SUPPORTING
STATEMENT
NESHAP
FOR
IRON
AND
STEEL
FOUNDRIES:
(
FINAL
RULE)

(
40
CFR
PART
63,
SUBPART
EEEEE)

PART
A
1.0
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection.

"
NESHAP
for
Iron
and
Steel
Foundries:
(
Final
Rule)
(
40
CFR
part
63,
subpart
EEEEE)."
This
is
a
new
information
collection
request
(
ICR)
that
has
been
assigned
Environmental
Protection
Agency
(
EPA)
ICR
number
2096.02.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
iron
and
steel
foundries
that
are
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions.
The
national
emission
standard
for
hazardous
air
pollutants
(
NESHAP)
applies
to
emissions
sources
in
new
and
existing
foundries.
Research
and
development
facilities
and
small­
scale
production
operations
are
not
covered
by
the
rule.

The
NESHAP
sets
emissions
limits
for
metal
and
organic
HAP
along
with
operating
limits
for
capture
systems
and
control
devices.
All
respondents
are
required
to
prepare
and
follow
an
operation
and
maintenance
plan
for
capture
systems,
control
devices
(
including
corrective
action
procedures
for
bag
leak
detection
system
alarms),
and
mold
vent
ignition
procedures.

Work
practice
standards
require
that
foundries
meet
certification
requirements
for
their
charge
materials
or
prepare
and
follow
a
2
scrap
selection
and
inspection
plan.
Respondents
also
must
use
binder
chemical
formulations
that
contain
no
methanol
(
for
the
catalyst
portion
of
the
formulation).
Consistent
with
the
NESHAP
General
Provisions,
all
respondents
must
prepare
and
follow
a
startup,
shutdown,
and
malfunction
plan.

Respondents
demonstrate
initial
compliance
through
performance
tests
and
compliance
certifications.
Continuous
compliance
is
demonstrated
through
repeat
performance
tests
(
every
5
years
for
emissions
limits
and
every
6
months
for
the
opacity
limit
for
fugitive
emissions
from
foundry
operations).

Foundries
also
must
monitor
capture
system
and
control
device
operating
parameters.
A
continuous
emissions
monitoring
system
(
CEMS)
is
required
for
automated
pallet
and
cooling
lines
and
automated
shakeout
lines
at
new
foundries;
procedures
are
included
in
the
rule
for
requesting
alternative
monitoring
requirements.
Installation
and
operation
requirements
are
included
for
bag
leak
detection
systems,
continuous
parameter
monitoring
systems
(
CPMS),
and
CEMS.
Respondents
must
submit
one­
time
notifications
as
required
by
the
NESHAP
General
Provisions
and
semiannual
reports
of
deviations
from
the
rule
requirements.
An
immediate
report
is
required
if
actions
taken
in
response
to
the
startup,
shutdown,
or
malfunction
were
not
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

Respondents
must
maintain
records
of
specific
information
to
3
ensure
that
the
rule
requirements
are
being
achieved
and
maintained.
These
requirements
are
listed
in
Attachment
1.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

The
EPA
is
charged
under
section
112
of
the
Clean
Air
Act,

as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAP]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
major
sources,
identify
any
non­
major
sources
not
subject
to
the
standards,
and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
MACT
standards
are
being
achieved.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.

(
b)
Use/
Users
of
the
Data.

The
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new
or
reconstructed
sources
subject
to
the
standards,
(
2)
ensure
that
MACT
is
being
properly
4
applied,
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Based
on
the
reported
information,
EPA
can
decide
which
plants,

records,
or
processes
should
be
inspected.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
computer
search
of
the
Federal
Information
Locator
System
indicated
that,
with
the
exception
of
the
New
Source
Performance
Standards
for
Electric
Arc
Furnaces
(
40
CFR
part
60,
subparts
AA
and
AAa),
there
are
no
similar
information
requests
being
carried
out
by
the
Federal
government.
A
similar
search
of
EPA's
ongoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
this
rule.

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

This
section
is
not
applicable
because
this
is
a
rulerelated
ICR.

(
c)
Consultations.

This
rule
was
developed
in
consultation
with
State
and
local
agencies,
EPA
Regional
Office
experts,
individual
foundries,
and
their
trade
associations.
For
example,
several
meetings
and
telephone
consultations
were
held
with
representatives
from
the
5
American
Foundrymen's
Society.
The
non­
EPA
persons
consulted
prior
to
proposal
of
the
standards
are
identified
in
Table
1.

