**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Iron and Steel Foundries**  **(40 CFR Part 63, Subpart EEEEE**  **) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal), EPA I CR Number 2096.05 , OMB Control Number 2060

- 0543 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Iro n and Steel Foundries (40 CFR part 63, subpart EEEEE) were proposed on December 12, 2002, (67 FR 78274), and promulgated on April 22, 2004, (69 FR 21905). The final rule was amended on both May

20, 2005 (70 FR 29400) , and on February 7, 2008 (73 FR 7210). These regulations apply to existing and new iron and steel foundry facilities that are major sources of hazardous air pollutant (HAP) emissions. The rule applies to emissions from metal melting furnaces, scrap pre - heaters, pouring areas, pouring s tations, automated conveyor and pallet cooling lines, automated shakeout lines, and mold and core making lines; and to fugitive emissions from foundry operations. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart EEEEE

. In general , all NESHAP standards r equire initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facili ties. 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, repor ts, 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 lea st 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). EPA estimated that 98 of the 650 existing foundries are major sources that will be subject to the rule requirements. Over the next three ye ars, an average of 98 respondents per ye ar will be subject to the se standard s , and no additiona l respondents per ye ar will become subject to the se same standard s
.2

The active (previous) IC R had the following “ Terms of Clearance ” (TOC):
When this I CR is renewed, EPA should review the respondent burden, universe, labor rates, and capital costs and ensure these estimates have been updated.
EPA has addressed each item of concern in the TOC by consulting with industry

. EPA has updated all labor costs using the latest labor rates and reviewed all calculations. All of the iron and steel foundries in the United States are owned and operated by the iron and steel industry

(the “Affected Public”). None of the facilities in the United States are owned by state , local, tribal or the Federal government. These are all privatel y - owned , for

- prof it businesses. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)

. T he “ burden ” to the Federal Government is attributed enti rely to work performed b y either F ederal employ ees or government contractor s and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal).
**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 pollut ants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emiss ion reduction. Inaddition, 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 procedur es 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 emis sions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y require. In the Administrator's judgm ent, particulate matter (PM), metal, and organic HAP emissions from iron and steel foundries either cause or contribute to air pollution that may3

reasonabl y be anticipated to endanger public health and/ or welfare. Therefore, the NESHAP were promulgated for thi s source category at 40 CFR part 63, subpart EEEEE

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard 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 are required in order to determine an affected facility ’ s initial capability to comp ly

with the emission standar d . Continuous emission monitors are used to ensure compliance with the standard 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 notificat ions required in the standard 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 properl y installed and operated , leaks are being detected and repaired , and the standard is being met. The performance test may also be observed. The required semiannual reports are used to determine periods o f excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. The information generated by the monitoring, recordkeeping and reporting requirements described in this I CR is used by the Agency

to ensure that facilities affected by the NESHAP continues to operate the control equipment in compliance with the regulation. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping an d reporting are required under 40 CFR part 63, subpart EEEEE

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y t o the delegated 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, duplication does not exist.4

**3(b) Public Notice 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 Regis ter ( 77 FR 63813 ) on October 17, 2012

. No comments were received on the burden published in the Federal Register

. **3(c) Consultations**

. The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three y ears. 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 Sy stem (OTIS ) which is operated and mai ntained b y EPA's Office of Compliance. OTI S is EPA ’ s 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. Industry tr ade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard s as they w ere being developed and the standard has been reviewed previousl y to determine the minimum information needed for compliance purposes. Indeveloping this ICR, we contacted : 1) the Alliance of Automobile Manufacturers , at (202) 326

- 5549 ; and 2) the American Foundry Societ y , at (800) 437

- 4237. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection**  Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet 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 operation and maintenance of control equipment and the possibility

of detecting violations would b e less likely

. **3(e) General Guidelines**
T hese 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 Part 70 permit program and the five

- ye ar s tatute of limitations on which the permit program is based. T h e retention of records for five ye ars allow s EPA to establish the compliance history of5

a source , an y pattern of non - compliance and to determine the appropriate level of enforcement action. EP A has found that the most flagrant violators have violations extending beyond five ye ars. 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**
T he 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 iron and steel foundries . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards , and the corresponding North American Industry Classification Sy stem (NAICS ) codes X for this source category is listed below.

