1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
Amendments
to
NSPS
for
Electric
Arc
Furnaces
at
Steel
Plants."
This
is
a
revision
to
the
existing
approved
information
collection
request
(
OMB
control
number
2060­
0038),
currently
under
review
for
renewal
(
ICR
no.
1060.12).
The
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
request
is
1060.13.

(
b)
Short
Characterization/
Abstract.

Potential
respondents
are
owners
or
operators
of
electric
arc
furnaces
(
EAF)
at
steel
plants.
The
EPA
is
amending
the
new
source
performance
standards
(
NSPS)
for
EAF
constructed
after
October
21,
1974,
and
on
or
before
August
17,
1983
(
40
CFR
60
subpart
AA)
and
the
NSPS
for
EAF
constructed
after
August
17,

1983
(
40
CFR
60
subpart
AAa).
The
amendments
allow
bag
leak
detection
coupled
with
daily
shop
opacity
observations
and
corrective
action
procedures
as
an
alternative
to
continuous
opacity
monitoring
systems.

The
amendments
are
being
made
in
response
to
a
petition
to
reopen
the
NSPS
received
from
the
American
Iron
and
Steel
Institute
(
AISI),
the
Specialty
Steel
Industry
of
North
America(
SSINA),
and
the
Steel
Manufacturers
Association
(
SMA),

who
will
be
jointly
referred
to
as
"
the
Industry."
The
changes
2
add
alternative
monitoring
options
that
provide
owners
and
operators
more
flexibility
in
monitoring
compliance
with
the
rules
while
not
reducing
environmental
benefit.
No
changes
are
made
to
the
emissions
control
requirements.

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

The
EPA
is
charged
under
section
111
of
the
Clean
Air
Act,

as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
nonair
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
section
111(
a)(
l)].

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.
In
addition,
section
114(
a)
states
that:

.
.
.
.
the
Administrator
may
require
any
owner
or
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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
Keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
3
(
G)
provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
particulate
matter
emissions
from
steel
plants
subject
to
NSPS
Subparts
AA
and
AAa
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,

NSPS
were
promulgated
for
this
source
category.

The
control
of
emissions
of
particulate
matter
from
steel
plants
subject
to
NSPS
Subparts
AA
ans
AAa
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulate
matter
from
steel
plants
are
the
result
of
operation
of
the
EAF,
argon­
oxygen
decarburization
vessels,
and
dust
handling
systems.
These
standards
rely
on
the
capture
and
reduction
of
particulate
matter
emissions
by
hoods
and
fabric
filters.

In
order
to
ensure
compliance
with
these
standards,
adequate
recordkeeping
is
necessary.
In
the
absence
of
such
information
enforcement
personnel
would
be
unable
to
determine
whether
the
standards
are
being
met
on
a
continuous
basis,
as
required
by
the
Clean
Air
Act.

(
b)
Practical
Utility/
Users
of
the
Data.

The
additional
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
ensure
that
the
standards
are
being
properly
applied;
and
(
2)
ensure
that
emission
control
devices
4
are
being
properly
operated
and
maintained
to
reduce
emissions
from
furnaces.

The
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
facilities
that
may
not
be
in
compliance
with
the
standard.
Based
on
reported
information,
the
EPA
can
decide
which
facilities
should
be
subject
to
inspection
or
enforcement
action.
The
records
that
facilities
maintain
indicate
to
the
EPA
whether
plant
personnel
are
employing
adequate
standard
operational
procedures
and
whether
they
are
operating
and
maintaining
control
equipment
properly.

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

A
computer
search
of
the
Federal
Information
Locator
System
indicated
that
there
were
no
similar
information
requests
being
carried
out
by
the
Federal
government.
A
similar
search
of
EPA's
ongoing
ICR
revealed
no
duplication
of
information­
gathering
efforts.
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards
(
e.
g.,
records
of
annual
lead
performance
tests).
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
in
lieu
of,
or
as
a
part
of,
the
report
required
by
the
standards.

(
b)
Public
Notice
required
prior
to
ICR
Submission
to
OMB.

This
section
is
not
applicable
because
this
is
a
rulerelated
ICR.
5
(
c)
Consultations.