TABLE
1.
PERSONS
CONSULTED
ON
THE
PROPOSED
INFORMATION
COLLECTION
ACTIVITIES
Contact
Organization
Telephone
Number
Gary
Mosher
American
Foundrymens'
Society
(
847)
824­
0181
Raymond
Monroe
Steel
Founders'
Society
of
America
(
847)
382­
8240
(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,

EPA
would
not
be
reasonably
assured
that
a
plant
is
in
compliance
with
the
standards.

(
e)
General
Guidelines.

None
of
the
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
f)
Confidentiality.

All
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B
­­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
28,

1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,

1979).

(
g)
Sensitive
Questions.

This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAIC
Codes.

Potential
respondents
are
owners
or
operators
of
new
or
existing
foundries
that
are
major
sources.
We
estimate
that
98
of
the
650
existing
foundries
are
major
sources
that
will
be
6
subject
to
the
rule
requirements.
No
new
foundries
are
projected
during
the
3­
year
period
of
this
ICR.
The
NAIC
codes
are
331511
for
iron
foundries,
331512
for
steel
investment
foundries,
and
331513
for
steel
foundries
(
except
investment).

(
b)
Information
Requested.

(
i)
Data
Items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
Activities.
The
respondent
activities
required
by
the
rule
are
identified
in
Table
2
and
introduced
in
section
6(
a).

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
3
and
introduced
in
section
6(
c).

(
b)
Collection
Methodology
and
Management.

This
is
not
relevant
to
this
information
collection
request.

(
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.
Twenty
foundries
have
been
identified
as
small
entities.
None
of
the
foundries,
including
the
small
entities,

are
at
risk
of
closure
as
a
result
of
the
rule.
The
rule
provides
a
maximum
degree
of
operational
flexibility,
and
the
ICR
requirements
are
the
minimum
necessary
to
demonstrate
compliance.

Affected
plants
will
have
3
years
to
demonstrate
compliance,
and
the
Administrator
or
permitting
authority
may
grant
1
additional
year
if
more
time
is
needed
to
install
controls.

(
d)
Collection
Schedule.

Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
National
Compliance
Database
(
NCDB)
operated
and
7
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
enforcement
and
compliance
programs.
A
schedule
for
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
are
triggered
by
actions
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
information
burden
estimates
for
reporting
and
recordkeeping
are
presented
in
Table
2.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
the
final
rule
are
presented
in
Table
2.
Because
much
of
the
data
are
already
collected
by
respondents
or
required
by
existing
law,
minimal
respondent
development
costs
are
associated
with
the
information
collection
activities
for
the
rule.

(
i)
Estimating
Labor
Costs.
Labor
rates
and
associated
costs
are
based
on
Bureau
of
Labor
Statistics
(
BLS)
data.

Technical,
management,
and
clerical
average
hourly
rates
for
private
industry
workers
were
taken
from
the
March
2003
Employment
Cost
Trends
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t10.
htm).

Wages
for
white­
collar
occupations
are
used
as
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
30.54/
hour
for
technical,
$
44.33/
hour
for
managerial,
and
$
18.88/
hour
for
clerical.
These
rates
represent
salaries
plus
fringe
benefits
and
do
not
include
the
cost
of
overhead.
An
overhead
rate
of
110
percent
is
used
to
account
for
these
costs.
The
fully­
burdened
wage
rates
used
to
represent
respondent
labor
costs
are:

technical
at
$
64.13,
management
at
$
93.09,
and
clerical
at
$
39.64.
8
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)

Costs.
As
shown
in
Table
2
(
p.
15),
the
estimate
of
capital
and
operations
and
maintenance
costs
is
$
272,600
per
year.

(
iii)
Capital/
Startup
vs.
O&
M
Costs.
The
estimate
of
capital/
startup
costs
versus
O&
M
costs
is
shown
in
Table
2
(
p.
15).
The
annual
O&
M
cost
over
the
3­
year
period
of
this
ICR
is
$
133,300
per
year.

(
iv)
Annualizing
Capital
Costs.
Table
2
(
p.
15)
shows
an
estimate
of
the
annualized
cost
of
capital
to
be
$
139,300
per
year.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
the
MACT
standards,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program,
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Table
3.

