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
Integrated
Iron
and
Steel
Manufacturing
NESHAP."
This
is
a
new
ICR
and
the
EPA
tracking
number
is
2003.02.

(
b)
Short
Characterization/
Abstract.

Potential
respondents
are
owners
or
operators
of
integrated
iron
and
steel
manufacturing
facilities
that
are
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions.
The
final
rule
applies
to
existing
and
new
sinter
plants,
blast
furnaces,
and
basic
oxygen
process
furnace
(
BOPF)
shops
at
these
facilities.

Emission
limits
for
particulate
matter
and/
or
opacity
limits,

which
act
as
surrogates
for
individual
metallic
HAP,
are
established
for
six
types
of
discharge
points.
Operating
limits
are
also
required
for
certain
capture
systems
and
control
devices.
The
rule
also
includes
an
operating
limit
for
the
oil
content
of
the
sinter
plant
feedstock
to
reduce
organic
HAP.
As
an
alternative,
a
facility
may
choose
to
monitor
emissions
of
volatile
organic
compounds
instead
of
oil
content.

Plants
are
required
to
conduct
a
performance
test
to
demonstrate
initial
compliance
with
each
emission
and
opacity
limit
and
establish
operating
limits
for
capture
systems
and
control
devices.
A
performance
test
is
also
required
to
2
demonstrate
compliance
with
the
operating
limit
on
the
oil
content
of
sinter
plant
feedstock
or
for
volatile
organic
compounds.

Consistent
with
State
rules,
repeat
performance
tests
(
twice
during
a
permit
term)
are
required
to
demonstrate
continuous
compliance.
Plants
must
also
monitor
operating
parameters
for
certain
capture
systems
and
control
devices
using
continuous
parameter
monitoring
systems
and/
or
continuous
opacity
monitoring
systems.
A
continuous
opacity
monitoring
system
is
required
only
if
an
electrostatic
precipitator
is
used
as
the
control
device.

Plants
must
also
perform
inspections
and
maintenance
specified
included
in
their
written
operation
and
maintenance
plan
for
capture
systems,
control
devices.
Inspection
and
maintenance
requirements
also
are
required
for
each
type
of
monitoring
system.
To
demonstrate
continuous
compliance
with
the
sinter
plant
operating
limit,
plants
must
sample
the
oil
content
of
the
feedstock
daily
and
compute
the
30­
day
rolling
average.

Consistent
with
the
NESHAP
General
Provisions,
all
respondents
are
also
required
to
prepare
and
operate
by
a
startup,
shutdown,

and
malfunction
plan.

Respondents
must
submit
one­
time
notifications
as
required
by
the
NESHAP
General
Provisions
and
semiannual
compliance
reports
explaining
any
deviation.
An
immediate
report
is
required
if
actions
taken
in
response
to
the
startup,
shutdown,

or
malfunction
were
not
consistent
with
the
written
startup,
3
shutdown,
and
malfunction
plan.
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
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.
4
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
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
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.
5
(
c)
Consultations.

This
rule
was
developed
in
consultation
with
State
and
local
agencies,
EPA
regional
office
experts,
individual
iron
and
steel
plants,
and
their
trade
association.
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
Bruce
Steiner
American
Iron
and
Steel
Institute
202­
452­
7100
Don
Kuh
Indiana
Department
of
Environmental
Management
317­
233­
6866
(
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
6
involve
matters
of
a
sensitive
nature.

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

A
total
of
18
iron
and
steel
manufacturing
facilities
in
10
States
operated
in
2002;
we
believe
most
of
these
facilities
are
major
sources
that
would
be
subject
to
the
rule
requirements.

The
SIC
code
for
the
respondents
is
3312;
the
NAIC
code
is
331111.

(
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
as
a
firm
having
no
more
than
1,000
employees.
None
of
the
18
integrated
iron
and
steel
facilities
are
small
entities.
However,
our
economic
analysis
shows
that
no
facility
is
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
have
3
years
to
demonstrate
compliance
and
the
Administrator
or
permitting
authority
may
grant
1
additional
year
if
more
time
is
needed
to
7
install
controls.

(
d)
Collection
Schedule.