The
EPA
is
amending
the
NSPS
for
EAF
based
on
a
petition
to
reopen
the
NSPS
received
from
the
Industry.
The
Industry
argues
that
COMS
are
not
capable
of
accurately
monitoring
opacity
emissions
from
an
EAF
shop
at
the
three
percent
excess
emissions
threshold
level
and
that
the
EAF
NSPS
should
be
amended
to
address
the
"
technological
shortcomings"
associated
with
COMS,

and
suggested
a
number
of
alternative
monitoring
options,

including
the
one
in
the
final
amendments.
The
non­
EPA
persons
consulted
during
development
of
the
amendments
are
identified
in
Table
1.

TABLE
1.
PERSONS
CONSULTED
ON
THE
INFORMATION
COLLECTION
ACTIVITIES
IN
THE
AMENDMENTS
Contact
Organization
Telephone
Number
C.
M
Thompson
on
behalf
of
AISI,
SSINA,
and
SMA
Collier
Shannon
Scott,
PLLC
(
202)
342­
8400
(
d)
Effects
of
Less
Frequent
Collection.

The
NSPS
requires
semi­
annual
reports.
If
the
relevant
information
were
collected
less
frequently,
the
EPA
would
not
be
reasonably
assured
that
a
plant
is
in
compliance
with
the
standards.
In
addition,
the
EPA's
authority
to
take
administrative
action
would
be
significantly
reduced.

(
e)
General
Guidelines.

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

(
f)
Confidentiality.
6
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
steel
electric
arc
furnaces
built
after
October
21,
1974.
Steel
electric
arc
furnaces
are
included
in
NAIC
code
331111.

(
b)
Information
Requested.

(
i)
Data
Items,
Including
Recordkeeping
Requirements.

Attachment
1,
Source
Data
Information
Requirements,
summarizes
the
additional
recordkeeping
and
reporting
requirements
resulting
from
the
amendments.

(
ii)
Respondent
Activities.
Additional
respondent
activities
required
by
the
amendments
for
each
of
the
first
three
years
following
promulgation
are
identified
in
Table
2
and
introduced
in
section
6(
a).
7
5.
The
Information
Collected
 
­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

The
only
activities
that
the
Federal
government
will
be
required
to
perform
are
associated
with
the
review
of
reported
information
and
observation
of
performance
tests.
However,
these
activities
are
already
included
in
the
existing
ICR,
and
no
increase
will
occur
due
to
the
new
alternative
monitoring
requirements.

(
b)
Collection
Methodology
and
Management.

This
is
not
relevant
to
this
information
collection
request.

(
c)
Small
Entity
Flexibility.

Steel
plants
with
electric
arc
furnaces
are
not
small
businesses.

(
d)
Collection
Schedule.

Information
contained
in
the
periodic
reports
submitted
to
the
EPA
will
be
reviewed
for
accuracy
and
completeness
and
then
entered
into
the
National
Compliance
Database
operated
and
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance.
Data
obtained
during
periodic
visits
by
EPA
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.
A
schedule
for
collection
of
information
and
8
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
annual
burden
estimates
for
the
additional
recordkeeping
and
reporting
requirements
are
presented
in
Table
2.
These
estimates
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

The
additional
information
collection
activities
for
the
amendments
are
shown
in
Table
2.
These
activities
will
occur
only
if
the
owner
or
operator
chooses
to
use
the
alternative
monitoring
option.
Respondents
choosing
to
use
the
bag
leak
detection
system
must
prepare
and
follow
a
site­
specific
monitoring
plan,
implement
corrective
action
procedures,
make
once
daily
shop
opacity
observations,
and
keep
records
to
document
compliance.

(
i)
Estimating
Labor
Costs.
This
ICR
uses
a
technical
labor
rate
of
$
61.66
per
hour
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.

Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rate
has
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
This
is
the
9
same
average
hourly
rate
used
in
the
last
renewal
of
the
ICR
(
ICR
No.
1060.12).

