1 **SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX)**  **(Renewal)**
**1. Identification of the Information Collection 1(a) Title**  **of the Information Collection** NESHAP for Ferroalloy s Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal), EPA I CR Number 1831. 05 , OMB Control Number 2060

- 0391

. **1(b) Short Characterization/Abstract** The National Emiss ion Standards for Hazardous Air Pollutants (NESHAP) for the regulations published at regulatory citation were proposed on August 4, 1998, promulgated on May 20, 1999, and amended most recentl y on March 22, 2001. The promulgated rule applies to new and exi sting ferroalloy 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 ferroallo y production plants are subject to this NESHAP rule: submerged arc furnaces; the metal ox ygen refining process; crushing and screening operations; and fugitive dust sources. New sources include those that commenced construction or reconstruction aft er the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart XXX. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the aff ected facilities. They

are also required to maintain records of the occurrence and duration of an y startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem 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 of these measurements, and retain the file for at least five 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 th e United States Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of one respondent 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 is 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). The facility currently subject to this rule has the ability t o comply with the reporting requirements electronically

.2

The OMB approved the currentl y active Information Collection Request (ICR) without any “ Terms of Clearance. ” There are approximately

16 facilities listed in the EPA database s ys tems that are potentially

subject to this regulation. However, we have determined that there is onl y one ferroalloy production plant in the United States that is a major source facility , which subject to the rule and is, therefore, a respondent to this I CR. This facility is publicly

owned and operated by Eramet Corporation. There is no other facilit y that is respondent to this ICR that could be owned b y either state, local and tribal age ncies, or the Federal government. The estimates and assumptions are based on recent information gathered from industry ; the EPA Air Facility Sy stem (AFS) database through the Online Tracking Information Sy stem (OTI S); review of information available on th e active ICR; and consultation with the Ohio Environmental Protection Agency

. There is currentl y a new proposed NESHAP for ferroallo ys , which may affect the universe of respondents in the next few years. It is estimated that one additional facility and possibly nine other non

- manganese producing facilities would be subject to the p roposed rule.
The burden to the affected public is calculated in Table 1: Annual Respondent Burden and Cost, for Ferroallo ys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX )

. The t otal industry burden is estimated to be 584 hours and $55,956

. T he burden to the “Federal Government” is attributed entirel y to work performed b y Federal employees or government contractor. This burden is calculated in Ta ble 2: Annual Burden and Cost to the Federal Government: for Ferroallo ys Prod uction: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX )

. The average annual Agency burden is estimated to be 41 hours and $1,866.
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under se ction 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 po llutants 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 su ch 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 suc h manner as the3 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 Sectio n 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, particulate matter and metallic HAP emissions from ferroalloy production facilities cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category

at 40 CFR part 63, subpart XXX. **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 accord ance 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 t o compl y 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 operatin g 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 bec omes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y 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/maint enance 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 XXX. **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 directl y to the delegated4

state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y 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 Not ice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 76 FR 26 900 ) on May 9 , 2011 . No comments were received on the burden published in the Federal Regist er
. **3(c) Consultations**
T he 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 b y indus try , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) 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. Approximately

one respondent will be subject to the standard over the three

- ye ar period covered by this IC R. Industry representatives 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 I CR, we contacted the following persons:

**Name Organization**  **Phone** Jeffrey McKinney Eramet Marietta, Inc. 740

- 374

- 1143 Paul Pigott Felman Production 304

- 675

- 0079 Christina Wieg Ohio Environmental Protection Agency 740

- 380

- 6490
The consultation with Eramet confirmed that the Marietta facility is still the only

facility affected b y this I CR. Because no additional facility has become subject since the previous I CR renewal (i.e. in the last three ye ars), zero growth is assumed over the three year duration of this ICR

. No additional comments were received on this I CR. **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 frequentl y, the proper op eration and maintenance of control equipment and the possibility

of detecting violations would be less likely

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**3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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

- ye ar records retention requirement is consistent with the part 70 permit program and the five

- ye ar statute of limitations upo n which the permit program is based.
The retention of records for five ye ars allows EPA to establish the compliance history of a source, an y 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 ye ars. In addition, EPA would be prevented from pursuing the violato rs due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are the owners or operators of all new and existing ferroallo ys production facilities that are major sources or are co - located at major sources. The affected facilities produce either ferromanganese or silicomanganese. The United States Standard Industrial Classification (SIC) code for the respondents affected b y the standards is 3313, "Electrometallurgical Products, Except Steel" which corresponds to The North American Industry Classificatio n Sy stem (NAICS) code 331112, “ Electrometallurgical Ferroallo y Product Manufacturing ”

