SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(Renewal) 

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(Renewal), EPA ICR Number 2267.04, OMB Control Number 2060-0605.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron and 

Steel Foundry Area Sources were promulgated on January 2, 2008 (73 FR 225). These 

regulations apply to new and existing iron or steel foundries that are an area source of hazardous 

air pollutants (HAP) emissions. There are different requirements for foundries based on size. 

Existing foundries with an annual metal melt production greater than 20,000 tons and new 

foundries with an annual metal melt capacity greater than 10,000 tons are classified as large 

foundries. Existing foundries with an annual metal melt production of 20,000 tons or less and 

new foundries with an annual metal melt capacity of 10,000 tons or less are classified as small 

foundries.

Research and development facilities are not covered by the rule. Foundries covered by 

the rule would not be required to obtain a Title V operating permit. New facilities include those 

that commenced construction or reconstruction on or after September 17, 2007, the date of 

proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart 

ZZZZZ.

In general, all NESHAP standards require initial notification reports, 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 U.S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 427 respondents per year will be subject to these

standards, and no additional respondents per year will become subject to these same standards. 

This estimate consists of 344 small foundries and 83 large foundries. 
2

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

without any “Terms of Clearance.”

In the United States, there are approximately 427 iron and steel foundries that are owned 

and operated by the iron and steel foundry industry. None of these 427 facilities are owned by 

either state, local, or tribal, entities or by the Federal government. They are owned and operated 

by privately-owned, for-profit businesses. The ‘burden’ to the “Affected Public” may be found 

below in Tables 1a-1c: Annual Respondent Burden and Cost – NESHAP for Iron and Steel 

Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal). The Federal Government 

‘burden’ is attributed entirely to work performed by either Federal employees or government 

contractors and may be found below in Table 2: Average Annual EPA Burden and Cost –

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(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 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 

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, HAP emissions from iron foundries and steel foundries

either cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 

CFR Part 63, Subpart ZZZZZ.

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

The recordkeeping and reporting requirements in the standard ensure compliance with the

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

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

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. 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 notifications 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 properly 

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 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

ZZZZZ.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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

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

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

burden published in the Federal Register. 

3(c) Consultations

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

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

primary source of information as reported by industry, in compliance with the recordkeeping and 
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reporting provisions in the standard, is Enforcement and Compliance History Online (ECHO), 

which is operated and maintained by the EPA’s Office of Compliance. ECHO 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.

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

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

this ICR, we contacted both the American Foundry Society, at (800) 537-4237, and the Steel 

Founders’ Society of America, at (847) 382-8240.

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 first Federal Register notice. 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 frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

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

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 on 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, 
5

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 iron and steel 

foundries. The United States Standard Industrial Classification (SIC) code for the respondents 

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

(NAICS) code are listed in the table below: 

Standard (40 CFR Part 63, Subpart ZZZZZ) 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 by the NESHAP for Iron 

and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ). 

A source must make the following reports:

Notifications

Notification of applicability §63.9(b)(2); 

§63.10899(d)

Notification of construction/ reconstruction §63.9(b)(5)

Notification of special compliance requirements §63.9(d)

Notification of performance test (large foundries) §63.9(c); §63.10898 

Notification of opacity/VE observations (large foundries) §63.9(f)

Additional CMS notifications §63.9(g)
6

Notifications

Notification of compliance status §63.9(h)(1); 

§63.10900 

Notification of changes in information §63.9(j)

Reports

Semiannual excess emissions/deviation reports §63.10(e)(3), 

§63.10899(b)(2) 

§63.10899(c)

Initial performance test report (large foundries) §63.7(e)(1), 

§63.10898 

CMS performance evaluation report §63.8(e)(5),

§63.10898 

SSM reports (large foundries) §63.6(e)(3), 

§63.10897(g) 

A source must keep the following records:

Recordkeeping

Material specifications – written materials specifications, records that 

demonstrate compliance with requirements for restricted metallic 

scrap, general scrap, mercury, and scrap that does not contain motor 

vehicle scrap. 