**Standard (40 CFR**  **P art 6**  **3 ,**  **S ubpart**  **EEEEE )**  **SIC Codes NAICS Codes**  Iron Foundries 3321, 3322 331511 Steel Investment Foundries 3324 331512 Steel Foundries (except Investment) 3325 331513 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE)

. A source must make the following reports:6

**Notification s**  Notification of construction/reconstruction 63.5 Initial notifications 63.9(b), 63.7750 Initial performance test 63.7(b), 63.9(e) Rescheduled initial performance test 63.7(b)(2) Approval of smelters fugitive dust control standard operating procedures manual, and operating procedures manual for baghouses 63.549(b) Demonstration of continuous monitoring sy stem 63.9(g) Compliance status 63.9(h) , 63.7750(e) Phy sical or operational change 63.9, 63.10
**Reports** Initial performance test results 63.10(d)(2) Periodic startup, shutdown, malfunction reports 63.10(d)(5)(i) , 63.7751(c) Semiannual compliance reports (monitoring/ exceedance summary) 63.10(e)(3), 63.7751 A source must keep the following records:
**Recordkeeping** Startups, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 63.6(e)(3), 63.7752(a)(2) Records of performance test 63.7752(a)(3) All reports and notifications 63.10(b), 63.7752(a)(1) Record of applicability 63.10(b)(3) Records for sources with continuous monitoring systems 63.10(3), 63.7752(b) Records to show compliance with emission limitation, work practices standard, and operation and maintenance requirements of parametric monitoring data, s ys tem maintenance and calibration 63.7752(c) Records are required to be retained for five years, however, onl y the data of the most recent two y ears must be kept on

- site 63.7753(c)
Electronic Reporting Some of the r espondents are using monitoring equipment that automatically records7

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 r espondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, operate and maintain baghouses, according to standard operating procedures manual and consistent with the manufacturer’s instructions. Perform initial performance test and repeat performance tests if necessary

. Monitor and record pressure drop and liquid supply pressure at the wet scrubber at least once every hour when using this control device for controlling particulate matter and metal HAP emissions from a process fugitive source. Install, calibrate, maintain, and operate a CMS for temperature monitoring of the afterburner or the combined blast furnace and reverberatory furnace exhaust streams when compl yi ng with the total hydrocarbon emission standard. Install, calibrate, maintain, and operate a total h ydrocarbon CMS f or measuring emissions when compl yi ng with the total hydrocarbon emission standard. Equip pressurized drying bleaching seals with an alarm to determine seal malfunctions Use referenced Methods in Appendix A, part 60, to determine compliance with the emis sion standards (i.e., Methods 1, 2, 3, 4 for stack PM testing; Method 18 for volatile organic HAP testing; Method 18 or Method 25 for total hydrocarbons testing) 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and8 **Respondent Activities** 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. Currently , sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem ) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y 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, analy sis, storage, and distribution of the required information.
**Agenc y 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 OTIS. **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y 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 det erminations.9

In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 indu strial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **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 ty pes of control equipment employ ed, the recordkeeping and reporting re quirements 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 e conomies 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

– NE SHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (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 Reduction Act. Where ver appropriate, specific tasks and major assumpt ions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6( a) Estimating Respondent Burden**  The average annual burden to industry over the next three y ears from these recordkeeping and reporting requirement s is estimated to be 29,747 hours ( Total Labor Hours from Table 1 below ). T hese particular 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 an y comments received.10

**6(b) Estimating Respondent Costs (i) Estimating Labor Co**  **sts** This I CR uses the following labor rates: Managerial $1 2 2

. 4 9 ($5 8

. 3 3 + 110%) Technical $ 10 1

. 2 8 ($4 8

. 2 3 + 110%) Clerical $ 50

. 80 ($2 4

. 19 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs**  The ty pe of industry

costs associated with the information collection activ ities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subject to the regulation. The annual operation and maintenance cost s are the ongoing costs to mainta in the monitors and other costs su ch as photocop yi ng and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenance (O&M) Costs**  (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/ Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) Leak detectors $9,000 0 $0 $1,470 98 $144,060 Flow rate mo nitors $7,500 0 $0 $2,000 64 $128,000 pH monitor $7,500 0 $0 $2,000 46 $92,000 Pressure drop $7,500 0 $0 $2,000 18 $36,000 VOC CEM $100,000 0 $0 $10,000 0 $0 Total $0 $400,060 Note: We assume that on average, 98 respondents will be subject to this standard. There will be no new foundries projected during the next three years. The total capital/startup costs for this I CR are zero . This is the total o f column D in the above ta ble.11

The total operation and maintenance (O&M) costs for this I CR are $400,060

. 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 y ears of the IC R is estimated to be $ 400,060

. These are the costs of recordkeeping

. **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. EPA's overall compliance and enforcement program i ncludes 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 ye ars of the ICR is estimated to be $40,838

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**
Ba sed on our research for this I CR, approximately 98 existing respondents will be subject to the se standard s on average over the next three years, . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 98 per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y th is ICR :12 **Number of Respondents**