The
Agency
labor
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
2003
General
Schedule
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
Salary
Table
2003­

GS
available
on
the
OPM
website,

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf
.
The
government
9
employee
labor
rates
are
$
13.91/
hour
for
clerical
(
GS­
7,
Step
1),

$
29.35
for
technical
(
GS­
13,
Step
1),
and
$
40.80/
hr
for
management
(
GS­
15,
Step
1).
These
rates
represent
salaries
plus
fringe
benefits
and
do
not
include
the
cost
of
overhead.
An
overhead
rate
of
110
percent
is
used
to
account
for
these
costs.
The
fully­
burdened
wage
rates
used
to
represent
Agency
labor
costs
are:
clerical
at
$
22.26;
technical
at
$
46.96,
and
management
at
$
65.28.

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

The
EPA
estimates
that
98
foundries
will
install
the
required
emissions
control
and
monitoring
equipment,
conduct
initial
performance
tests,
prepare
the
required
written
plans,
and
provide
the
one­
time
notifications
during
the
3­
year
clearance
period
for
this
ICR.
No
compliance
reports
will
be
submitted
during
this
3­

year
period
because
plants
do
not
have
to
comply
until
after
the
term
of
this
ICR.
For
the
same
reason,
no
costs
will
be
incurred
during
the
3­
year
period
for
inspections,
operation
and
maintenance
of
control
devices
and
monitoring
systems,
and
mold
vent
ignition
procedures.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
2,
are
calculated
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,

and
clerical
staff,
and
by
adding
down
the
cost
column.
The
total
annual
hours
are
22,325
hours;
the
estimated
cost
is
$
1,354,049
per
year
including
technical,
management,
and
clerical
hours.
The
total
cost
given
in
Table
2,
including
the
cost
of
labor,
capital,

operation,
and
maintenance,
is
$
1,626,649
per
year.
The
annualized
cost
of
capital
for
monitoring
devices
is
$
139,300
10
averaged
over
the
first
3
years
of
the
ICR.
This
is
based
on
an
equipment
lifetime
of
20
years,
an
interest
rate
of
7
percent,
and
a
capital
recovery
factor
of
0.142.
Operation
and
maintenance
costs
(
excluding
any
labor
hours
given
in
the
labor
burden
estimate)
are
estimated
at
$
133,300
per
year
averaged
over
the
3­

year
period.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
3,
are
calculated
by
adding
personhours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,

total
cost
is
the
sum
of
this
total
salary
cost
and
total
travel
expenses
for
tests
attended.
The
total
annual
hours
are
629.
The
total
annual
cost
is
$
31,169.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
ICR.

(
g)
Burden
Statement
The
average
annual
respondent
burden
per
facility
is
estimated
at
228
hours.
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.
11
An
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.
The
OMB
control
numbers
for
EPA's
regulations
in
40
CFR
part
63
are
listed
in
40
CFR
part
9.

To
comment
on
the
Agency's
need
for
this
information
the
accuracy
of
the
provided
burden
estimates,
and
any
suggestions
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0034,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,

Room
B­
102,
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
AIR
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
docket.
Use
EDOCKET
to
submit
or
view
public
comments,
and
to
access
the
index
listing
of
the
contents
of
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,",
then
key
in
the
docket
ID
number
identified
above.
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
No.
OAR­
2002­
0034
in
any
correspondence.

PART
B
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
12
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
(
C)

Personhours
per
respondent
(
C=
AxB)
(
D)
Respondents
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
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
40
1
40
32.66b
1,306
65
131
$
91,119
4.
Reporting
Requirements
A.
Read
instructions
2
1
2
32.66b
65
3
7
$
4,556
B.
Required
activities
Initial
performance
tests
70
3.8c
266
32.66b
8,688
434
869
$
605,944
Followup
performance
testsd
NA
VOC
CEMS
performance
evaluation
and
performance
testd
NA
Startup,
shutdown,
malfunction
plan
34
1
34
32.66b
1,110
56
111
$
77,452
Operation
and
maintenance
plan
72
1
72
32.66b
2,352
118
235
$
164,015
Scrap
selection/
inspection
plan
10
1
10
32.66b
327
16
33
$
22,780
Scrap
inspectionsd
NA
Monthly
inspections
of
capture
systems
and
maintenance
of
control
devices
and
monitoring
systems,
and
mold
vent
ignition
pland
NA
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
(
C)