§63.10899(b)(1), 

§63.10890(e)(2)

Mercury – records of number of mercury switches removed or weight 

of mercury recovered, estimated number of vehicles processed, 

estimate the percent of mercury switches recovered; records 

identifying each scrap provider and documenting the scrap provider's 

participation in an approved mercury switch removal program

§63.10899(b)(2)-(3), 

§63.10890(e)(3)-(4)

Non-methanol binder chemical formulations - Material Safety Data 

Sheet, certified product data sheet, or a manufacturer’s hazardous air 

pollutant data sheet.

§63.10899(b)(4), 

§63.10890(e)(5)

Annual quantity and composition of each HAP-containing chemical 

binder or coating material - copies of purchasing records, Material 

Safety Data Sheets, or other documentation that provide information 

on the binder or coating materials used

§63.10899(b)(5), 

§63.10890(e)(6)

Metal melt production §63.10899(b)(6), 

§63.10890(e)(7)

Operation and maintenance plan (large foundries) §63.10899(b)(7)
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Recordkeeping

If applicable, emissions averaging plan (large foundries) §63.10899(b)(8)

Bag leak detection system (new sources) (large foundries) §63.10899(b)(9)

Capture system inspections (large foundries) §63.10899(b)(10)

CPMS specifications (large foundries) §63.10899(b)(11)

Corrective action (large foundries) §63.10899(b)(12)

PM control device log of inspections/maintenance (large foundries) §63.10899(b)(13); 

§63.10897

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

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

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

a plant site. 

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

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

widely used. At this time, it is estimated that approximately 0 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

supply pressure for control device. 

Perform initial performance test, Reference Method 1 or 1A; 2, 2A, 2C, 2D, 2F, or 2G, 3, 3A, 

or 3B ; 4; 5, 5B, 5D, 5F, or 5I; 29; 9 or 22 tests, and repeat performance tests if necessary.

Implement initial and periodic inspections and maintenance of control devices (e.g., PM 

control devices, baghouses, dry electrostatic precipitator and wet scrubber)

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

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

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

reduced the burden associated with monitoring and recordkeeping. 

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

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 properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard and note the operating conditions under which compliance was 

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

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

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

determinations.
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Information contained in the reports is reported by state and local government in the ICIS 

Air database which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s 

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

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

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

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

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

years.

5(c) Small Entity Flexibility

A small entity for this industry is defined by the Small Business Administration as a firm 

having no more than 500 employees. A total of 319 of the 427 iron and steel foundries are small 

entities. Approximately 45 percent (37 of 83) of the large iron and steel foundries (annual metal 

melt production greater than 20,000 tons) are owned by small entities while 85 percent (292 of

344) of the small iron and steel iron and steel foundries are owned by small entities. The final 

rule includes a specific compliance option for small foundries that provides a maximum degree 

of operational flexibility, and the ICR requirements are the minimum necessary to demonstrate 

compliance. Since proposal, we have further reduced the impacts on small entities by increasing 

the threshold definition for a small foundry from an annual melt production of 10,000 tons to 

20,000 tons. Our analyses show that the final NESHAP will not result in a significant economic 

impact on a substantial number of small entities. No small entity is expected to incur an 

economic impact that is greater than 3 percent of its revenue. The number of foundries that may

incur an economic impact greater than 1 percent of their revenues ranges from an average of 9 to 

a maximum (at the 98th percentile) of 13.

5(d) Collection Schedule

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

shown below in Tables 1a-1c: Annual Respondent Burden and Cost – NESHAP for Iron and 

Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

6. Estimating the Burden and Cost of the Collection

Tables 1a-1c 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, specific tasks and 

major assumptions 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 displays a currently valid OMB Control Number.
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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 7,893 (Total Labor Hours from Table 1c). 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

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 

subject 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 costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent 1

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent 2

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

N/A $718.31 0 $0 $0 0 $0

1 We assume large foundries will incur capital costs by purchasing file storage cabinets. During the initial rule 

development, we estimated the total capital cost to be $59,620 for all 83 large foundries ($718.31 per respondent). 
11

At 7 percent interest and 20-year equipment life (capital recovery factor = 0.142), the annualized capital cost is 

$8,490 per year for all foundries. 

