1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
Taconite
Iron
Ore
Processing
NESHAP."
This
is
a
revision
of
the
Information
Collection
Request
(
ICR)
submitted
for
the
proposed
rule
and
the
tracking
number
2050.02
has
been
assigned.

(
b)
Short
Characterization/
Abstract.

Potential
respondents
are
owners
or
operators
of
taconite
iron
ore
processing
facilities
that
are
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions.
The
final
rule
applies
to
existing
and
new
ore
crushing
and
handling
operations,
ore
dryers,
indurating
furnaces,
and
finished
pellet
handling
operations
at
these
facilities.
The
particulate
matter
(
PM)

emission
limits
for
each
new
and
existing
affected
source
are
shown
in
the
table
below.
Each
PM
emission
limit
is
expressed
in
grains
of
PM
per
dry
standard
cubic
feet
of
exhaust
gas
(
gr/
dscf).

Affected
sources
have
3
years
from
the
promulgation
date
to
demonstrate
compliance
with
the
emissions
limits.
Operation
limits
apply
for
control
devices
to
ensure
these
emission
limits
are
met.
If
the
source
requires
more
time
to
comply
they
may
submit
a
compliance
extension
request.
2
Affected
Source
Existing
New
Ore
Crushing
and
Handling
0.008
gr/
dscf
0.005
gr/
dscf
Straight
Grate
Indurating
Furnace
Processing
Magnetite
0.01
gr/
dscf
0.006
gr/
dscf
Grate
Kiln
Indurating
Furnace
Processing
Magnetite
0.01
gr/
dscf
0.006
gr/
dscf
Grate
Kiln
Indurating
Furnace
Processing
Hematite
0.03
gr/
dscf
0.018
gr/
dscf
Ore
Dryers
0.052
gr/
dscf
0.025
gr/
dscf
Finished
Pellet
Handling
0.008
gr/
dscf
0.005
gr/
dscf
Affected
sources
are
required
to
conduct
an
initial
performance
test
no
later
than
180
days
after
the
compliance
date
to
demonstrate
initial
compliance
with
each
emission
limit
and
establish
operating
limits
for
control
devices.
For
ore
crushing
and
handling
units
and
finished
pellet
handling
units,
the
rule
allows
initial
testing
to
be
conducted
on
representative
emission
units
rather
than
on
each
emission
unit.
For
ore
dryers
and
indurating
furnaces,
the
rule
requires
that
performance
tests
be
conducted
on
all
corresponding
stacks.
The
facility
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
days
prior
to
each
test.
It
was
assumed
that
all
initial
performance
tests
will
be
conducted
in
the
first
three
years
after
promulgation.
Therefore,
the
burden
for
conducting
initial
performance
tests
is
reflected
in
this
ICR.

Affected
sources
must
conduct
performance
tests
on
all
stacks
from
indurating
furnaces
no
less
than
twice
during
a
3
permit
term
to
demonstrate
continuous
compliance.
Affected
sources
must
conduct
performance
tests
on
ore
crushing
and
handling
operations
and
finished
pellet
handling
operations
at
a
frequency
determined
by
the
permitting
authority.
Since
subsequent
performance
testing
would
be
conducted
beyond
the
3­

year
period
covered
by
this
ICR,
the
burden
for
subsequent
performance
testing
is
not
included
in
this
ICR.

Sources
must
monitor
operating
parameters
for
control
devices
using
continuous
parameter
monitoring
systems
(
CPMS),
bag
leak
detectors,
or
continuous
opacity
monitoring
systems
(
COMS).

Facilities
that
use
CPMS
or
baghouse
leak
detectors
must
submit
a
site­
specific
monitoring
plan.
Facilities
may
submit
a
petition
for
approval
to
monitor
alternative
operating
parameters.

Inspection
and
maintenance
requirements
are
specified
for
each
type
of
monitoring
system.

Consistent
with
the
NESHAP
General
Provisions,
all
respondents
are
required
to
prepare
and
operate
by
an
operation
and
maintenance
plan
and
a
startup,
shutdown,
and
malfunction
plan.
Each
source
must
also
prepare
and
operate
by
a
fugitive
dust
emissions
control
plan.
Sources
must
submit
a
testing
plan
if
they
intend
to
conduct
initial
performance
testing
on
representative
emission
units
or
if
they
do
not
have
a
title
V
permit.
Respondents
must
submit
a
one­
time
initial
notification
report
as
required
by
the
NESHAP
General
Provisions.