(
ii)
Estimating
Capital
and
Operation
and
Maintenance
(
O&
M)

Costs.
If
owners
or
operators
elect
to
use
the
alternative
monitoring
option
they
will
need
to
purchase
and
install
and
maintain
bag
leak
detection
systems.
However,
the
annualized
costs
of
these
systems
will
be
more
than
offset
by
annualized
savings
resulting
from
no
longer
having
to
maintain
and
replace
the
existing
COMS.
As
such,
there
is
no
increase
to
the
estimated
total
capital
costs
and
total
annual
O&
M
costs
for
emission
monitoring.
The
average
annual
costs
for
capital/
start
and
O&
M
for
the
existing
rule
requirements
were
estimated
at
$
289,890.

(
iii)
Capital/
Startup
vs.
O&
M
Costs.
There
is
no
increase
in
capital/
startup
costs
as
a
result
of
the
new
alternative
monitoring
requirements.
The
total
capital/
startup
costs
for
the
existing
rule
requirements
are
$
4,140.
The
total
O&
M
costs
for
the
existing
rule
requirements
are
$
285,750.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
estimated
as
an
incidental
part
of
the
standard
development,
no
Agency
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Publication
and
distribution
of
the
information
are
part
of
the
Aerometric
10
Information
Retrieval
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
a
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and
is
not
attributable
to
this
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
costs
associated
with
the
review
of
reported
information
and
observation
of
performance
tests.
However,
these
costs
are
already
included
in
the
existing
ICR,
and
no
increase
will
occur
due
to
the
new
alternative
monitoring
requirements.

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

The
average
number
of
affected
facilities
(
95.3)
used
in
estimating
burden
for
the
current
ICR
(
ICR
No.
1060.12;
based
on
95
existing
and
1
new
facility
per
year)
were
used
in
estimating
the
burden
for
the
additional
requirements.
The
number
of
potential
respondents
assumes
that
40
percent
of
affected
facilities
(
38.1)
use
COMS
and
that
33
percent
of
facilities
that
currently
operate
COMS
(
12.6)
will
choose
to
implement
the
alternative
monitoring
requirements.
Therefore,
12.6
facilities
are
projected
to
implement
the
alternative
monitoring
requirements.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.
11
(
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,
and
by
summing
down
the
labor
cost
column.
The
net
average
annual
burden
to
industry
over
the
next
three
years
from
these
new
recordkeeping
and
reporting
requirements
is
estimated
at
2,025
person­
hours.
The
increased
average
annual
burden
to
industry
over
the
next
three
years
due
to
the
new
requirements
is
estimated
to
be
$
135,960.

The
annual
average
increase
in
burden
is
175
labor
hours
and
$
10,790
per
source
(
based
on
12.6
sources
implementing
the
alternative
monitoring
requirements).

The
total
annual
hour
burden,
including
existing
rule
requirements,
is
estimated
to
increase
from
58,195
hours
to
60,400,
and
total
annual
labor
costs
increase
from
$
3,588,328
to
$
3,724,288.
The
number
of
total
annual
responses
remains
unchanged
at
192.
The
annual
public
reporting
and
recordkeeping
burden
is
estimated
to
average
315
(
rounded)
hours
per
response
(
60,400
hours
divided
by
192
responses
per
year).
The
total
annual
capital
and
O&
M
costs
remain
unchanged
at
$
289,890.

(
ii)
The
Agency
Tally.
No
change
in
agency
burden
will
occur
due
to
the
alternative
monitoring
requirements
being
added.

(
iii)
Variations
in
the
Annual
Bottom
Line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
e)
Reason
for
Change
in
Burden.
12
The
change
in
estimated
burden
results
from
new
alternative
monitoring
requirements
being
added
in
response
to
a
petition
to
reopen
the
NSPS
received
from
the
Industry.
The
changes
will
not
remove
any
of
the
rule's
requirements,
but
will
add
alternative
monitoring
options
that
will
provide
owners
and
operators
more
flexibility
in
complying
with
the
rules
while
not
reducing
environmental
benefit.
If
an
owner
or
operator
selects
this
option,
they
will
incur
additional
recordkeeping
and
reporting
burden.
This
increase
is
partially
offset
by
a
decrease
in
recordkeeping
and
reporting
burden
since
owners
and
operators
would
no
longer
be
required
to
install
and
operate
a
COMS.

(
g)
Burden
Statement.

