SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 

60, Subparts N and Na) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60, 

Subparts N and Na) (Renewal), EPA ICR Number 1069.11, OMB Control Number 2060-0029.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Primary and Secondary Emissions 

from Basic Oxygen Furnaces were proposed on June 11, 1973, promulgated on March 8, 1974, 

and amended on October 17, 2000. These regulations apply to each basic oxygen process 

furnace (BOPF) in an iron and steel plant that commenced construction, modification, or 

reconstruction after the date of proposal. An opacity limit was promulgated on April 13, 1978 as 

a supplement to the mass standard. On January 20, 1983, amendments to the Standards of 

Performance for Primary Emissions from Basic Oxygen Process Furnaces merged with 

Standards of Performance for Secondary Emissions from Basic Oxygen Process Steelmaking 

Facilities (Subpart Na). Subpart Na is applicable to any top-blown BOPF, and hot metal transfer 

station or skimming stations used with bottom-blown or top-blown BOPF's for which 

construction, reconstruction, or modification commenced after January 20, 1983. Subpart Na 

was promulgated on January 2, 1986. This information is being collected to assure compliance 

with 40 CFR Part 60, Subparts N and Na.

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

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

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

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

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

and are required of all affected facilities subject to NSPS. 

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

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

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

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

States Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 18 respondents per year will be subject to the 

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

The Office of Management and Budget (OMB) approved the currently active ICR 
2

without any “Terms of Clearance.” 

The 18 respondents are owned and operated by the iron and steel industry (the “Affected 

Public”). None of the facilities in the United States are owned by either state, local, tribal or the 

Federal government; all are privately-owned, for-profit businesses. 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

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

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years. In addition, section 114(a) states that the Administrator may require any 

owner/operator subject to any requirement of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, particulate matter emissions from BOPFs at iron and 

steel plants cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 

CFR Part 60, Subparts N and Na.

2(b) Practical Utility/Users of the Data
3

The recordkeeping and reporting requirements in the standards 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 the standards at all times. 

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 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. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

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

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

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

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

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.
4

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted the American Iron and Steel Institute (AISI) at (202) 945-4777, and 

North Start BlueScope Steel at (419) 822-2200.

After a thorough review, it is our policy to respond to comments received since the last 

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

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

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

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 (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are BOPFs at iron and 

steel plants. The United States Standard Industrial Classification (SIC) codes for the respondents 

affected by the standards and the corresponding North American Industry Classification System

(NAICS) codes are listed in the table below. 
5

Standard (40 CFR Part 60, Subparts N and Na) SIC Codes NAICS Codes

Iron and Steel Mills 3312, 3399 331111

Steel Wire Drawing 3315 331222

Rolled Steel Shape Manufacturing 3312, 3316, 3399 331221

Iron and Steel Pipe and Tube Manufacturing from 

Purchased Steel 3317 331210

4(b) Information Requested

(i) Data Items

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

and Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na). 

A source must make the following reports:

Notifications

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

Notification of actual startup 60.7(a)(3)

Notification of physical or operational change 60.7(a)(4)

Notification of monitoring system performance commencement 60.7(a)(5) 

Performance test results 60.8(a)

Notification of performance test 60.8(d)

Demonstration of continuous monitoring system 60.7(a)(5)

Semiannual compliance reports of all measurements over any 3-hour 

period that average more than 10 percent below the average level 

maintained during the most recent performance test in which the 

facility demonstrated compliance with the standard

60.7(c), 60.143(c-e)

A source must keep the following records:

Recordkeeping

Maintain records of startup, shutdown, or malfunction period where 

the continuous monitoring system is inoperative

60.7(b)

Emission test results, continuous monitoring system data, performance 

test results and other data needed to determine compliance with mass 

60.7(f), 60.145a
6

Recordkeeping

and visible emission limits

Time and duration of each steel production cycle 60.143(a)

Record the time and duration of the rates or levels of any diversion of 

exhaust gases from the main stack servicing the BOPF

60.143(a)

Record the various rates or levels of exhaust ventilation at each phase 

of the cycle through each duct of the secondary emission capture 

system

60.143a(a)

Record of time and duration of the visible emission data sets 60.145a(d)

Record the particulate matter concentration (i.e., opacity levels) exiting 

the control device and discharge into the atmosphere

60.142(a-b)

Record the pressure loss through the venture constriction of the 

scrubber continuously

60.143(a)(1)

Record the water supply pressure to the venture scrubber control 

equipment continuously

60.143(a)(2)

Records are required to be retained for 2 years 60.7(f)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

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

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

a plant site. 

