access the index listing of the contents of the public 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 above. The docket is also available for in 

person viewing at the Air and Radiation 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 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 Air Docket is (202) 566-1742. Also, you may 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 relevant Docket ID Number (EPA-HQ-OAR-2010-0895) in any correspondence.

Part B of the Supporting Statement

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

information.
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ATTACHMENT 1

Burden Estimate Tables 1 through 8

Tables 1 through 3: Annual Respondent Burden and Cost of Recordkeeping and Reporting 

Requirements of the Proposed Standard , Years 1 through 3

Table 4: Summary of Annual Respondent Burden and Cost of Recordkeeping and 

Reporting of the Proposed Standard

Tables 5 through 7: Annual Burden and Cost to the Federal Government of the Proposed

Standard, Years 1 through 3

Table 8: Summary of Annual Burden and Cost to the Federal Government of the 

Proposed Standard
(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L)

Person-hours 

per 

occurrence

Contractor 

cost per 

occurrence

Other nonlabor costs 

per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person-hours 

per 

respondent 

per year

Respondents 

per year

Technical 

person-hours 

per year

Management 

person-hours 

per year

Clerical 

person-hours 

per year

Total labor 

costs per 

year

Total nonlabor costs 

per year

Total number 

of responses 

per year

(AxD) (ExF) (Gx0.05) (Gx0.1) ((B+C)xDxF) (DxF)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read instructions (b) 2.0 1.0 2.0 2.0 4.0 0.4 0.4 $499 $0 0

B. Required activities

 a. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - Furnace PP FF 15.0 $200,000 3.0 45.0 0.0 0.0 0.0 0.0 $0 $0 0

 b. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - Furnace NP FF/Scrbr 15.0 $52,000 3.0 45.0 0.0 0.0 0.0 0.0 $0 $0 0

 c. Initial Compliance test (PM) -- MOR/Local Vent./Crushing sources NP FF 15.0 $5,000 2.0 30.0 0.0 0.0 0.0 0.0 $0 $0 0

 d. Weekly Method 9 (c) 2.0 104.0 208.0 0.0 0.0 0.0 0.0 $0 $0 0

 Initial Capital 2.0 $9,800 1.0 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 2.0 $258,000 1.0 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 e. Pressure drop/liquid flow rate CPMS-scrubber

 Initial Capital 2.0 $50,000 1.0 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 2.0 $18,000 1.0 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 f. Bag Leak Detection System 

 Initial Capital 4.0 $269,148 0.5 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 4.0 $219,078 0.5 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 g. Ductwork flow rate monitoring 

 Initial Capital 2.0 $41,400 0.5 1.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 2.0 $4,140 0.5 1.0 0.0 0.0 0.0 0.0 $0 $0 0

 h. Furnace Capture System Inspection (Quarterly) 2.0 10.0 20.0 0.0 0.0 0.0 0.0 $0 $0 0

 i. Annual Compliance test - Furnace Scrbr (PM, Hg), Furnace FF (Hg) 20.0 $5,000 1.0 20.0 0.0 0.0 0.0 0.0 $0 $0 0

 j. Quarterly Compliance test - Furnace FF (PAH) 20.0 $10,000 4.0 80.0 0.0 0.0 0.0 0.0 $0 $0 0

C. Create information See 3B $0

D. Gather existing information See 3B $0

E. Write report $0

 a. Initial Notification N/A

 b. Notification of Compliance Status 4.0 1.0 4.0 0.0 0.0 0.0 0.0 $0 $0 0

 c. Annual Compliance Certification (d) 10.0 1.0 10.0 0.0 0.0 0.0 0.0 $0 $0 0

 d. Develop process fugives ventilation plan 80.0 $250,000 1.0 80.0 2.0 160.0 1.0 16.0 $17,775 $500,000 2