The
following
reports
are
required
by
the
final
rule
but
are
4
not
included
in
the
burden
for
this
ICR
because
their
due
dates
are
beyond
the
period
covered
by
this
ICR.
Semiannual
compliance
reports
are
required
and
must
explain
any
deviations
that
occurred
during
the
reporting
period.
An
immediate
report
is
required
if
actions
taken
in
response
to
the
startup,
shutdown,

or
malfunction
are
not
consistent
with
the
written
startup,

shutdown,
and
malfunction
plan.
A
report
must
be
submitted
after
the
third
consecutive
unsuccessful
attempt
at
corrective
action
for
operating
parameters.
A
notification
must
be
submitted
to
request
approval
to
conduct
a
new
performance
test
to
revise
an
operating
limit.
A
notification
of
compliance
status
is
due
following
the
initial
compliance
demonstration.

Respondents
must
maintain
records
of
specific
information
to
ensure
that
the
emission
limitations
and
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
U.
S.
Environmental
Protection
Agency
(
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
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
5
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)
Practical
Utility/
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
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
sources,

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
there
are
no
similar
information
requests
being
6
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
final
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
final
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
final
rule
was
developed
in
consultation
with
State
and
local
agencies,
EPA
regional
office
experts,
and
individual
taconite
iron
ore
processing
plants.

(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,

EPA
would
not
be
reasonably
assured
that
a
source
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).
7
(
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/
SIC
Codes.

A
total
of
8
taconite
iron
ore
processing
facilities
in
2
states
exist.
We
believe
all
of
these
facilities
are
major
sources
that
would
be
subject
to
the
rule
requirements.
The
SIC
code
for
the
respondents
is
1011;
the
NAIC
code
is
21221.

(
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
Tables
1
through
3
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
Tables
4
through
6
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
as
a
firm
having
no
more
than
500
employees.
None
of
the
8
taconite
iron
ore
processing
facilities
are
small
entities.
The
final
rule
provides
a
maximum
degree
of
operational
flexibility
and
the
ICR
requirements
are
the
minimum
necessary
to
demonstrate
compliance.

Affected
sources
have
3
years
from
the
promulgation
date
to
demonstrate
compliance
with
the
emission
limits.

(
d)
Collection
Schedule.

Information
contained
in
the
one­
time
only
reports
will
be
8
entered
into
the
Compliance
Data
System
operated
and
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
action
of
the
respondents.

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

The
information
burden
estimates
for
reporting
and
recordkeeping
for
the
first
three
years
after
promulgation
are
presented
in
Tables
1
through
3.
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
Tables
1
through
3.

(
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
civilian
workers
were
taken
from
the
2002
Employer
Costs
for
Employee
Compensation
(
http://
stats.
bls.
gov/
ncs/
home.
htm).
Wages
for
civilian
workers
(
white­
collar
occupations)
are
used
as
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
29.42/
hour
for
technical,
$
42.56/
hour
for
managerial,
and
$
18.74/
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
hourly
wage
rates
used
to
represent
respondent
labor
costs
are:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.
9
Table
1.
Respondent
Burden
and
Cost
of
Reporting
For
the
First
Year
After
the
Promulgation
Date
Burden
Item
Personhours
per
occurrence
(
A)
Occurrences
per
Respondent
(
B)
Personhours
per
respondent
(
C)=(
AxB)
Respondents
(
D)
Technical
personhours
(
E)=(
CxD)
Management
person­
hours
(
F)=(
E
x0.05)
Clerical
person­
hours
(
G)=(
E
x0.1)
Cost
$
Yr
1
(
H)
a
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
2
1
2
8
16
0.8
2
1,123
B.
Required
Activities
­
Perf.
Testing
­
Facility
Laborb,
c
40
1
40
8
320
16.0
32
22,460
­
Perf.
Testing
­
Contractor
Costsb,
c
­
­
­
­
­
­
­
333,000
­
SSM
Plan
40
1
40
0
­
­
­
­

C.
Create
Information
See
4B
D.
Gather
Existing
Information
See
4B
E.
Write
Report
­
Initial
Notification
2
1
2
8
16
0.8
1.6
1,123
­
Compliance
Extension
Request
2
1
2
0
­
­
­
­