2 No costs for monitoring equipment are estimated because no monitoring equipment is required for existing 

sources.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $0. This is the total of 

column G. 

The average annual cost for both capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $0. 

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$35,937. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Iron and 

Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

427 existing respondents will be subject to the standards. It is estimated that no additional 

respondents per year will become subject to this rule. A total of 344 of the 427 facilities have 

metal melting rate of 20,000 tpy or less (small foundries) and 83 have metal melting rates greater 

than 20,000 tpy (large foundries). As shown in the table below, the overall average number of 

respondents is 427 per year. 
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The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 427 0 0 427

2 0 427 0 0 427

3 0 427 0 0 427

Average 0 427 0 0 427

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 427. 

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 Notification 0 0 0 0

Notification of Compliance Status 0 0 0 0

Deviations Report (small 

foundries) 172 1 0 172

Repeat of Performance Test 

(large foundries) 83 0.2 0 17

SSM plan (large foundries) 83 1 083
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Total Annual Responses

Semiannual compliance reports

(large foundries) 83 2 0 166

Total 438

The number of Total Annual Responses is 438. 

The total annual labor costs are $772,735. Details regarding these estimates may be 

found below in Tables 1a-1c: Annual Respondent Burden and Cost – NESHAP for Iron and 

Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

Agency are shown in Tables 1a-1c and Table 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 7,893 hours. Details regarding these estimates may be 

found in Tables 1a-1c: Annual Respondent Burden and Cost – NESHAP for Iron and Steel 

Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal). 

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

information is estimated to average 18 hours per response.

The annual total of both capital/startup and O&M costs to the regulated entity are $0. 

These 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 790 

labor hours at a cost of $35,937. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) 

(Renewal).

6(f) Reasons for Change in Burden

The increase in burden from the most recently-approved ICR is due to several changes.

This ICR uses updated labor rates, adds burden requirements to repeat certain performance tests

(PM tests for large foundries and opacity tests for all foundries), and corrects the average number 

of respondents per year. The previous ICR incorrectly carried-over the estimated burden from 

the initial 3-year compliance period of the rule, and calculated the average number of respondent 
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per year by dividing the total number of respondents by three. This ICR revised the average 

number of respondents per year (total of 427, rather than 142.3) to reflect correctly the current 

annual burden activities for all existing respondents. This correction results in an increase in 

burden hours and costs for both the respondents and the Agency as compared to the previous 

ICR.

There is also a decrease in the capital/startup costs as calculated in section 6(b)(iii) 

compared to the previous ICR. The previous ICR estimated capital costs associated with 

purchasing file cabinets. Since we expect this to be a one-time cost for new respondents only, 

we have removed this capital cost in this ICR renewal. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 18 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

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

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

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

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

Docket ID Number EPA-HQ-OECA-2014-0096. An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. 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-2014-0096 and OMB Control Number 2060-0605 in any
15

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 1a: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 

CFR Part 63, Subpart ZZZZZ) (Renewal)

Burden item (A) 

Person hours per occurrence

(B) 

No. of occurrences per 

respondent per year

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization of Technology and Systems N/A

4. Reporting Requirements

A. Read instructions g4 1

B. Required activities

 Repeat performance tests for opacity e0.1 2

 Scrap specifications g4 1

 Monthly rolling average calculation 0.25 12

 No methanol binder formulation c0 0

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

 Initial notification of applicability g2 1

 Notification of compliance status 4 1

 Deviations report 1 1

 Notification of construction/reconstruction N/A

 Notification of anticipated startup N/A

 Notification of actual startup N/A

 Notification of foundry reclassification e1 0
17

Burden item (A) 