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

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

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

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

supply pressure for venture scrubber. 

Perform initial performance test, Reference Method 5, 9, and 2 test, and repeat performance 
7

Respondent Activities

tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

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 Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to
8

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 and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

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

determinations.

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

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

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

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

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

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

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

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Primary and 

Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na)

(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 each of the subparts 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.
9

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 6,263 (Total Labor Hours from Table 1). These 

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

regulation, Agency knowledge and experience with the NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

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 standards 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 and other costs such as photocopying and postage.

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Flow meters to 

measure exhaust 

gas flow rate 

$18,000 0 $0 $900 18 $16,200

Flow meters to 

measure pressure 

flow rate

0 0 $0 $900 15 $13,500

Total $0 $29,700

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 $29,700. 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 $29,700. 

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 

$9,421. 

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 – NSPS for Primary and 

Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na)

(Renewal).
11

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

18 existing respondents will be subject to the standard. 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 18 per year. 

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

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 18 0 0 18

2

0 18 0 0 18

3

0 18 0 0 18

Average 0 18 0 0 18

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 18. 

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

Notification of construction or 

modification 0 1 0 0

Notification of performance test 0 1 0 0

Report results of performance test 0 1 0 0
12

Total Annual Responses

Semiannual report 18 2 0 36

Total 36

The number of Total Annual Responses is 36. 

The total annual labor costs are $613,126. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Primary and 

Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na)

(Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The total annual labor hours are 6,263. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost – NSPS for Primary and Secondary Emissions 

from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na) (Renewal). 

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

information is estimated to average 174 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $29,700. 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 207

labor hours at a cost of $9,421. See Table 2: Average Annual EPA Burden and Cost – NSPS for 

Primary and Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N 

and Na) (Renewal).

6(f) Reasons for Change in Burden

There is no change in labor hours in this ICR compared to the previous ICR. The slight 

increase in respondent and Agency burden costs is due to an adjustment in labor rates used in the 

burden calculations. The labor rates have been adjusted to reflect the most recent labor rates 

from the Bureau of Labor Statistics and OPM. 

6(g) Burden Statement
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The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 174 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-2014-0037. 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 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) 566-1927. 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 EPAHQ-OECA-2014-0037 and OMB Control Number 2060-0029 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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Table 1: Annual Respondent Burden and Cost – NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces (40 

CFR Part 60, Subparts N and Na) (Renewal)

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

 A. Read instructions c

1 1 1 0 0 0 0 $0 

 B. Required activities

 Performance tests d

194 1 194 0 0 0 0 $0 

 Repeat of performance test e

194 1 194 0 0 0 0 $0 

 Daily monitoring of emissions 

and operations See 4E

 C. Create information See 3B and 

4E

 D. Gather existing information See 3B and 

4E

 E. Write Report

 Notification of reconstruction or 

modification 2 1 2 0 0 0 0 $0 

 Notification of performance test 2 1 2 0 0 0 0 $0 

 Performance test results 32 1 32 0 0 0 0 $0 

 Semiannual report of excess 

emissions f 10 2 20 18 360 18 36 $40,531.68

Subtotal for Reporting 

Requirements 414 $40,531.68

4. Recordkeeping requirements
15

Burden item

(A) 