­
Site­
specific
Test
Planb
40
1
40
2.7
107
5.3
10.7
7,487
­
Operation
and
Maintenance
Plan
40
1
40
0
­
­
­
­

­
Fugitive
Dust
Emis.
Control
Plan
20
1
20
0
­
­
­
­

­
Site­
specific
Monitoring
Plan
80
1
80
0
­
­
­
­

­
Petition
for
Alt.
Monitoring
Reqs.
40
1
40
2
80
4.0
8.0
5,615
­
Notification
of
Performance
Test
4
3
12
8
96
4.8
9.6
6,738
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3A
B.
Plan
Activitiesb
3
1
3
2.7
8
0.4
0.8
561
C.
Develop
Record
Systemb
16
1
16
2.7
43
2.1
4.3
2,995
D.
Time
to
Enter
Information
­
­
­
­
­
­
­
­

E.
Time
to
Train
Personnelb
3
1
3
2.7
8
0.4
1
561
F.
Time
to
Transmit
or
Disclose
Informationb
1
2
2
2.7
5
0.3
1
374
F.
Time
for
Audits
N/
A
TOTAL
BURDEN
AND
COST
699
34.9
70
382,037
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Assumes
that
1/
3
of
all
sources
will
send
in
a
test
plan,
conduct
performance
testing,
and
conduct
recordkeeping
procedures
in
each
of
the
3
years.

c
Performance
testing
includes
40
hours
per
facility
per
year
to
set
up
testing
contractor,
oversee
tests,
and
review
test
reports.
Testing
contractor
costs
are
based
on
the
following:
(
53
ind.
furnace
and
ore
dryer
Method
5
PM
tests
@
$
8,000/
test)+(
115
OCH
and
PH
Method
5
PM
tests
@
$
5,000/
test)
=
$
999,000.

$
999,000/
3
years
=
$
333,000/
year
10
Table
2.
Respondent
Burden
and
Cost
of
Reporting
For
the
Second
Year
After
the
Promulgation
Date
Burden
Item
Personhours
per
occurrence
(
A)
Occurrences
per
Respondent
(
B)
Personhours
per
respondent
(
C)=(
AxB)
Respondents
(
D)
Technical
personhours
(
E)=(
CxD)
Management
person­
hours
(
F)=(
E
x0.05)
Clerical
person­
hours
(
G)=(
E
x0.1)
Cost
$
Yr
2
(
H)
a
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
2
1
2
0
­
­
­
­

B.
Required
Activities
­
Perf.
Testing
­
Facility
Laborb,
c
40
1
40
8
320
16.0
32
22,460
­
Perf.
Testing
­
Contractor
Costsb,
c
­
­
­
­
­
­
­
333,000
­
SSM
Plan
40
1
40
0
­
­
­
­

C.
Create
Information
See
4B
D.
Gather
Existing
Information
See
4B
E.
Write
Report
­
Initial
Notification
2
1
2
0
­
­
­
­

­
Compliance
Extension
Request
2
1
2
3
6
0.3
0.6
421
­
Site­
specific
Test
Planb
40
1
40
2.7
107
5.3
10.7
7,487
­
Operation
and
Maintenance
Plan
40
1
40
0
­
­
­
­

­
Fugitive
Dust
Emis.
Control
Plan
20
1
20
0
­
­
­
­

­
Site­
specific
Monitoring
Plan
80
1
80
0
­
­
­
­

­
Petition
for
Alt.
Monitoring
Reqs.
40
1
40
0
­
­
­
­

­
Notification
of
Performance
Test
4
3
12
8
96
4.8
9.6
6,738
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3A
B.
Plan
Activitiesb
3
1
3
2.7
8
0.4
0.8
561
C.
Develop
Record
Systemb
16
1
16
2.7
43
2.1
4.3
2,995
D.
Time
to
Enter
Information
­
­
­
­
­
­
­
­

E.
Time
to
Train
Personnelb
3
1
3
2.7
8
0.4
1
561
F.
Time
to
Transmit
or
Disclose
Informationb
1
2
2
2.7
5
0.3
1
374
F.
Time
for
Audits
N/
A
TOTAL
BURDEN
AND
COST
593
29.6
59
374,597
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Assumes
that
1/
3
of
all
sources
will
send
in
a
test
plan,
conduct
performance
testing,
and
conduct
recordkeeping
procedures
in
each
of
the
3
years.

c
Performance
testing
includes
40
hours
per
facility
per
year
to
set
up
testing
contractor,
oversee
tests,
and
review
test
reports.
Testing
contractor
costs
are
based
on
the
following:
(
53
ind.
furnace
and
ore
dryer
Method
5
PM
tests
@
$
8,000/
test)+(
115
OCH
and
PH
Method
5
PM
tests
@
$
5,000/
test)
=
$
999,000.