Year (A) Number of Ne w 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 98 0 0 98
2 0 98 0 0 98
3 0 98 0 0 98 Average 0 98 0 0 98 1 New respondent include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 98

. The total number of annual responses per ye ar is calculated using the following table:

**Total Annual Responses**  (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D
Initial notification 0 0 0 0 Semiannual compliance reports 98 2 0 196 Startup, shutdown, malfunction reports 1 1 0 1 Total 197 The number of Total Annual Responses is 197. The total annual labor costs are $2,909,637

. Details regarding these estimates may be found below in Table 1. Annual Respondent Burden and Cost

– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents an d the Agency

are shown below in Tables 1 and 2 , respectively , and summarized below.13 **(i) Respondent Tally** The total annual labor hours are 29,747 hours for a cost of $2,909,637

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 151 hours per response
. The total annual capital/startup and O&M costs to the regulated entity are $400,060

. 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 y ears is estimated to be 906 labor hours at a cost of $40,838 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)

. **6(f) Reasons for Change in Burden** There is no change in labor hours in this I CR compared to the previous I CR. This is due to two considerations : 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three y ears ; and 2) 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 adjustment increase in the respondent labor costs due to an increase in labor ra tes. Additionally , there is an adjustment decrease in the Agency labor costs due to a correction of mathematical error. The previous I CR incorrectly calculated total Agency

labor cost for each burden item. **6(g) Burden Statement** The annual public repo rting and recordkeeping burden for this collection of information is estimated to average 151 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining informat ion, 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; 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 display s a valid OMB Control Number. The OMB Control14

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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0697

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a co py

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 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 Public 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 i s (202) 566

- 17 52

. 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 EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 2012

- 0697 and OMB Control Number 2060

- 0543 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**  **Iron and Steel Foundries (40 CFR Part**  **63 , Subpart**  **EEEEE )**  **(Renewal)**

**Burden item (A)**  **(B) (C)**  **(D) (E)**  **(F) (G)**  **(H) Person**  **hours per occurrence**  **No. of**

**occurrences per**  **respondent per year**  **Person**

**hours per respondent**  **per year Respondents** 

**per year a**  **Technical**

**person**   ** hours per** **year Managem**  **ent**

**person hours per year**  **Clerical**

**person hours**  **per year Total Cost** 

**p er year**  **b**

**(C=AxB) (E=CxD)**  **(Ex0.05) (Ex0.**  **1)** 1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements a. Read rule and instructions c 2 1 2 0 0 0 0 $0 b. Required activities c Initial performance tests d 70 3.8 266 0 0 0 0 $0 Follow

- up performance tests 70 0.8 56 0 0 0 0 $0 VOC CEMS performance tests d N/A Startup, shutdown, malfunction plan 34 1 34 0 0 0 0 $0 Operation and maintenance plan 72 1 72 0 0 0 0 $0 Scrap selection/inspection plan c 10 1 10 0 0 0 0 $0 Scrap inspection e 0.5 350 175 98 17,150 857.5 1,715 $1,929,109.18 Monthly inspections of capture systems, maintenance of control devices and mo nitoring systems, and mould vent ignition plan 2 12 24 18 432 21.6 43.2 $48,593.30
c. Create information See 3B d. Gather existing information See 3B e. Write report Notification of applicability c 2 1 2 0 0 0 0 $0 Notification of construction /reconstruction c 2 1 2 0 0 0 0 $0 Notification of actual startup c 2 1 2 0 0 0 0 $0 Notification of special compliance requirements c N/A16

Compliance extension request c 2 1 2 0 0 0 0 $0 Notification of performance test c 2 3.8 7.6 0 0 0 0 $0 Site

- specific test plan c 20 3.8 76 0 0 0 0 $0 N otification of CEMS performance evaluation c 60 1 60 0 0 0 0 $0 CEMS QA plan c 40 1 40 0 0 0 0 $0 Notification of compliance status c 8 1 8 0 0 0 0 $0 NESHAP w aiver application N/A Report of performance test See 3B Semiannual compliance reports f 16 2 32 98 3,136 156.8 313.6 $352,751.39 Startup, shutdown, malfunction reports g 4 1 4 1 4 0.2 0.4 $449.94 **Subtotal for Reporting Requirements 23,830**  **.3 $2,330,903.81**  4 Recordkeeping requirements a. Read instructions See 3A b. Plan activities 3 1 3 0 0 0 0 $0 c. Implement activities c 12 1 12 0 0 0 0 $0 d. Develop record system h 3 1 3 0 0 0 0 $0 e. Time to enter information i 1 52 52 98 5,096 254.8 509.6 $573,221.01 f. Time to train personnel 3 2 6 0 0 0 0 $0 g. Time to adjust existing ways to comply with previously applicable requirements N/A h. Time to transmit information j 0.25 2 0.5 98 49 2.45 4.9 $5,511.74 i. Time for audits N/A **Subtotal for Recordkeeping Requirements 5,91**  **6.75 $578,732.75**  **TOTAL LABOR BURDEN AND COST (rounded) 29,747**  **$2,909,637**
**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to this rule will be 98. There will be no new fo undries projected during the next three years of this ICR. b This ICR uses the following labor rates: $122.49 per hour for Exec utive, Administrative, and Managerial labor; $101.28 per hour for Technical labor, and $50.80 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2 012, Table 2. Civilian Workers, b y occupational and industry group. The rates are from column 1, Total Compensation. The rates have been increased by 110 perc ent to account for the benefit packages available to those employed by private industry.17