. **4(b) Information Requested**6 **( i) Data Items**  In this ICR, all the data that is recorded or reported is required b y the NESHAP for Ferroallo ys Production: Ferromangan ese and Silicomanganese (40 CFR P art 63, S ubpart XXX) (Renewal). A source must submit the following reports: **Notification Reports** Notification of applicability if an area source becomes subject to the rule 63.9 (b)(1)(ii); 63.1658(a)
Notification/application for approval of construction/reconstruction 63.5(a, b, d and e); 63.9(b)(1)(iii); 63.1658(a) Request for an extension of compliance status 63(d); 63.1658(b) Notification that source is subject to special compliance requirements 63.10(d); 63.1658(c) Notification of performance test 63.9(e); 63.1658(d) Notification of opacit y and visible emission observations 63.1658(e) Reschedule of initial performance test 63.7(b)(2) Notification of compliance status 63.9(h); 63.1658(f) **Reports** Results of performance tests 63.10(d)(2); 63.1659(a)(2) Results of opacity

or visible emission observations 63.10(d)(3) Progress reports if source has received an extension for compliance 63.10(d)(4) Immediate and periodic startup, shutdown, ma lfunction reports 63.10(d)(5)(i

- ii); 63.1659(a)(4) Continuous monitoring sy stems (CMS) performance evaluations reports 63.10(e)(2) Quarterl y excess emissions reports and CMS performance report, unless a semiannual frequency

has been approved 63.10(e)(3)( i); 63.1659(b)(6) Request to reduce frequency of reporting to semiannual 63.10(e)(3)(ii) Waiver of recordkeeping and reporting 63.10(f) A source must keep the following records:7 **Recordkeeping** Maintain records of all information necessary to demonstrate compliance with standard including the occurrence and duration of startup, shutdown, or malfunction of operations 63.10(a

- c); 63.1660(a)(2) Specific requirements include maintaining records of process or control device (e.g., capture s ys tem an d venturi scrubbers) parameters; bag leak detention sy stems; certification that monitoring devices are accurate; and records of the implementation and corrective actions associated with the startup, and shutdown and malfunction plan 63.1660(b)

Maintain re cords for a total of five ye ars with the most recent two ye ars being kept on site 63.10(b)(2); 63.1660(a)(2) Electronic Reporting Currently , one respondent is using monitoring equipment that automatically records parameter data, e.g., pressure drop across the venturi scrubber, monitoring parameter data for the capture s ys tems, and bag leak detection sy stems alarms. Although personne l at the affected facility must evaluate the data, this internal automation has significantly reduced the burden associated with monitoring and recordkeeping at the plant site. In addition, the respondent is able to meet the reporting requirements of the rule by transmitting data including reports electronically

to the regulatory

agencies. **(ii) Respondent Activities** 

**Respondent Activities** Read instructions. Monitor shop opacity

through one of the monitoring options including: 1) monitor control sy stem fan motor amperes and capture s ys tem damper positions once per shift; 2) install, calibrate, maintain, and operate CMS for volumetric flow rate through each separately ducted hood; and 3) install, calibrate, maintain, and operate for volumetric flow rate at the inlet of the air pollution control device and capture s ys tem damper positions once per shift. Monitor baghouse operations on a regular basis, for example, observe on a daily basis for the presence of visible emissions at baghouses, bag leak d etection s ys tem, and conduct periodic visual inspections to ensure it is working properl y. Monitor pressure drop and liquid supply pressure across the venturi scrubber. Perform initial performance test, Reference Method 9 of 40 CFR part 60 for opacity o bservations, Reference Method 5 to determine particulate matter concentration and volumetric flow rate for baghouses without stack, and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above.8 **Respondent Activities** Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems fo r the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y previously applicable instructions and requirements. 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) Agenc y Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S) **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 properl y installed and operated. Performance test reports are used b y the Age ncy to discern a source ’ s initial capability to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The quarterl y excess emissions reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the OTI S which is operated and maintained by

the EPA Office of Compliance. OTI S is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and9

enforcement b y local and state regulatory agencie s, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibilit y**  The NESHAP for ferroalloy s production facilities is applicable to only major sources. There are no small businesses affected b y this regulation at this time. In addition, during the rule development process, the EPA closely reviewed the existing permi t conditions at each of the two existing facilities, where feasible, incorporated similar, if not identical, requirements in the final rule. One of the existing facilities at the time of rule development is no longer subject to the rule during the period of this ICR. 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 Table 1: Annual Respondent Burden and Cost: NESHAP for Ferroalloy s Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Re duction Act. Where appropriate, the specific tasks and major assumptions have been identified in the burden calculations. Responses to this information collection are mandatory