$
999,000/
3
years
=
$
333,000/
year
11
Table
3.
Respondent
Burden
and
Cost
of
Reporting
For
the
Third
Year
After
the
Promulgation
Date
Burden
Item
Personhours
per
occurrence
(
A)
Occurrences
per
Respondent
(
B)
Personhours
per
respondent
(
C)=(
AxB)
Respondents
(
D)
Technical
personhours
(
E)=(
CxD)
Management
person­
hours
(
F)=(
E
x0.05)
Clerical
person­
hours
(
G)=(
E
x0.1)
Cost
$
Yr
3
(
H)
a
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
2
1
2
0
­
­
­
­

B.
Required
Activities
­
Perf.
Testing
­
Facility
Laborb,
c
40
1
40
8
320
16.0
32
22,460
­
Perf.
Testing
­
Contractor
Costsb,
c
­
­
­
­
­
­
­
333,000
­
SSM
Plan
40
1
40
8
320
16.0
32
22,460
C.
Create
Information
See
4B
D.
Gather
Existing
Information
See
4B
E.
Write
Report
­
Initial
Notification
2
1
2
0
­
­
­
­

­
Compliance
Extension
Request
2
1
2
0
­
­
­
­

­
Site­
specific
Test
Planb
40
1
40
2.7
107
5.3
10.7
7,487
­
Operation
and
Maintenance
Plan
40
1
40
8
320
16.0
32
22,460
­
Fugitive
Dust
Emis.
Control
Plan
20
1
20
8
160
8.0
16.0
11,230
­
Site­
specific
Monitoring
Plan
80
1
80
8
640
32.0
64.0
44,919
­
Petition
for
Alt.
Monitoring
Reqs.
40
1
40
0
­
­
­
­

­
Notification
of
Performance
Test
4
3
12
8
96
4.8
9.6
6,738
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3A
B.
Plan
Activitiesb
3
1
3
2.7
8
0.4
0.8
561
C.
Develop
Record
Systemb
16
1
16
2.7
43
2.1
4.3
2,995
D.
Time
to
Enter
Information
­
­
­
­
­
­
­
­

E.
Time
to
Train
Personnelb
3
1
3
2.7
8
0.4
1
561
F.
Time
to
Transmit
or
Disclose
Informationb
1
2
2
2.7
5
0.3
1
374
F.
Time
for
Audits
N/
A
Total
Labor
BURDEN
AND
COST
2,027
101.3
203
475,244
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Assumes
that
1/
3
of
all
sources
will
send
in
a
test
plan,
conduct
performance
testing,
and
conduct
recordkeeping
procedures
in
each
of
the
3
years.

c
Performance
testing
includes
40
hours
per
facility
per
year
to
set
up
testing
contractor,
oversee
tests,
and
review
test
reports.
Testing
contractor
costs
are
based
on
the
following:
(
53
ind.
furnace
and
ore
dryer
Method
5
PM
tests
@
$
8,000/
test)+(
115
OCH
and
PH
Method
5
PM
tests
@
$
5,000/
test)
=
$
999,000.

$
999,000/
3
years
=
$
333,000/
year
12
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)

Costs.
In
order
to
record
the
information
required
by
the
rule,

sources
must
install
monitoring
devices.
Each
baghouse
must
monitor
the
pressure
drop
across
each
cell
and
have
a
bag
leak
detection
system.
Each
dynamic
wet
scrubber
must
monitor
the
daily
average
scrubber
water
flow
rate
and
either
the
daily
average
fan
amperage
or
the
daily
average
pressure
drop.
All
other
wet
scrubbers
must
monitor
the
daily
average
pressure
drop
and
daily
average
water
flow.
Each
dry
electrostatic
precipitator
must
either
have
a
COMS
or
monitor
the
daily
average
secondary
voltage
and
the
daily
average
secondary
current.
The
burden
for
all
dry
electrostatic
precipitators
was
based
on
the
assumption
that
COMS
will
be
used.
The
costs
of
each
of
these
monitoring
systems
were
estimated
based
on
previous
EPA
rule­
making
experience
and
vendor
quotes.
These
costs
were
multiplied
by
the
number
of
systems
expected
to
be
installed
to
determine
the
total
capital
cost
of
monitoring.
The
annualized
capital
cost
for
monitoring
devices
is
$
392,751.
This
is
based
on
an
equipment
lifetime
of
25
years,
an
interest
rate
of
7
percent,
yielding
a
capital
recovery
factor
of
0.086.