 e. Update fugitive dust control plan 10.0 1.0 10.0 2.0 20.0 1.0 2.0 $2,350 $0 2

 f. Update baghouse monitoring plan 10.0 1.0 10.0 2.0 20.0 1.0 2.0 $2,350 $0 2

 g. Develop bagleak detection system SOP 20.0 1.0 20 2.0 40 1 4 $4,554 $0 2

Reporting Subtotal 140.0 598.0 10.0 244.0 4.4 24.4 $27,529 $500,000 8.0

4. Recordkeeping Requirements

A. Read instructions See 3A $0 0

B. Implement activities N/A $0 0

C. Develop record system N/A $0 0

D. Time to enter information

E. Records of all info. required by standards (e) 1.0 60.0 60.0 0.0 0.0 0.0 0.0 $0 $0 0

F. Time to train personnel 20.0 1.0 20.0 2.0 40.0 1.0 4.0 $4,554 $0 0

G. Time for audits N/A 0.0 0.0 $0 $0 0

Recordkeeping Subtotal 61.0 80.0 2.0 40.0 1.0 4.0 $4,554 $0 0

TOTAL 201.0 678.0 12.0 284.0 5.4 28.4 $32,082 $500,000 8.0

Total Hours Labor Cost Non-Labor Total

Summary of respondent burden 318 $32,082 $500,000 $ 532,082

Initial capital and startup $0

Annualized Capital/startup and O&M $500,000

N/A = Not Applicable.

(a) Costs are based on the following hourly rates: technical at $106.17, management at $146.50, and clerical at $40.15.

(b) One-time activity. There are an estimated 2 existing ferroalloys production facilities and no new facilities are expected.

(c) Weekly method 9, with initial tests estimated to occur in Year 2 of ICR. Assumes DCOT camera systems. 

(d) The 2 existing plants would be required to submit an Annual Compliance Certification at the end of Year 2 of the ICR and each year thereafter.

(e) Recordkeeping requirements begin in Year 2 of ICR clearance period for all existing plants.

TABLE 1. YEAR 1 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE
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(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L)

Person-hours 

per 

occurrence

Contractor 

cost per 

occurrence

Other nonlabor costs 

per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person-hours 

per 

respondent 

per year

Respondents 

per year

Technical 

person-hours 

per year

Management 

person-hours 

per year

Clerical 

person-hours 

per year

Total labor 

costs per 

year

Total nonlabor costs 

per year

Total number 

of responses 

per year

(AxD) (ExF) (Gx0.05) (Gx0.1) ((B+C)xDxF) (DxF)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read instructions (b) 20.0 1.0 20.0 0.0 0.0 0.0 0.0 $0 $0 0

B. Required activities

 a. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - Furnace PP FF 15.0 $200,000 3.0 45.0 1.0 45.0 0.5 4.5 $5,031 $600,000 3

 b. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - Furnace NP FF/Scrbr 15.0 $52,000 3.0 45.0 1.0 45.0 0.5 4.5 $5,031 $156,000 3

 c. Initial Compliance test (PM) -- Bldg Vent./#12 casting/misc. sources NP FF 15.0 $5,000 2.0 30.0 2.0 60.0 1.0 6.0 $6,757 $20,000 4

 d. Weekly Method 9 (c) 2.0 104.0 208.0 2.0 416.0 1.0 41.6 $45,982 $0 0

 Initial Capital 2.0 $9,800 1.0 2.0 2.0 4.0 1.0 0.4 $587 $19,600 0

 Annual (O&M) 2.0 $258,000 1.0 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 e. Pressure drop/liquid flow rate CPMS-scrubber

 Initial Capital 2.0 $50,000 1.0 2.0 1.0 2.0 0.5 0.2 $294 $50,000 0

 Annual (O&M) 2.0 $18,000 1.0 2.0 0.0 0.0 0.0 0.0 $0 $0 0

 f. Bag Leak Detection System 

 Initial Capital 4.0 $269,148 0.5 2.0 2.0 4.0 1.0 0.4 $587 $269,148 0

 Annual (O&M) 4.0 $219,078 0.5 2.0 2.0 4.0 1.0 0.4 $587 $219,078 0

 g. Ductwork flow rate monitoring 

 Initial Capital 2.0 $41,400 0.5 1.0 2.0 2.0 1.0 0.2 $367 $41,400 0

 Annual (O&M) 2.0 $4,140 0.5 1.0 2.0 2.0 1.0 0.2 $367 $4,140 0

 h. Furnace Capture System Inspection (Quarterly) 2.0 10.0 20.0 0.0 0.0 0.0 0.0 $0 $0 0

 i. Annual Compliance test - Furnace Scrbr (PM, Hg), Furnace FF (Hg) 20.00 $5,000 1.0 20.0 0.0 0.0 0.0 0.0 $0 $0 0

 j. Quarterly Compliance test - Furnace FF (PAH) 20.00 $10,000 4.0 80.0 0.0 0.0 0.0 0.0 $0 $0 0