Person hours per occurrence

(B) 

No. of occurrences per 

respondent per year

 Request for compliance extension N/A

 Notification of repeat of performance test N/A

 Site specific test plan N/A

 Notification of performance evaluation N/A

 Quality assurance plan for CEMS/COMS N/A

 NESHAP waiver request N/A

 Startup, shutdown, and malfunction plan/reports N/A

 Semiannual excess emissions reports N/A

Subtotal for Reporting Requirements

5. Recordkeeping Requirements 

A. Read instructions See 4A

B. Plan activities See 4A

C. Implement activities See 4A

D Develop record system 2 1

E. Time to enter information 0.1 52

F. Time to transmit or disclose information 0.25 2

G. Time to adjust existing ways g2 1

F. Time to train personnel g N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements

TOTAL LABOR BURDEN AND COST (rounded)

Assumptions:

a We have assumed that there are 427 existing iron and steel foundries that area sources. No new sources are projected during the 3-year term of this ICR. A total of 344 of the 427 facilities are smal
18

Burden item (A) 

Person hours per occurrence

(B) 

No. of occurrences per 

respondent per year

b This ICR uses the following labor rates: The hourly wage rates used to represent respondent labor costs are: technical at $101.05, management at $128.02, and clerical at $51.37. These rates are fro

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 no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.

d We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations. In addition, t

e We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a proc

6 minutes (or 0.1 hrs). No separate notification required.

f We have assumed that no cost would be incurred to train personnel.

g One-time only costs
19

Table 1b: Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 

CFR Part 63, Subpart ZZZZZ) (Renewal)

Burden item

(A) Person 

hours per 

occurrence

(B) No. of 

occurrences 

per 

respondent 

per year

(C) Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per year 

(Ex0.1)

(H) Total 

Cost per 

year b

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization of 

Technology and Systems N/A

4. Reporting Requirements

A. Read instructions h

8 1 8 0 0 0 0 $0

B. Required activities 

 Repeat of Performance Test for PM d24 0.2 4.8 83 398.4 19.92 39.84 $44,855.06

 Repeat performance tests for opacity e0.1 2 0.2 83 16.6 0.83 1.66 $1,868.96

 Scrap material specifications g

4 1 4 0 0 0 0 $0.00

 Prepare operation & maintenance plan g

8 1 8 0 0 0 0 $0.00

 No methanol binder formulation c

4 1 4 0.67 2.68 0.13 0.27 $301.74

Initial/subsequent performance tests e

0 0 0 0 0 0 0 $0

Initial and periodic inspections of PM control 

devices, monthly inspection of capture systems 

d

0 0 0 0 0 0 0 $0

Monthly emissions averaging calculations e

0 0 0 0 0 0 0 $0

C. Create information See 4B

D. Gather existing information See 4B

E. Write report See 4B

 Initial notification of applicability h

4 1 4 0 0 0 0 $0
20

Burden item

(A) Person 

hours per 

occurrence

(B) No. of 

occurrences 

per 

respondent 

per year

(C) Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per year 

(Ex0.1)