Operating
and
Maintenance
costs
were
estimated
on
an
annual
basis
for
each
monitoring
device
and
multiplied
by
the
estimated
number
of
systems
to
be
installed.
The
average
annual
operating
and
maintenance
costs
during
the
first
3
years
is
$
117,345.

(
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
13
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
Tables
4
through
6.

Labor
rates
and
associated
costs
for
the
Agency
are
assumed
to
be
the
same
as
the
respondent's
hourly
rates.
The
Agency
labor
rates
are
estimated
as
follows:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.
14
Table
4.
Burden
and
Cost
for
the
Federal
Government
for
the
First
Year
After
the
Promulgation
Date
Activity
EPA
hours
per
occurrence
(
A)
Occurrences
per
Respondent
(
B)
Personhours
per
Respondent
(
C)
=
(
AxB)
Respondents
(
D)
Technical
person­
hours
(
E)
=
(
CxD)
Management
person­
hours
(
F)
=
(
E
x0.05)
Clerical
person­
hours
(
G)
=
(
E
x0.1)
Cost
$

Year
1
(
H)
a
1.
Initial
Performance
Testb,
c
8
7
56
8
448
22.4
44.8
31,443
2.
Repeat
Performance
Test
N/
A
­
­
­
­
­
­
­

3.
Litigation
N/
A
­
­
­
­
­
­
­

4.
Excess
Emissions
Enforcement
Activities
N/
A
­
­
­
­
­
­
­

5.
Report
Review
A.
Initial
Notification
2
1
2
8
16
0.8
1.6
1,123
B.
Notification
Initial
Performance
Test
2
3
6
8
48
2.4
4.8
3,369
C.
Fugitive
Dust
Emissions
Control
Plan
10
1
10
0
­
­
­
­

D.
Performance
Test
Report
N/
A
­
­
­
­
­
­
­

E.
Compliance
Extension
Request
2
1
2
0
­
­
­
­

F.
Site­
specific
Test
Planb
10
1
10
2.7
27
1.4
2.7
1,895
G.
Operation
and
Maintenance
Plan
10
1
10
0
­
­
­
­

H.
Site­
specific
Monitoring
Plan
10
1
10
0
­
­
­
­

I.
Petition
for
Alternative
Monitoring
Requirements
5
1
5
2
10
0.5
1.0
702
J.
SSM
Plan
10
1
10
0
­
­
­
­

TOTAL
BURDEN
AND
COST
(
SALARY)
549
27.5
54.9
38,532
Travel
Expenses
for
Performance
Testingb.
c
(
1
person
x
8
plant/
yr
x
7
day/
plant
x
$
100
per
diem)
5,600
Total
Annual
Cost
44,132
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Assumes
that
1/
3
of
all
sources
will
send
in
a
test
plan
and
conduct
performance
testing
in
each
of
the
three
years.

C
53
indurating
furnace
and
ore
dryer
Method
5
PM
tests
+
115
OCH
and
PH
Method
5
PM
tests
=
168
Method
5
PM
tests.

168
tests/
3
years
=
56
Method
5
PM
tests/
year.
(
56
Method
5
PM
tests/
year)/(
8
plants)
=
7
Method
5
PM
tests
per
year
per
plant.
15
Table
5.
Burden
and
Cost
for
the
Federal
Government
for
the
Second
Year
After
the
Promulgation
Date
Activity
EPA
hours
per
occurrence
(
A)
Occurrences
per
Respondent
(
B)
Personhours
per
Respondent
(
C)
=
(
AxB)
Respondents
(
D)
Technical
person­
hours
(
E)
=
(
CxD)
Management
person­
hours
(
F)
=
(
E
x0.05)
Clerical
person­
hours
(
G)
=
(
E
x0.1)
Cost
$