. The Agency

may n either conduct n or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is es timated to be 584 hours

. The recordkeeping hours shown in Table 1 are 502 hours (rounded). The reporting requirement hours shown in Table 1 are 82 hours (rounded). 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**10 **(i) Es timating Labor Costs** 
This I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2: Civilian workers, by occupational and industry group
. ” The rates are from C olumn 1, “ Total compensation. ” The rates have been increased b y 11 0 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital and startup costs for this ICR since we have assumed that the only source subject to this regulation has already purchased the necessary

equipment to comply

with this rule. In additi on, we have assumed that there are no operational and maintenance (O&M) costs for use of continuous monitoring sy stems since the monitors required b y the rule are typically used b y the source as part its normal operations to ensure that the control devices are functioning properly . We have assumed that other costs associated with photocopying and postage are negligible.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only t ype of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/ startup costs or operation and maintenance costs. Therefore, there are no average annual costs for capital/startup and operation and maintenance to the regulated industry over the next three years of the ICR is zero. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. The overall compliance and enforcement program of EPA includes activities suc h as the examination of records maintained b y 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 $1, 866 . This cost is based on the average hourl y l abor rate as follows:

Managerial $ 62.27 ( GS

- 13, Step 5, $ 38.92 x 1.6)11 Technical $ 46.21 ( GS

- 12, Step 1, $ 28.88 x 1.6) Clerical $ 25.01 (GS

- 6, Step 3, $ 15.63 x 1.6) These rates are from the Office of Personnel Management (OPM) “ 2011 General Schedule ” which excludes locality

rates of pay . Details upon which this estimate is based appear in Table 2: Annual Burden and Cost for The Federal Government: NESHAP for Ferroall oys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal) , attached. **6(d) Estimating the Respondent Universe and Total Burden and Costs**
Based on our research for this I CR, only one existing ferroalloy

production facility is currentl y subject to the standard, and no new or existing facility is expected to become subject to this regulation in the next three ye ars. **Number of Respondents**

**Respondents That Submit Reports**  **Respondents That Do Not Submit Any**  **Reports**

Year (A) Number of Ne w Respondents * (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 1 0 0 1 2 0 1 0 0 1 3 0 1 0 0 1 Average 0 1 0 0 1 * New respondents include sources with constructed, reconstructed and modified affected facilities To avoid double

- counting respondents column D is subtracted. As shown above, there is an average of one respondent over the three

- ye ar period of this I CR.
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 Notifications * 0 5 N/A 0 Notification of Performance Test 0 1 N/A 0
Notification of Com pliance Status 1 1 N/A 112 **Total Annual Responses** Quarterly Reports 1 4 N/A 4 Semiannual Reports 1 2 N/A 2 Total 7 * Initial Notifications include: applicability; initial performance test, extension of compliance; the source is subject to special compliance requirements; and opacity and visible emission observations. The number of Total Annual Responses is seven. The total annual labor costs are $ 55,956 . Details regarding these estimates may be found in Table 1 : Annual Respondent Burden and Cost: NESHAP for Ferroalloy s Production: Ferromanganese and Silicomangan ese (40 CFR Part 63, Subpart XXX) (Renewal) , attached. There are no annual capital/startup and O&M costs to the regulated entity. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup versus Operation and Maintenance (O&M) Costs.
The average annual Agency burden and cost over next three years are estimated to be 4 1 labor hours at a cost of $1, 866 . See Table 2. Annual Agency Burden and Cost: NESHAP for Ferroallo ys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal) , attached. **6(e) Bottom Line Burden Hours 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, respectivel y, and summarized below. **(i) Respondent Tally** 
The total annual labor hours are 584. Details regarding these estimates may be found in Table 1 : Annual Respondent Burden and Cost: NESHAP for Ferroallo ys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renew al) below

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 83 hours per response. There are no annual capital/startup and O&M costs to the regulated entity s ubject to the NESHAP for Ferroalloy s Production. 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 4 1 labor hours at a cost of $1, 866 . See Table 2 : Annual Agency Burden and Cost: NESHAP for Ferroallo ys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal) , attached.13