The
annual
increase
in
the
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
estimated
at
2,025
person­
hours
and
$
135,960.
The
annual
average
increase
in
burden
is
175
labor
hours
and
$
10,790
per
source
(
based
on
12.6
sources
implementing
the
alternative
monitoring
requirements).
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,
13
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.
14
TABLE
2.
ANNUAL
BURDEN
OF
ADDITIONAL
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
NSPS
SUBPARTS
AA
AND
AAa
Item
(
A)
Hours/
Occurence
(
B)
Occurrences/
Respondent/

Year
(
C=
AxB)
Hours/
Respondent/

Year
(
D)
Respondents/

Yeara
(
E=
CxD)
Hours/

Year
(
F)
Cost/

Yearb
1.
APPLICATIONS
Not
applicable
2.
SURVEYS
AND
STUDIES
Not
applicable
3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
B.
Required
Activities
Daily
emissions
monitoring
C.
Create
Information
D.
Gather
Existing
Information
E.
Write
Report
Report
of
excess
emissions
or
unacceptable
conditions
No
change
in
burden
due
to
additional
requirementsc
Included
in
4E
Included
in
3B
Included
in
3D
No
change
in
burden
due
to
additional
requirementsc,
d
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
B.
Plan
Activities
C.
Implement
Activities
D.
Develop
Record
System
No
change
in
burden
due
to
additional
requirementsc
Included
in
3B
Included
in
3D
Not
applicable
E.
Time
to
Enter
Information
+
Records
of
daily
shop
opacity
readings
e
­
Decrease
in
burden
due
to
no
longer
operating
COMg
+
Increase
in
burden
due
to
operating
BLDSh
0.5
­
0.5
+
0.5
350f
350
350
175
175
175
12.6
12.6
12.6
2,205
­
2,205
2,205
135,960
­
135,960
135,960
F.
Train
Personnel
G.
Audits
Not
applicable
Not
applicable
15
TABLE
1.
ANNUAL
BURDEN
OF
ADDITIONAL
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
NSPS
SUBPARTS
AA
AND
AAa
(
Continued)

Item
(
A)
Hours/
Occurence
(
B)
Occurrences/
Respondent/

Year
(
C=
AxB)
Hours/
Respondent/

Year
(
D)
Respondents/

Yeara
(
E=
CxD)
Hours/

Year
(
F)
Cost/

Yearb
TOTAL
ANNUAL
BURDEN
2,205
135,960
a
Assume
an
average
of
1
new
plant
per
year
or
3
new
plants
over
the
next
3
years;
yielding
an
average
total
of
95.3
potential
respondents
per
year.
Assume
40%
are
currently
using
COM,
and
1/
3
of
those
respondents
will
choose
to
use
alternative
monitoring
options;
yielding
12.6
respondents
per
year.

b
Assume
an
hourly
wage
of
$
61.66
(
includes
110%
overhead
costs).

This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

c
The
additional
monitoring
requirements
will
not
increase
the
burden
for
this
activity.

d
The
existing
ICR
assumed
that
all
respondents
will
have
at
least
one
incident
of
excess
emissions
per
reporting
period.
Therefore,
no
new
reports
will
be
needed.

e
Daily
opacity
readings
include
readings
by
a
certified
visible
emissions
observer.
Visible
emissions
observations
should
be
taken
for
at
least
three
6­
minute
periods
during
a
day
of
operation,
and
the
opacity
should
be
recorded
for
any
point(
s)
where
visible
emissions
are
observed.

f
Assume
facilities
operate
350
days
per
year.

g
Continuous
opacity
Monitoring
(
COM)
will
no
longer
be
required
for
owners
and
operators
who
elect
the
alternative
monitoring
option.

h
Includes
operation
and
maintenance
of
the
bag
leak
detection
system
(
BLDS)
including
the
time
required
to
respond
to
alarms.
The
time
required
to
repair
any
leaks
found
is
included
in
the
existing
ICR.
16
ATTACHMENT
1
ADDITIONAL
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirements
Regulation
Prepare
monitoring
plan
60.273a(
e)(
4)
and
60.273(
e)(
4)

Perform
daily
opacity
observations
by
a
certified
observer
60.273(
c)
and
60.273a(
c)

Install,
maintain,
and
operate
bag
leak
detection
system
60.273(
e)
and
60.273a(
e)

Maintain
records
of
bag
leak
detection
system
alarms
60.276(
e)
and
60.276a(
e)