Year
2
(
H)
a
1.
Initial
Performance
Testb,
c
8
7
56
8
448
22.4
44.8
31,443
2.
Repeat
Performance
Test
N/
A
­
­
­
­
­
­
­

3.
Litigation
N/
A
­
­
­
­
­
­
­

4.
Excess
Emissions
Enforcement
Activities
N/
A
­
­
­
­
­
­
­

5.
Report
Review
A.
Initial
Notification
2
1
2
0
­
­
­
­

B.
Notification
Initial
Performance
Test
2
3
6
8
48
2.4
4.8
3,369
C.
Fugitive
Dust
Emissions
Control
Plan
10
1
10
0
­
­
­
­

D.
Performance
Test
Report
N/
A
­
­
­
­
­
­
­

E.
Compliance
Extension
Request
2
1
2
2
4
0.2
0.4
281
F.
Site­
specific
Test
Planb
10
1
10
2.7
27
1.4
2.7
1,895
G.
Operation
and
Maintenance
Plan
10
1
10
0
­
­
­
­

H.
Site­
specific
Monitoring
Plan
10
1
10
0
­
­
­
­

I.
Petition
for
Alternative
Monitoring
Requirements
5
1
5
0
­
­
­
­

J.
SSM
Plan
10
1
10
0
­
­
­
­

TOTAL
BURDEN
AND
COST
(
SALARY)
527
26.4
52.7
36,988
Travel
Expenses
for
Performance
Testingb.
c
(
1
person
x
8
plant/
yr
x
7
day/
plant
x
$
100
per
diem)
5,600
Total
Annual
Cost
42,588
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Assumes
that
1/
3
of
all
sources
will
send
in
a
test
plan
and
conduct
performance
testing
in
each
of
the
three
years.

C
53
indurating
furnace
and
ore
dryer
Method
5
PM
tests
+
115
OCH
and
PH
Method
5
PM
tests
=
168
Method
5
PM
tests.

168
tests/
3
years
=
56
Method
5
PM
tests/
year.
(
56
Method
5
PM
tests/
year)/(
8
plants)
=
7
Method
5
PM
tests
per
year
per
plant.
16
Table
6.
Burden
and
Cost
for
the
Federal
Government
for
the
Third
Year
After
the
Promulgation
Date
Activity
EPA
hours
per
occurrence
(
A)
Occurrences
per
Respondent
(
B)
Personhours
per
Respondent
(
C)
=
(
AxB)
Respondents
(
D)
Technical
person­
hours
(
E)
=
(
CxD)
Management
person­
hours
(
F)
=
(
E
x0.05)
Clerical
person­
hours
(
G)
=
(
E
x0.1)
Cost
$

Year
3
(
H)
a
1.
Initial
Performance
Testb,
c
8
7
56
8
448
22.4
44.8
31,443
2.
Repeat
Performance
Test
N/
A
­
­
­
­
­
­
­

3.
Litigation
N/
A
­
­
­
­
­
­
­

4.
Excess
Emissions
Enforcement
Activities
N/
A
­
­
­
­
­
­
­

5.
Report
Review
A.
Initial
Notification
2
1
2
0
­
­
­
­

B.
Notification
Initial
Performance
Test
2
3
6
8
48
2.4
4.8
3,369
C.
Fugitive
Dust
Emissions
Control
Plan
10
1
10
8
80
4.0
8.0
5,615
D.
Performance
Test
Report
N/
A
­
­
­
­
­
­
­

E.
Compliance
Extension
Request
2
1
2
0
­
­
­
­

F.
Site­
specific
Test
Planb
10
1
10
2.7
27
1.4
2.7
1,895
G.
Operation
and
Maintenance
Plan
10
1
10
8
80
4.0
8.0
5,615
H.
Site­
specific
Monitoring
Plan
10
1
10
8
80
4.0
8.0
5,615
I.
Petition
for
Alternative
Monitoring
Requirements
5
1
5
0
­
­
­
­

J.
SSM
Plan
10
1
10
8
80
4.0
8.0
5,615
TOTAL
BURDEN
AND
COST
(
SALARY)
843
42.2
84.3
59,167
Travel
Expenses
for
Performance
Testingb.
c
(
1
person
x
8
plant/
yr
x
7
day/
plant
x
$
100
per
diem)
5,600
Total
Annual
Cost
64,767
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Assumes
that
1/
3
of
all
sources
will
send
in
a
test
plan
and
conduct
performance
testing
in
each
of
the
three
years.