Personhours
per
respondent
(
C=
AxB)
(
D)
Respondents
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
13
E.
Write
report
Notification
of
applicability
2
1
2
32.66b
65
3
7
$
4,556
Notification
of
constr./
reconstr.
N/
A
Notification
of
anticipated
startup
N/
A
Notification
of
actual
startup
N/
A
Notification
of
special
compliance
requirements
N/
A
Compliance
extension
request
2
1
2
5e
10
0.5
1.0
$
697
Notification
of
performance
test
2
3.8c
7.6
32.66b
248
12
25
$
17,313
Site­
specific
test
plan
20
3.8c
76
32.66b
2,482
124
248
$
173,127
Notification
of
CEMS
performance
evaluation
NA
CEMS
q/
a
plan
NA
Notification
of
compliance
status
8
1
8
32.66b
261
13
26
$
18,224
NESHAP
waiver
application
N/
A
Report
of
performance
test
See
4B
Semiannual
compliance
reportsd
NA
Emergency
startup,
shutdown,
or
malfunction
reportsd
NA
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4A
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
(
C)

Personhours
per
respondent
(
C=
AxB)
(
D)
Respondents
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
14
B.
Plan
activities
3
1
3
32.66b
98.0
4.90
9.80
$
6,834
C.
Implement
activities
12
1
12
32.66b
391.9
19.6
39.2
$
27,336
D.
Develop
record
system
3
1
3
32.66b
98.0
4.90
9.80
$
6,834
E.
Time
to
enter
information
1
52
52
32.66b
1,698
84.9
169.8
$
118,455
F.
Time
to
train
personnel
3
1
3
32.66b
98.0
4.90
9.80
$
6,834
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
3
1
3
32.66b
98.0
4.90
9.80
$
6,834
H.
Time
to
transmit
or
disclose
information
0.25f
2
0.5
32.66b
16.3
0.8
1.6
$
1,139
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
19,413
971
1,941
$
1,354,049
Annualized
cost
of
capitalg
$
139,300
Operation
and
maintenance
(
O&
M)
h
$
133,300
Total
(
capital
recovery
plus
O&
M)
$
272,600
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
64.13,
management
at
$
93.09,
and
clerical
at
$
39.64.

b
Affects
98
respondents
in
the
third
year
of
the
3­
year
term
of
the
ICR
(
98/
3
=
32.66
respondents/
yr).

c
Performance
tests
are
required
for
particulate
matter
by
Method
5
(
or
total
metal
HAP
by
Method
29),
opacity
by
Method
9,
triethylamine
by
Method
18,
and
VOHAP
by
Method
18
or
25A,

depending
on
the
emission
source.
The
performance
test
notification,
test
plan,
test,
and
report
are
required
for
a
total
of
377
control
devices
=
377/
98
=
3.8
per
respondent.
d
This
activity
is
not
applicable
because
it
will
not
occur
in
the
3­
year
term
of
the
ICR.

e
Assumes
15
facilities
request
a
compliance
extension
(
15
facilities/
3
yrs
=
5/
yr).

f
Assumes
15
minutes
to
transmit
recorded
information.

g
Based
on
a
capital
cost
of
$
293,700
for
continuous
parameter
monitoring
systems
and
bag
leak
detectors,
7
percent
interest,
and
20­
year
equipment
life
(
capital
recovery
factor
=
0.142).

Incurred
in
the
third
year
of
the
ICR
term
($
418,000/
3
=
$
139,300/
yr).

h
Operation
and
maintenance
cost
for
continuous
parameter
monitoring
systems
and
bag
leak
detectors.
Incurred
in
the
third
year
of
the
ICR
term
($
400,000/
3
=
$
133,300/
yr).
15
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
STANDARD
Activity
(
A)

Hours
per
occurrence
(
B)

Hours
per
plant
per
year
(
C)
Plants
per
year
(
D)
Technical
person­
hours
per
year
(
D=
BxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
person­
hours
per
year
(
Dx0.1)
(
G)