**6(f) Reasons for Change in Burden** There is no change in the industry labor hours in this I CR compared to the previous I CR. This is due to two considerations. First, the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years. Se condl y, the growth rate for the industry

is very low, negative or non

- existent, so there is no significant change in the overall burden. However, there is an increase in the total labor and Agency costs as currentl y identified in the OMB Inventory

of Approved Burdens. This increase is not due to any program changes. The change in cost estimates reflects updated labors rates available from the Bureau of Labor Statistics.
There is a decrease in th e total number of Agency hours, from 91 to 41 hours, due to a transcription error. Additionally , a mathematical error was corrected for the Management person

hours per ye ar and Clerical person

- hours per year for one of the implementation activities. **6(g) Burden Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 83 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintai n, 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; s earch 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 v alid 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 fo r minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0231

. An electronic version of the public docket is available at http://www.regu lations.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 electronic ally . When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC) , EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public14

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. 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 In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EP A. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2011

- 0231 and OMB Control Number 2060

- 0391 in any correspondence. **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 Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part**  **63, Subpart XXX)**

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrence**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Cost,$ b** 

1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Sy stems N/A 4. Reporting Requirements c A. Read instructions Included in 5C B. Required activities Included in 5C C. Create Information Included in 5C D. Gather Existing Information Included in 5C E. Write report c, d i. Initial notifications N/A ii. Notification of reconstruction/modification N/A iii. Notification of annual performance test 2 1 2 1 2.0 0.1 0.20 $220.39 iv. Notification of opacity and visible observations 2 1 2 1 2.0 0.1 0.20 $220.39 v. Report of performance test results/opacity observations 5 1 5 1 5.00 0.25 0.50 $550.97 vi. Periodic startup, shutdown and malfunction reports 10 2 20 1 20.00 1.00 2.00 $2,203.87 vii. Capture hood inspection report 4 2 8 1 8.00 0.40 0.80 $881.5516 **Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrence**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Cost,$ b** 

viii. Summary report of maintenance records 4 2 8 1 8.00 0.40 0.80 $881.55 ix. Fugitive dust operations report 4 2 8 1 8.00 0.40 0.80 $881.55 x. Quarterly excess emissions reports 4 4 16 1 16.00 0.80 1.60 $1,763.09 xi. Annual compliance status certification 2 1 2 1 2.00 0.10 0.20 $220.39 Reporting Subtotal 82 $7,823.72 5. Recordkeeping Requirements A. Read instructions Included in 5C B. Plan activities 10 1 10 1 10.00 0.50 1.00 $1,101.93 C. Implement activities: e, f i. Control devices:

- Annual Performance tests for the control devices associated with submerged arc furnaces 50 1 50 1 50.00 2.50 5.00 $5,509.67

- Baghouse monitoring includes: Daily 0.5 350 175 1 175.00 8.75 17.5 $19,283.83 Weekly 0.1 50 5 1 5.00 0.25 0.50 $550.97 Monthly 0.1 12 1.2 1 1.20 0.06 0.12 $132.23 Quarterly 0.1 4 0.4 1 0.40 0.02 0.04 $44.08 Semiannually 0.1 2 0.2 1 0.20 0.01 0.02 $22.04

- Parameter monitoring: fan mo tor amperes, damper positions and pressure drop 0.1 1050 105 1 105.00 5.25 10.50 $11,570.30 ii. Monthly capture system inspection 2 12 24 1 24.00 1.20 2.40 $2,644.6417 **Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrence**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Cost,$ b** 

iii. Opacity violation/scrubber 2 1 2 1 2.00 0. 1 0. 2 $220.39 iv. Opacity violation/baghouse 2 20 40 1 40.00 2.00 4.00 $4,407.73 v. Monitoring violation

- capture system 2 12 24 1 24.00 1.20 2.40 $2,644.64 D. Develop record system c, g N/A E. Time to enter and transmit information Included in 5C F. Time to train personnel N/A G. Time to adjust existing ways to comply with previously applicable requirements N/A
H. Time to disclose information N/A I. Time for audits N/A Recordkeeping subtotal 502 $48,132.43 TO TAL LABOR BURDEN AND COST (Rounded) 584 $55,956