C
53
indurating
furnace
and
ore
dryer
Method
5
PM
tests
+
115
OCH
and
PH
Method
5
PM
tests
=
168
Method
5
PM
tests.

168
tests/
3
years
=
56
Method
5
PM
tests/
year.
(
56
Method
5
PM
tests/
year)/(
8
plants)
=
7
Method
5
PM
tests
per
year
per
plant.
17
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.

The
EPA
estimates
that
all
8
facilities
will
install
the
required
monitoring
equipment,
conduct
initial
performance
tests,

conduct
recordkeeping
activities
and
prepare
and
submit
the
following
reports/
notifications
during
the
3­
year
period
for
this
ICR:
a
startup,
shutdown,
and
malfunction
plan;
a
fugitive
dust
emissions
control
plan;
a
testing
plan;
an
operations
and
maintenance
plan;
a
site­
specific
monitoring
plan;
performance
test
notifications;
and
the
initial
notification.
The
EPA
estimates
that
a
portion
of
the
facilities
will
prepare
and
submit
a
compliance
extension
request
and
a
petition
for
alternative
monitoring
requirements.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
tables.
The
total
labor
burden
for
the
first
3
years,

provided
in
Table
7,
is
3,816
hours
with
an
estimated
cost
of
$
1,231,878
including
technical,
management
and
clerical
hours.

Annual
average
labor
cost
is
1,272
hours
with
an
estimated
annual
cost
of
$
410,626.
Adding
three
years
of
annualized
capital
costs
and
O&
M
costs
yields
a
total
respondent
burden
for
recordkeeping
and
reporting
for
the
first
3
years
of
$
920,722.
18
Table
7.
Summary
of
Respondent
Burden
and
Cost
of
Reporting
Year
Respondents
Technical
personhours
Management
personhours
Clerical
personhours
Total
Hours
Total
Cost
$
a
First
Year
8
699
35
70
803
382,037
Second
Year
8
593
30
59
682
374,597
Third
Year
8
2,027
101
203
2,331
475,244
Three
Year
Labor
Total
3,318
166
332
3,816
1,231,878
Annual
Average
Labor
Cost
1,106
55
111
1,272
410,626
Annual
Average
Capital
Cost
392,751
Annual
Average
O&
M
Cost
117,345
TOTAL
ANNUAL
AVERAGE
COST
920,722
a
Costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

b
Capital
costs
are
based
on
an
estimated
209
scrubbers,
52
baghouses
and
28
ESPs.
The
total
capital
cost
is
estimated
to
be
$
4,576,955.
Assuming
a
lifetime
of
25
years
and
7%
interest
(
i.
e.,
a
capital
recovery
factor
of
0.086)
yields
the
annualized
capital
cost.

c
O&
M
costs
are
based
on
209
scrubbers,
52
baghouses
and
28
ESPs.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
7,
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
respondent
recordkeeping
and
reporting
labor
burden,

provided
in
Table
7,
is
1,272
hours
with
an
estimated
cost
of
$
410,626
per
year
including
technical,
management,
and
clerical
hours.
The
annualized
capital
cost
for
monitoring
devices
is
$
392,751.
Operation
and
Maintenance
cost
(
excluding
any
labor
hours
given
in
the
labor
burden
estimate)
are
estimated
at
19
$
117,345
per
year
average
over
the
3
year
ICR
period.
The
total
annual
average
burden
is
$
920,722.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
8,
are
calculated
as
in
the
respondent
table,
by
adding
person­
hours
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
average
hours
are
736
hours.
The
total
annual
cost
is
$
50,496.

(
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.

Table
8.
Summary
of
Annual
Burden
and
cost
for
the
Federal
Government
Year
Respondents
Technical
personhours
Management
personhours
Clerical
personhours
Total
Hours
Total
Cost
$
a
First
Year
8
549
27
55
631
44,132
Second
Year
8
527
26
53
606
42,588
Third
Year
8
843
42
84
969
64,767
Three
Year
Total
1,919
96
192
2,207
151,487
ANNUAL
AVERAGE
640
32
64
736
50,496
a
Labor
costs
are
based
on
the
following
2002
hourly
rates:
technical
at
$
61.78,
management
at
$
89.38,
and
clerical
at
$
39.35.

(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
159
hours
20
per
response
(
1,272
hours/
8
facilities).
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
No.
OAR­
2002­
0039,
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
B102,
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/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
21
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.