c We have assumed that existing respondents are in compliance with the initial rule requirements. New respondents would have t o com ply w ith the initial rule requirements including notification and performance test for add

- on control devices. d Performanc e tests are required for particulate matter by Method 5 or total metal HAP by Method 29, for triethylamine by Method 18, and VOHAP by Method 18 or 25A, depending on the emission source. We have assumed that 20 percent of respondents would repeat performan ce tests due to failure. e Monitoring and recordkeeping of operations for respondents with add

- on control devices include: 1) specific operating parameters for each control device established during the performance test, 2) startup, shutdown, and malfunct ion of equipment, 3) work practices including an inspection of iron and steel scrap to minimize, to the extent practicable, the amount of organics and HAP metals in the charge materials used by the metal casting department. f We have assumed that responde nts are required to submit semiannual compliance reports. g We have assumed that one respondent with add

- on controls per year will have at least one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plans. h We have assumed that new respondents would of already have the technology and recordkeeping systems in place to monitor its daily operations and to comply with existing regulations. i We have assumed that it will take each respondent one hour 52 times per year to enter i nformation. j We have assumed that it will take each of the respondents 15 minutes two times per year to transmit information.18

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE)**  **(Renewal)**

**Activity (A)**  **(B) (C)**  **(D) (E)**  **(F) (G)**  **(H) EPA**  **person**   ** hours per** **occurrence No. of** 

**occurrences per plant**  **per year EPA person** 
****

**hours per plant per**  **year Plants** 

**per year**  **a Technical** 

**person**   ** hours per** **year Managem**  **ent**

**person**   ** hours per** **year Clerical** 

**person**   ** hours** **per year Total** 

**Cost, $ b** 
**(C=AxB) (E=CxD)**  **(Ex0.05) (Ex0.1)**  Initial performance test 40 1 40 0 0 0 0 $0 Repeat performance

– retesting 40 1 40 0 0 0 0 $0 Report review c Notification of construction /reconstruction N/A Notification of actual startup N/A Notification of special compliance requirements N/A Notification of applicability 2 1 2 0 0 0 0 $0 Notification of initial performance test 2 1 2 0 0 0 0 $0 Notification of CEMS performance evaluation 2 1 2 0 0 0 0 $0 CEMS QA plan 2 1 2 0 0 0 0 $0 Notification of compliance status 4 1 4 0 0 0 0 $0 Site

- specific test plan 2 1 2 0 0 0 0 $0 Scrap selection/inspection plan 4 1 4 0 0 0 0 $0 Repeat performance test report 2 1 2 0 0 0 0 $0 Semiannual compliance reports d 4 2 8 98 784 39.2 78.4 $40,630.41 NESHAP w aiver application 4 1 4 0 0 0 0 $0 Compliance extension request 4 1 4 0 0 0 0 $0 Scrap inspections N/A Emergency startup, shutdown, and malfunction report e 4 1 4 1 4 0.2 0.4 $207.30 Subtotals Labor Burden and cost 788 39.4 78.8 $40,837.71 **TOTAL ANNUAL BURDEN AND COST (rounded) 906**  **$40,838**
**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to this rule will be 98. There will be no new fo undries projected during the next three years of this ICR.19

b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 Managerial rate (GS

- 13, Step 5), $46.21 Technical rate (GS

- 12, Step 1), and $25.01 Clerical rate ( GS

- 6, Step 3). These rates are from the Office of Personnel Management (OPM) 2012 General Schedule which excludes locality rates of pay, and have been increased by 60 percent to account for benefit packages available to government employees. c We have as sumed that existing respondents are in compliance with the initial rule requirements. New respondents would have to comply w ith the initial rule requirements including notification and performance test for add

- on control devices. d We have assumed that r espondents are required to submit semiannual compliance reports
e We have assumed that one respondent with add

- on controls per year will have one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plans.