Cost,
$
a
Initial
performance
test
40
40
5b
200
10
20
$
10,490
Repeat
performance
test­
Retesting
preparation
2
2
0.0c
0
0.0
0.0
$
0
Repeat
performance­
Retesting
40
40
0.0c
0
0
0
$
0
Litigationd
Excess
Emissions
Enforcement
Activitiesd
Report
Review
Notification
of
construction/
reconstruction
N/
A
Notification
of
anticipated
startup
N/
A
Notification
of
actual
startup
N/
A
Notification
of
special
compliance
requirements
N/
A
Notification
of
applicability
2
2
32.66e
65
3
7
$
3,426
Notification
of
initial
performance
test
2
2
32.66e
65
3
7
$
3,426
Notification
of
CEMS
performance
evaluation
NA
0
$
0
CEMS
q/
a
plan
NA
0
$
0
Notification
of
compliance
status
4
4
32.66e
131
7
13
$
6,852
Site­
specific
test
plan
2
2
32.66e
65
3
7
$
3,426
Scrap
selection/
inspection
plan
0
0
0
$
0
Repeat
performance
test
report
2
2
0.0c
0
0
0
$
0
Semi­
annual
compliance
reportd
NESHAP
waiver
application
4
4
0.0f
0
0
0
$
0
Compliance
extension
request
4
4
5f
20
1
2
$
1,049
Emergency
startup,
shutdown,
and
malfunction
reportd
TOTAL
BURDEN
AND
COST
(
SALARY)
547
27
55
$
28,669
Travel
Expenses
for
Tests
Attended
(
1
person
x
5
plants/
yr
x
1
day/
plant
x
$
100
per
diem)
+
($
400/
round
trip
x
5
round
trips/
yr)
=
$
2,500
16
TOTAL
ANNUAL
COST
$
28,669
+
$
2,500
=
$
31,169
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
46.96,
management
at
$
65.28,
and
clerical
at
$
22.26.

b
Assumes
EPA/
State
personnel
will
attend
15
performance
tests
over
3
years
(
15/
3
=
5).

c
Assumes
no
plants
have
to
repeat
their
performance
test
over
the
3­
year
term
of
the
ICR.

d
There
will
be
no
compliance
activities
over
the
3­
year
term
of
the
ICR
because
compliance
is
not
required
until
after
3
years.

e
For
98
foundries
over
3­
year
term
of
the
ICR
(
98/
3
=
32.66).

f
Assumes
15
plants
request
compliance
extensions
(
15/
3
=
5
plants
per
year).
17
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
retention
a
STUDIES
AND
PLANS
Scrap
inspection
plan
63.7700(
c)
N/
A
Life
of
the
affected
source
Operation
and
maintenance
plan
63.7710(
b)
N/
A
Life
of
the
affected
source
Startup,
shutdown,
and
malfunction
plan
63.7720(
c)
63.6(
e)(
3)
Life
of
the
affected
source;
5
years
for
previous
versions
Site­
specific
test
plan
Table
1
63.7(
c)
5
years
CEMS
performance
evaluation
test
plan
and
q/
a
planb
Table
1
63.8(
e)
5
years
NOTIFICATIONS
Applicability
63.7750(
a)
63.9(
b)(
1)­(
3)
5
years
Construction/
reconstruction
63.7750(
a)
63.9(
b)(
4)
5
years
Request
for
extension
of
compliance
63.7750(
a)
63.9(
c)
5
years
Special
compliance
requirements
63.7750(
a)
63.9(
d)
5
years
Performance
test
63.7750(
a)
63.7(
b),
63.9(
e)
5
years
Performance
evaluation
for
VOC
CEMSb
63.7750(
a)
63.8(
e),
63.9(
g)
5
years
Request
for
alternative
monitoring
method
63.7750(
a)
63.8(
f)(
4)
5
years
Compliance
status
63.7750(
a)
63.9(
h)
5
years
REPORTS
Performance
evaluation
for
VOC
CEMSb
63.7741(
f)
63.9(
g)
5
years
Semiannual
compliance
reports
63.7751(
a)­(
b)
N/
A
5
years
Immediate
SSM
reports
63.7751(
c)
63.6(
e)(
3),
63.10(
d)(
5)
5
years
RECORDKEEPING
Notifications
and
reports
63.7752(
a)(
1)
63.10(
b)(
2)(
xiv)
5
years
SSM
plan/
events
63.7752()(
2)
63.6(
e)(
3)(
iii)­(
v)
5
years
Performance
tests
and
performance
evaluations
for
VOC
CEMSb
63.7752(
a)(
3)
63.10(
b)(
2)(
viii)
5
years
CEMSb
63.7752(
b)
63.10(
b)(
2)(
vi)­(
xi)
63.6(
h)(
7)(
i)­(
ii)
63.8(
d)(
3)
63.10(
b)(
2)(
i)­(
ii)
5
years
Records
to
demonstrate
compliance
63.7752(
c)
63.10(
b)(
2)(
vii)
5
years
a
Records
for
the
most
recent
2
years
must
be
retained
onsite
but
records
for
the
remaining
3
years
may
be
kept
offsite.
b
Applies
to
certain
lines
at
new
foundries;
none
are
expected
over
the
3­
year
clearance
period
for
this
ICR.