C. Create information See 3B $0

D. Gather existing information See 3B $0

E. Write report $0

 a. Initial Notification N/A

 b. Notification of Compliance Status 4.0 1.0 4.0 0.0 0.0 0.0 0.0 $0 $0 0

 c. Annual Compliance Certification (d) 10.0 1.0 10.0 2.0 20.0 1.0 2.0 $2,350 $0 2

 d. Develop process fugives ventilation plan 80.0 $250,000 1.0 80.0 0.0 0.0 0.0 0.0 $0 $0 0

 e. Update fugitive dust control plan 10.0 1.0 10.0 0.0 0.0 0.0 0.0 $0 $0 0

 f. Update baghouse monitoring plan 10.0 1.0 10.0 0.0 0.0 0.0 0.0 $0 $0 0

 g. Develop bagleak detection system SOP 20.0 1.0 20 0.0 0 0 0 $0 $0 0

Reporting Subtotal 140.0 616.0 19.0 604.0 9.5 60.4 $67,941 $1,018,818 12.0

4. Recordkeeping Requirements

A. Read instructions See 3A $0 0

B. Implement activities N/A $0 0

C. Develop record system N/A $0 0

D. Time to enter information

E. Records of all info. required by standards (e) 1.0 60.0 60.0 2.0 120.0 1.0 12.0 $13,368 $0 0

F. Time to train personnel 20.0 1.0 20.0 2.0 40.0 1.0 4.0 $4,554 $0 0

G. Time for audits N/A 0.0 0.0 $0 0

Recordkeeping Subtotal 61.0 80.0 4.0 160.0 2.0 16.0 $17,922 $0 0

TOTAL 201.0 696.0 23.0 764.0 11.5 76.4 $85,863 $1,018,818 12.0

Total Hours Labor Cost Non-Labor Total

Summary of respondent burden 852 $85,863 $1,018,818 $ 1,104,681

Initial capital and startup $380,148

Annualized Capital/startup and O&M $1,018,818

N/A = Not Applicable.

(a) Costs are based on the following hourly rates: technical at $71.95, management at $115.94, and clerical at $34.17. 

(b) One-time activity. There are an estimated 2 existing ferroalloys production facilities and no new facilities are expected.

(c) Weekly method 9, with initial tests estimated to occur in Year 2 of ICR. Assumes in-house readers. 

(d) The 2 existing plants would be required to submit an Annual Compliance Certification at the end of Year 2 of the ICR and each year thereafter.

(e) Recordkeeping requirements begin in Year 2 of ICR clearance period for all existing plants.

TABLE 2. YEAR 2 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE
14

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L)

Person-hours 

per 

occurrence

Contractor 

cost per 

occurrence

Other nonlabor costs 

per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Person-hours 

per 

respondent 

per year

Respondents 

per year

Technical 

person-hours 

per year

Management 

person-hours 

per year

Clerical 

person-hours 

per year

Total labor 

costs per 

year

Total nonlabor costs 

per year

Total number 

of responses 

per year

(AxD) (ExF) (Gx0.05) (Gx0.1) ((B+C)xDxF) (DxF)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read instructions (b) 20.0 1.0 20.0 0.0 0.0 0.0 0.0 $0 $0 0

B. Required activities

 a. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - Furnace PP FF 15.0 $200,000 3.0 45.0 0.0 0.0 0.0 0.0 $0 $0 0

 b. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - Furnace NP FF/Scrbr 15.0 $52,000 3.0 45.0 0.0 0.0 0.0 0.0 $0 $0 0

 c. Initial Compliance test (PM) -- Bldg Vent./#12 casting/misc. sources NP FF 15.0 $5,000 2.0 30.0 0.0 0.0 0.0 0.0 $0 $0 0

 d. Weekly Method 9 (c) 2.0 104.0 208.0 2.0 416.0 1.0 41.6 $45,982 $0 0

 Initial Capital 2.0 $9,800 1.0 0.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 2.0 $258,000 1.0 2.0 2.0 4.0 1.0 0.4 $587 $516,000 0

 e. Pressure drop/liquid flow rate CPMS-scrubber

 Initial Capital 2.0 $50,000 1.0 0.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 2.0 $18,000 1.0 2.0 1.0 2.0 0.5 0.2 $294 $18,000 0

 f. Bag Leak Detection System 

 Initial Capital 4.0 $269,148 0.5 0.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 4.0 $219,078 0.5 2.0 2.0 4.0 1.0 0.4 $587 $219,078 0