Person 

hours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year 

a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

 A. Read instructions See 3A

 B. Plan activities See 3B

 C. Implement Activities See 3B

 D. Develop record system N/A

 E. Time to enter information

 Records of operating parameters 

 Exhaust ventilation rate g

0.25 365 91.25 18 1,642.5 82.13 164.25 $184,925.79

 Across the venture scrubber (i.e., 

pressuredrop and water supply 

pressure) h

0.25 365 91.25 15 1,368.75 68.44 136.88 $154,104.83

 Records of performance test See 3B

 Records of duration of each 

steel production cycle, and time and 

duration of any diversion of exhaust 

gases from the main stack serving the 

BOPF i

0.25 365 91.25 18 1,642.5 82.13 164.25 $184,925.79

 Recalibrate and check 

monitoring devices j 8 1 8 18 144 7.2 14.4 $16,212.67

 F. Time to train personnel 

 Certification of opacity observer k

8 2 16 18 288 14.4 28.8 $32,425.34

 G. Time for audits N/A

Subtotal for Recordkeeping 

Requirements 5,849 $572,594.42

TOTAL LABOR BURDEN AND 

COST (rounded) 6,263 $613,126 

Assumptions:
16

 a We have assumed that there are approximately 18 respondents (i.e., BOPF shops) that are subject to the regulation, with no additional new or reconstructed 

sources becoming subject to the rule over the next three years.

 b

 This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and 

$51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, Table 2. Civilian 

Workers, by Occupational and Industry groups. 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.

c

 We have assumed that it will take one hour for each respondent to read instructions.

d

 We have assumed that it will take 194 hours for each respondent to complete a performance test.

e

 We have assumed that it will take 10 percent of respondents to repeat performance test due to failures.

f

 We have assumed that it will take 10 hours twice per year for each respondent to write the semiannual reports if excess emission. 

g

 We have assumed that it will take each of the eighteen respondent 0.25 hours, 365 times per year, to record the exhaust ventilation rate.

h We have assumed that it will take each of the fifteen respondent 0.25 hours, 365 times per year, will enter information on records of CMS operating parameters 

across the venture scrubber. Fifteen of the existing respondents will use venture scrubbers as primary emission control systems.

i 

 We have assumed that it will take each respondent 0.25 hours, 365 days per year, to record the duration of each steel production cycle. 

j 

 We have assumed that it will take each respondent eight hours once per year to recalibrate and check monitoring devices.

k

 We have assumed that it will take each respondent eight hours twice per year to train personnel on certification of opacity observer.
17

Table 2: Average Annual EPA Burden and Cost – NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces 

(40 CFR Part 60, Subparts N and Na) (Renewal)

Activity

(A) 

EPA personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant per 

year

(C) 

EPA person 

hours per 

plant per 

year (AxB)

(D) 

Plants 

per 

year a 

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per year 

(Ex0.1)

(H) 

Cost, $ b

New facility

 Notification of performance test c

2 1 2 0 0 0 0 $0 

 Report of performance test results d

8 1 8 0 0 0 0 $0 

 Notification of reconstruction/modification e

2 1 2 0 0 0 0 $0 

Review reports: Existing and new sources 

 Semiannual reports of excess emissions and 

monitoring systems performance f 5 2 10 18 180 9 18 $9,421.20 

 

TOTAL ANNUAL BURDEN AND COST 

(rounded) 207 $9,421 

Assumptions:

 a

 We have assumed that there are approximately 18 respondents (i.e., BOPF shops) that are subject to the regulation, with no additional new or reconstructed 

sources becoming subject to the rule over the next three years.

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial, 

$46.67 for Technical, and $25.25 for Clerical. These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality 

rates of pay.

c

 We have assumed that it will take two hours once per year for each respondent to perform the performance test.

d

 We have assumed that it will take eight hours once per year for each respondent to report the performance test results.

e

 We have assumed that it will take two hours once per year for each respondent to comply with the notification requirements of the rule.

f

 We have assumed that it will take five hours twice per year for each respondent to submit semiannual reports of excess emissions and monitoring systems with all 

measurements over any three hour period (e.g., of low pressure) that average more than 10 percent below the averages during the most recent performance test.