(H) Total 

Cost per 

year b

 Notification of compliance status h

8 1 8 0 0 0 0 $0

 Notification of construction/reconstruction N/A

 Notification of anticipated startup N/A

 Notification of actual startup N/A

 Notification of foundry reclassification d

1 0 0 0 0 0 0 $0

 Request for compliance extension N/A

 Notification of repeat of PM performance 

test e 1 0.2 0.2 83 16.6 0.83 1.66 $1,868.96

 Site specific test plan e

0 0 0 0 0 0 0 $0

 Notification of performance evaluation N/A

 Quality assurance plan for CEMS/COMS N/A

 NESHAP waiver request N/A

 Startup, shutdown, and malfunction 

plan/reports 4 1 4 83 332 16.60 33.20 $37,379.22

 Semiannual excess emissions reports e

2 2 4 83 332 16.60 33.20 $37,379.22

Subtotal for Reporting Requirements 1,263 $123,653.15

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities See 4A

C. Implement activities See 4A

D Develop record system 4 1 4 0 0 0 0 $0

E. Time to enter information f

0.5 52 26 83 2,158 107.9 215.8 $242,964.90

F. Time to transmit or disclose information 0.25 2 0.5 83 41.50 2.08 4.15 $4,672.40

G. Time to adjust existing ways h

2 1 2 0 0 0 0 1. $0
21

Burden item

(A) Person 

hours per 

occurrence

(B) No. of 

occurrences 

per 

respondent 

per year

(C) Person 

hours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per year 

(Ex0.1)

(H) Total 

Cost per 

year b

F. Time to train personnel g

4 1 4 83 332 16.6 33.2 $37,379.22

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 2,911 $285,016.52

TOTAL LABOR BURDEN AND COST (rounded) 4,174 $408,670

Assumptions:

a We have assumed that there are 427 existing iron and steel foundries that area sources. No new sources are projected during the 3-year term of this ICR. A total of 344 of the 427 

facilities are small foundries and 83 are large foundries. 

b This ICR uses the following labor rates: The hourly wage rates used to represent respondent labor costs are: technical at $101.05, management at $128.02, and clerical at $51.37. 

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates 

are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c We assumed that two large area source foundries (2 foundries over 3 years = 0.67 foundries per year) are expected to have to change formulations to meet the no methanol 

requirement.

d We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal 

HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to a change to an operating limit or a process 

change likely to increase HAP emissions over the period of this ICR. 

e We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will 

not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity shall be determined as an average of 24 consecutive observations 

recorded at 15-second intervals, which average about 6 minutes (or 0.1 hrs). No separate notification required. 

f We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder 

formulations and information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of 

the General Provisions (40 CFR part 63, subpart A). In addition, record to record information to demonstrate compliance with the PM and opacity standards. 

g We have assumed that large foundries are expected to monitor visible emissions using a trained employee.

h One-time only costs
22

Table 1c: Annual Respondent Burden and Cost for All Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 

CFR Part 63, Subpart ZZZZZ) (Renewal)

Table Category Reporting 

Hours

Recordkeeping 

Hours

Burden Hours Burden Cost

1a Small Foundries 1,464 2,255 3,719 $364,065

1b Large Foundries 1,263 2,911 4,174 $408,670

Total 2,727 5,166 7,893 $772,735
23

Table 2: Average Annual EPA Burden and Cost – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, 

Subpart ZZZZZ) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

person 

hours 

per plant 

per year 

(AxB)

(D) 

Plants 

per 

year a 

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year (Ex0.1)

(H) 

Cost, $ b

Report Review:

 Initial notification of applicability c

1 1 1 0 0 0 0 $0

Deviation reports 1 1 1 172 172 8.6 17.2 $9,002.48

 Startup, shutdown, malfunction plan/report 2 1 2 83 166 8.3 16.6 $8,688.44

 Notification of compliance status c

2 1 2 0 0 0 0 $0

 Notification of performance tests d

1 0.2 0.2 83 16.6 0.83 1.66 868.84

 Semiannual excess emissions report 2 2 4 83 332 16.6 33.2 $17,376.88

TOTAL BURDEN AND COST (rounded) 790 $35,937

Assumptions:

a There are 427 existing iron and steel foundries that are area sources. No new sources are projected during the 3-year term of this ICR. For the purposed of deviation reports, 1 

report per year is estimated for one-half of the small foundries. For plan/reports and semiannual reports all large foundries (83 respondents) will submit reports.

b This ICR uses the following average hourly labor rates (GS-13, Step 5, $ x 1.6): 62.90 for managerial, $46.67 for technical and $25.25 for clerical. These rates are from the Office 

of Personnel Management (OPM) "2014 General Schedule" which excludes locality rates of pay.

c One-time only costs

d We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal 

HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to change to an operating limit or a process 

change likely to increase HAP emissions.