(
OAR­
2002­
0039).
22
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
23
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
40
CFR
part
63
General
Provisions
citation
Record
retention1
PERFORMANCE
TESTING
Initial
performance
test
63.9620(
a)

through
(
g)
N/
A
N/
A
Subsequent
performance
tests
63.9630
N/
A
N/
A
NOTIFICATIONS
Notifications
(
initial,

special
compliance
requirements,

performance
testing,

CMS,
and
compliance
status)
and
requests
(
alternative
monitoring
methods
and
extension
of
compliance)
63.9640,

63.9590(
c)
63.7(
b)
and
(
c),

63.8(
f)(
4),

63.9(
b)­

(
h),
63.90
5
years
Initial
notification
due
date
­
existing
sources
63.9640(
b)
63.9(
b)(
2)
5
years
Initial
notification
due
date
­
new
sources
63.9640(
c)
63.9(
b)(
3)
5
years
Notification
of
intent
to
conduct
a
performance
test
due
date
63.9640(
d)
63.7(
b)(
1)
5
years
Requirement
Regulation
citation
40
CFR
part
63
General
Provisions
citation
Record
retention1
24
Initial
notification
of
compliance
status
due
date
63.9640(
e)
63.9(
h)(
2)

(
ii)
5
years
Notification
of
request
to
conduct
a
performance
test
to
revise
the
operating
limit
63.9622(
f)
N/
A
5
years
PLANS
AND
REPORTS
Semiannual
compliance
report
due
date
63.9641(
a)
63.8(
c)(
7)­

(
8),
63.10
(
d)(
5)(
i)
5
years
Semiannual
compliance
report
contents
63.9641(
b)
63.8(
c)(
7)­

(
8),
63.10
(
d)(
5)(
i)
5
years
Immediate
startup,

shutdown,
and
malfunction
report2
63.9641(
c)
63.10(
d)(
5)

(
ii)
5
years
Part
70
monitoring
report
63.9641(
d)
N/
A
Life
of
affected
source
Fugitive
dust
emissions
control
plan
63.9591
N/
A
Life
of
affected
source
Operation
and
maintenance
plan
63.9600(
b)
N/
A
Life
of
affected
source
Requirement
Regulation
citation
40
CFR
part
63
General
Provisions
citation
Record
retention1
25
Testing
Plan
for
testing
representative
units
63.9620(
e)

and
(
g)
N/
A
Life
of
affected
source
Testing
Plan
for
plants
without
a
Title
V
permit
63.9630(
a)

through
(
e)
N/
A
Life
of
affected
source
Site­
specific
monitoring
plan
for
controls
not
listed
63.9631(
f)
N/
A
Life
of
affected
source
Site­
specific
monitoring
plan
for
CPMS
63.9632(
b)
N/
A
Life
of
affected
source
Site­
specific
monitoring
plan
for
baghouses
63.9632(
a)(
4)
N/
A
Life
of
affected
source
Startup,
shutdown,
and
malfunction
plan
63.9610(
c)
63.6(
e)(
3)
Life
of
affected
source
RECORDKEEPING
Notifications
and
reports
63.9642(
a)(
1)
63.10(
b)(
2)

(
xiv)
5
years
Startup,
shutdown,
and
malfunction
plan/
events
63.9642(
a)(
2)
63.6(
e)(
3)

(
iii)­(
v)
5
years
Performance
tests
63.9642(
a)(
3)
63.10(
b)(
2)

(
viii)
5
years
Requirement
Regulation
citation
40
CFR
part
63
General
Provisions
citation
Record
retention1
26
Records
for
COMS
63.9642(
b)
63.6(
h)(
7)

(
i)
and
(
ii),

63.8(
d)(
3),

63.10(
b)(
2)

(
vi)
5
years
Records
required
to
demonstrate
continuous
compliance
63.9642(
c)
63.10(
b)(
2)

(
vii)
5
years
N/
A
­
Not
applicable
1
All
records
must
be
retained
for
at
least
5
years.
The
records
for
the
most
recent
2
years
must
be
retained
onsite
but
records
for
the
remaining
3
years
may
be
kept
offsite
but
available
for
review.

2
Includes
reports
of
startups,
shutdowns,
or
malfunctions
where
procedures
in
startup,
shutdown,
and
malfunction
plan
were
not
followed.