**Assu mptions:**  a There is only one ferroalloy production facility currently subject to the standard. We have assumed that no additional respondents will become subject to this regulation since no industry grow th is expected in the next three years. b This ICR uses the followi ng labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, Septem ber 20 11 , A Ta

ble 2

. Civilian W orkers , by O ccupational and I ndustry Group. @ The rates are from column 1, A Total compensation. @ These rates have been increased by 110 percent to account for the benefit packages available to those employed by privat e industry. c We have assumed that the source has complied with the initial notification requirements and the initial compliance demonstration requirements since the effective date of the rule has passed. In addition, we have assumed that the source has already developed its record system including the startup, shutdown and malfunction plan; the fugitive dust plan; and the control equipment/maintenance plan. d Periodic reports include: quarterly emissions reports and semiannual reports that address the r equirements for opacity

- related reports; performance test results reports; startup, shutdown and malfunction reports; capture hood inspection reports; and fugitive dust operations reports.18

e The types of monitoring activities required by this NESHAP regu lation include: 1) monitoring of baghouse systems on a daily (visible observations and pressure drop across the baghouse), weekly (inspection of dust hoppers), monthly (inspection of bags cleaning mechanism), quarterly (inspection of baghouse integrity and bags tension) and semiannual (inspection of fans for wear) basis; 2) the implementation of a bag leak detection systems; 3) average hourly scrubber pressure drop (automatic device is used) monitoring for venturi scrubbers; and 4) either monitoring of control system fan motor ampares and capture system damper positions once per shift, or monitoring of volumetric flow rate through each separately ducted hood, or at the inlet of the air pollution co ntrol device using a continuous monitoring system and of the capture system damper positions once per shift, if the source is subject to the shop opacity standard. f Sources are required to conduct the annual performance test for the air pollution control devices and vent stacks to determin e particulate matter conc entration and volumetric flow

rate to demonstrate compliance with the emission standard. Reference Method 5 is used to determine particulate matter concentration and volumetric flow rate for baghouses without stack. Sources are also required to conduct i nitial opacity observations of the shop building using Reference Method 9 to demonstrate compliance with the opacity standards. g Sources are required to maintain records of: 1) process or control device parameters; 2) bag leak detention systems; 3) maint enance plan for air pollution control devices (e.g., capture system and venturi scrubbers); 4) certification that monitoring device s are accurate; and 5) the implementation and corrective actions taken related to the startup, shutdown and malfunction plan and the fugitive dust control plan.19

**Table 2.**  **A nnual**  **Burden and**  **Cost for**  **the Federal**  **Go vernment:**  **NESHAP for**  **Ferroalloys Production:**  **Ferromanganese and**  **Silicomanganese (40 CFR Part 63, Subpart XXX)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ a** 

A. Review reports: c & d i. Initial Notifications N/A ii. Notification of reconstruction/modification N/A iii. Notification of Performance Test 1 1 1 1 1.00 .050 0.10 $ 51.82 iv. Report of performance test results/opacity observations 5 1 5 1 5.00 0.25 0.50 $ 259.11 v. Semiannual summary reports 10 2 20 1 20.00 1.00 2.00 $ 1,036.45 vi. Quarterly excess emissions reports 2 4 8 1 8.00 0.40 0.80 $ 414.58 xi. Annual compliance status certification 2 1 2 1 2.00 0.10 0.20 $ 103.64 Total Annual Cost 41 $1, 865.61 TO TAL ANNUAL COST (rounded) $1, 866

**Assu mptions:**  a There is only one ferroalloy production facility currently subject to NESHAP, subpart XXX. We have assumed that no additional resp ondents will become subject to this regulation. b Costs are based on the following hourly rates: Managerial at $ 62.27 (GS

- 13, S tep 5, $ 38.92 x 1.6); Technical at $ 46.21 (GS

- 12, Step 1, $ 28.88 x 1.6); Clerical at $2 5.01 (GS

- 6, Step 3, $ 15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) A 2011 General Schedule @ which excludes locality rates of pay.20

c We h ave assumed that the source has comply with the initial notification requirements and the initial compliance demonstration re quirements since the effective date of the rule has passed. In addition, we have assumed that the source has already developed its record system including the startup, shutdown and malfunction plan; the fugitive dust plan; and the control equipment/maintenance plan. d Periodic reports include: quarterly emissions reports and semiannual reports that address the requirements for opaci ty

- related reports; performance test results reports; startup/shutdown/malfunction reports; capture hood inspection reports; and fugitive dust operations reports. N/A = Not applicable.