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

Subpart XXX) (Renewal), EPA ICR Number 1831.05, OMB Control Number 2060-0391. 

1(b) Short Characterization/Abstract

The National Emission 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 recently on March 22, 2001. The promulgated rule applies to 

new and existing 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 ferroalloy 

production plants are subject to this NESHAP rule: submerged arc furnaces; the metal oxygen 

refining process; crushing and screening operations; and fugitive dust sources. New sources 

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

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

In general, all NESHAP 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 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 the United 

States Environmental Protection Agency (EPA) regional office.

Over the next three years, 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 to comply with the reporting requirements 

electronically.
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The OMB approved the currently active Information Collection Request (ICR) without 

any “Terms of Clearance.”

There are approximately 16 facilities listed in the EPA database systems that are 

potentially subject to this regulation. However, we have determined that there is only 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 ICR. This facility is publicly owned and operated 

by Eramet Corporation. There is no other facility that is respondent to this ICR that could be 

owned by either state, local and tribal agencies, or the Federal government. The estimates and 

assumptions are based on recent information gathered from industry; the EPA Air Facility

System (AFS) database through the Online Tracking Information System (OTIS); review of 

information available on the active ICR; and consultation with the Ohio Environmental 

Protection Agency. 

There is currently a new proposed NESHAP for ferroalloys, 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 proposed rule. 

The burden to the affected public is calculated in Table 1: Annual Respondent Burden 

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

Subpart XXX ). The total industry burden is estimated to be 584 hours and $55,956. The burden 

to the “Federal Government” is attributed entirely to work performed by Federal employees or 

government contractor. This burden is calculated in Table 2: Annual Burden and Cost to the 

Federal Government: for Ferroalloys Production: 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 section 112 of the Clean Air Act, as amended, to establish 

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

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

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

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

of this Act to: 

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

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

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

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

such intervals, during such periods, and in such manner as the 
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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 and metallic HAP emissions from 

ferroalloy production facilities cause or contribute to air pollution that may reasonably 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 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.

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 directly to the delegated 
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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 (76 FR 26900) on May 9, 2011. 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. Approximately one 

respondent will be subject to the standard over the three-year period covered by this ICR.

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 ICR, 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 by this ICR. Because no additional facility has become subject since the previous ICR 

renewal (i.e. in the last three years), zero growth is assumed over the three year duration of this 

ICR. No additional comments were received on this ICR.

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.
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3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5.

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

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

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

the part 70 permit program and the five-year statute of limitations upon which the permit 

program is based. 

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

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

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

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

nonexistence of essential records.

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 ferroalloys 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 by the standards is 3313, "Electrometallurgical Products, Except Steel" 

which corresponds to The North American Industry Classification System (NAICS) code 

331112, “Electrometallurgical Ferroalloy Product Manufacturing”.

4(b) Information Requested
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(i) Data Items

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

Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart 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 opacity 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, malfunction reports 63.10(d)(5)(i-ii); 

63.1659(a)(4)

Continuous monitoring systems (CMS) performance evaluations reports 63.10(e)(2)

Quarterly 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:
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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 system and venturi scrubbers) parameters; 

bag leak detention systems; 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 records for a total of five years with the most recent two 

years 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 systems, and bag leak detection systems alarms. Although personnel 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 

system fan motor amperes and capture system 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 system 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 detection system, and conduct periodic 

visual inspections to ensure it is working properly.

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 

observations, 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.
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Respondent Activities

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.

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.

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

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, analyze, and maintain data in the Online Tracking Information System (OTIS)

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 OTIS which is operated and 

maintained by the EPA Office of Compliance. OTIS 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 OTIS for tracking air pollution compliance and 
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enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

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

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

years.

5(c) Small Entity Flexibility

The NESHAP for ferroalloys production facilities is applicable to only major sources. 

There are no small businesses affected by this regulation at this time. In addition, during the rule 

development process, the EPA closely reviewed the existing permit 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 Ferroalloys 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 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, the specific tasks 

and major assumptions have been identified in the burden calculations. Responses to this 

information collection are mandatory.

The Agency may neither conduct nor sponsor, and a person is not required to respond to, 

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated 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
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(i) Estimating Labor Costs

This ICR 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 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 only costs to the regulated industry resulting from information collection activities

required by 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 addition, we have assumed that there are no 

operational and maintenance (O&M) costs for use of continuous monitoring systems since the 

monitors required by the rule are typically used by 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 type 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 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 three years of the ICR is estimated to be 

$1,866. This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 x 1.6)
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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 Ferroalloys 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 ICR, only one existing ferroalloy production facility is 

currently subject to the standard, and no new or existing facility is expected to become subject to 

this regulation in the next three years.

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

Year

(A)

Number of New 

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-year period of this ICR.

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 

Compliance Status

1 1 N/A 1
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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 Ferroalloys Production: 

Ferromanganese and Silicomanganese (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 41

labor hours at a cost of $1,866. See Table 2. Annual Agency Burden and Cost: NESHAP for 

Ferroalloys 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, respectively, 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 Ferroalloys Production: 

Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal) 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 subject to the 

NESHAP for Ferroalloys 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 41

labor hours at a cost of $1,866. See Table 2: Annual Agency Burden and Cost: NESHAP for 

Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX)

(Renewal), attached.
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6(f) Reasons for Change in Burden

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

This is due to two considerations. First, the regulations have not changed over the past three 

years and are not anticipated to change over the next three years. Secondly, 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 currently 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 the total number of Agency hours, from 91 to 41 hours, due to a 

transcription error. Additionally, a mathematical error was corrected for the Management personhours per year 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 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, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2011-0231. 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), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 
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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 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.
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Table 1. Annual Respondent Burden and Cost: NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese 

(40 CFR Part 63, Subpart XXX)

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours 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)

Cost,$

 b

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, and 

Utilization of Technology and 

Systems

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 $881.55 
16

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours 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)

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 

motor 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 $2,644.64 
17

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrence 

per 

respondent 

per year

(C)

Personhours 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)

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 

TOTAL LABOR BURDEN 

AND COST (Rounded) 584 $55,956 

Assumptions:

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 growth is expected in the next three years.

b

 This ICR uses the following 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, September 2011, ATable 2. Civilian Workers, by 

Occupational and Industry Group.@ The rates are from column 1, ATotal compensation.@ These 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 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 requirements 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 regulation 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 control 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 determine particulate matter concentration 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 initial 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) maintenance plan for air pollution control 

devices (e.g., capture system and venturi scrubbers); 4) certification that monitoring devices 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. Annual Burden and Cost for the Federal Government: NESHAP for Ferroalloys Production: Ferromanganese and 

Silicomanganese (40 CFR Part 63, Subpart XXX)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant per 

year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants per 

year

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours 

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

TOTAL ANNUAL COST 

(rounded) $1,866

Assumptions:

a

 There is only one ferroalloy production facility currently subject to NESHAP, subpart XXX. We have assumed that no additional respondents will become 

subject to this regulation.

b

 Costs are based on the following hourly rates: Managerial at $62.27 (GS-13, Step 5, $38.92 x 1.6); Technical at $46.21 (GS-12, Step 1, $28.88 x 1.6); Clerical 

at $25.01 (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) A2011 General Schedule@ which excludes locality rates of 

pay. 
20

c We have assumed that the source has comply 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 requirements for opacity-related reports; performance test results 

reports; startup/shutdown/malfunction reports; capture hood inspection reports; and fugitive dust operations reports.

N/A = Not applicable.