 g. Ductwork flow rate monitoring 

 Initial Capital 2.0 $41,400 0.5 0.0 0.0 0.0 0.0 0.0 $0 $0 0

 Annual (O&M) 2.0 $4,140 0.5 1.0 2.0 2.0 1.0 0.2 $367 $4,140 0

 h. Furnace Capture System Inspection (Quarterly) 2.0 10.0 20.0 2.0 40.0 1.0 4.0 $4,554 $0 0

 i. Annual Compliance test - Furnace Scrbr (PM, Hg), Furnace FF (Hg) 20.0 $5,000 3.0 60.0 2.0 120.0 1.0 12.0 $13,368 $30,000 6

 j. Quarterly Compliance test - Furnace FF (PAH) 20.00 $10,000 4.0 80.0 1.0 80.0 0.5 8.0 $8,888 $40,000 4

C. Create information See 3B $0

D. Gather existing information See 3B $0

E. Write report $0

 a. Initial Notification N/A

 b. Notification of Compliance Status 4.0 1.0 4.0 2.0 8.0 1.0 0.8 $1,028 $0 2

 c. Annual Compliance Certification (d) 10.0 1.0 10.0 2.0 20.0 1.0 2.0 $2,350 $0 2

 d. Develop process fugives ventilation plan 80.0 $250,000 1.0 80.0 0.0 0.0 0.0 0.0 $0 $0 0

 e. Update fugitive dust control plan 10.0 1.0 10.0 0.0 0.0 0.0 0.0 $0 $0 0

 f. Update baghouse monitoring plan 10.0 1.0 10.0 0.0 0.0 0.0 0.0 $0 $0 0

 g. Develop bagleak detection system SOP 20.0 1.0 20.0 0.0 0 0 0 $0 $0 0

Reporting Subtotal 142.0 649.0 18.0 696.0 9 69.6 $78,004 $827,218 14.0

4. Recordkeeping Requirements

A. Read instructions See 3A $0 0

B. Implement activities N/A $0 0

C. Develop record system N/A $0 0

D. Time to enter information

E. Records of all info. required by standards (e) 1.0 60.0 60.0 2.0 120.0 1.0 12.0 $13,368 $0 0

F. Time to train personnel 20.0 1.0 20.0 2.0 40.0 1.0 4.0 $4,554 $0 0

G. Time for audits N/A 0.0 0.0 $0 0

Recordkeeping Subtotal 61.0 80.0 4.0 160.0 2.0 16.0 $17,922 $0 0

TOTAL 203.0 729.0 22.0 856.0 11.0 85.6 $95,926 $827,218 14.0

Total Hours Labor Cost Non-Labor Total

Summary of respondent burd 953 $95,926 $827,218 $ 923,144

Initial capital and startup $0

Annualized Capital/startup and O&M $827,218

N/A = Not Applicable.

(a) Costs are based on the following hourly rates: technical at $71.95, management at $115.94, and clerical at $34.17. 

(b) One-time activity. There are an estimated 2 existing ferroalloys production facilities and no new facilities are expected.

(c) Weekly method 9, with initial tests estimated to occur in Year 2 of ICR. Assumes in-house readers. 

(d) The 2 existing plants would be required to submit an Annual Compliance Certification at the end of Year 2 of the ICR and each year thereafter.

(e) Recordkeeping requirements begin in Year 2 of ICR clearance period for all existing plants.

TABLE 3. YEAR 3 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE
15

Year Technical Hours Clerical Hours

Management 

Hours

Total Labor 

Hours Labor Cost

Non-Labor 

(annualized 

Capital/Startup 

and O&M) Costs Total Costs

1 284 28 5 318 $32,082 $500,000 $532,082

2 764 76 12 852 $85,863 $1,018,818 $1,104,681

3 856 86 11 953 $95,926 $827,218 $923,144

Total 1,904 190 28 2,122 $213,871 $2,346,036 $2,559,907

Average 635 63 9 707 $71,290 $782,012 $853,302

TABLE 4. SUMMARY OF ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR 

FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE
16

TABLE 5. YEAR 1 ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE

(A) (B) (C) (D) (E) (F) (G) (H)

EPA personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants per 

year

Technical 

person-hours 

per year

Management 

person-hours 

per year

Clerical 

person-hours 

per year Cost,$ (a)

Activity (C=AxB) (CxD) (Ex0.05) (Ex0.1)

Report Review

 Initial Notification (b) 1.0 1.0 1.0 0.7 0.7 0.0 0.1 $35

 Notification of Compliance Status (c) 10.0 1.0 10.0 0.7 6.7 0.3 0.7 $352

 Annual Compliance Certification (d) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $211

 Report of Exceedence (e) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $211

 Review compliance monitoring plans prepared by plants 10.0 0.0 0.0 2.0 0.0 0.0 0.0 $0

TOTAL BURDEN AND COST (SALARY) 15.3 0.8 1.5 $811

(a) Costs are based on the following hourly rates: technical at $53.17, management at $62.90, and clerical at $37.87. 

 Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

(b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1.

(c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/yr in Year 1.

(d) The affected 2 plants will submit an annual compliance certification each year.

(e) Assumes that 2 facilities per year would have to submit an exceedance report per year.

N/A = Not applicable.

Total hours 18
17

TABLE 6. YEAR 2 ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE

(A) (B) (C) (D) (E) (F) (G) (H)

EPA personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants per 

year

Technical 

person-hours 

per year

Management 

person-hours 

per year

Clerical 

person-hours 

per year Cost,$ (a)

Activity (C=AxB) (CxD) (Ex0.05) (Ex0.1)

Report Review

 Initial Notification (b) 1.0 1.0 1.0 0.7 0.7 0.0 0.1 $35

 Notification of Compliance Status (c) 10.0 1.0 10.0 0.7 6.7 0.3 0.7 $352

 Annual Compliance Certification (d) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $211

 Report of Exceedence (e) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $211

 Review compliance monitoring plans prepared by plants 10.0 4.0 40.0 2.0 80.0 4.0 8.0 $4,229

TOTAL BURDEN AND COST (SALARY) 95.3 4.8 9.5 $5,040

(a) Costs are based on the following hourly rates: technical at $53.17, management at $62.90, and clerical at $37.87. 

 Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

(b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1.

(c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/yr in Year 1.

(d) The affected 2 plants will submit an annual compliance certification each year.

(e) Assumes that 2 facilities per year would have to submit an exceedance report per year.

N/A = Not applicable.

Total hours 110
18

TABLE 7. YEAR 3 ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE

(A) (B) (C) (D) (E) (F) (G) (H)

EPA personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA personhours per 

plant per year

Plants per 

year

Technical 

person-hours 

per year

Management 

person-hours 

per year

Clerical 

person-hours 

per year Cost,$ (a)

Activity (C=AxB) (CxD) (Ex0.05) (Ex0.1)

Report Review

 Initial Notification (b) 1.0 1.0 1.0 0.7 0.7 0.0 0.1 $35

 Notification of Compliance Status (c) 10.0 1.0 10.0 0.7 6.7 0.3 0.7 $352

 Annual Compliance Certification (d) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $211

 Report of Exceedence (e) 2.0 1.0 2.0 2.0 4.0 0.2 0.4 $211

 Review compliance monitoring plans prepared by plants 10.0 0.0 0.0 2.0 0.0 0.0 0.0 $0

TOTAL BURDEN AND COST (SALARY) 15.3 0.8 1.5 $811

(a) Costs are based on the following hourly rates: technical at $53.17, management at $62.90, and clerical at $37.87. 

 Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.

(b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1.

(c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/yr in Year 1.

(d) The affected 2 plants will submit an annual compliance certification each year.

(e) Assumes that 2 facilities per year would have to submit an exceedance report per year.

N/A = Not applicable.

Total hours 18
19

Year Technical Hours Clerical Hours

Management 

Hours

Total Labor 

Hours Labor Cost

1 15 2 1 18 $811

2 95 10 5 110 $5,040

3 15 2 1 18 $811

Total 126 13 6 145 $6,661

Average 42 4 2 48 $2,220

TABLE 8. SUMMARY OF ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR 

FERROALLYS PRODUCTION: FERROMANGANES AND SILICOMANGANESE
20

Attachment 2. Information Requirements – Amendments to the Ferroalloys Production NESHAP

Requirement Citation for Existing Sources Citation for New Sources General Provisions Citation

Emission standards §§63.1623, 63.1652 §§63.1623, 63.1652

Operational and work practice 

standards

§§63.1624, 63.1654 §§63.162463.1654

Performance tests §§63.1625, 63.1656 §§63.1625, 63.1656 §63.7

Monitoring §§63.1626, 63.1657 §§63.1626, 63.1657 §63.8

Notification §§63.1627, 63.1658 §§63.1627, 63.1658 §63.9

Recordkeeping and reporting §§63.1628, 63.1659, 63.1660 §§63.1628, 63.1659, 63.1660 §63.10