Information
contained
in
the
one­
time
only
reports
will
be
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
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
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
civilian
workers
were
taken
from
the
March
2002
Employment
Cost
Trends
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm).
Wages
for
civilian
workers
(
white­
collar
occupations)
are
used
as
the
basis
for
the
labor
rates
with
a
total
compensation
of
$
28.49/
hour
for
technical,
$
42.20/
hour
for
managerial,
and
$
18.41/
hour
for
clerical.
These
rates
represent
salaries
plus
8
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
$
59.83,
management
at
$
88.62,
and
clerical
at
$
38.66.

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

Costs.
As
shown
in
Table
2,
the
estimate
of
capital
and
operations
and
maintenance
costs
is
$
64,300
per
year.

(
iii)
Capital/
Startup
vs.
O&
M
Costs.
The
estimate
of
capital/
startup
costs
versus
O&
M
costs
is
shown
in
Table
2.
The
annual
O&
M
cost
over
the
3­
year
period
of
this
ICR
is
$
22,300.

(
iv)
Annualizing
Capital
Costs.
Table
2
shows
an
estimate
of
the
annualized
cost
of
capital
to
be
$
42,000
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.
Labor
rates
and
associated
costs
for
the
Agency
are
assumed
to
be
the
same
as
the
respondent's
hourly
rates.
The
Agency
labor
rates
9
are
estimated
as
follows:
technical
at
$
59.83,
management
at
$
88.62,
and
clerical
at
$
38.66.

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

The
EPA
estimates
that
all
18
facilities
will
install
the
required
monitoring
equipment,
conduct
initial
performance
tests,

prepare
startup,
shutdown,
and
malfunction
plans,
and
provide
the
one­
time
notifications
during
the
3­
year
clearance
period
for
this
ICR.
No
semiannual
compliance
reports
will
be
submitted
during
this
3­
year
period
because
plants
do
not
have
to
comply
until
after
the
term
of
this
ICR.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
2.
The
total
burden,
provided
in
Table
2,
is
4,772
hours;
the
estimated
cost
is
$
282,815
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
$
347,115
per
year.

(
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
4,772
hours.
The
annualized
cost
of
capital
for
monitoring
devices
is
$
42,000
averaged
over
the
first
3
years
of
the
ICR.
This
is
based
on
an
equipment
lifetime
of
5
years,
an
interest
rate
of
7
percent,
and
a
capital
recovery
factor
of
0.1424.
Operation
and
maintenance
costs
(
excluding
any
labor
hours
given
in
the
labor
burden
estimate)
are
estimated
at
$
22,300
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
as
in
the
respondent
table,
by
adding
person­
hours
per
year
down
each
10
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
73.
The
total
annual
cost
is
$
4,860.

(
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
265
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.
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
11
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2002­
0083,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
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
and
Radiation
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
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
0083)
in
any
correspondence.
12
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
13
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Number
of
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.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
40
1
40
6b
240
12
24
$
16,350
4.
Reporting
Requirements
A.
Read
instructions
2
1
2
6b
12
1
1
$
845
B.
Required
activities
Method
5
performance
test
40
7.6c
304
6b
1,824
91
182
$
124,230
Method
9
performance
test
8
3.6d
28.8
6b
173
9
17
$
11,805
Method
6071B
performance
test
2
365e
730
0f
0
0
0
$
0
Startup,
shutdown,
malfunction
plan
40
1
40
6b
240
12
24
$
16,350
Inspection
and
maintenance
of
capture
systems
and
control
devices
2
12
24
0
f
0
0
0
$
0
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Notification
of
applicability
2
1
2
6b
12
1
1
$
845
Notification
of
constr./
reconstr.
N/
A
Notification
of
anticipated
startup
N/
A
Notification
of
actual
startup
N/
A
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Number
of
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
Notification
of
special
compliance
requirements
N/
A
Compliance
extension
request
2
1
2
6b
12
1
1
$
845
Notification
of
opacity
observations
2
1
2
6b
12
1
1
$
845
Notification
of
performance
test
2
1
2
6b
12
1
1
$
845
Operation
and
maintenance
plan
40
1
40
6b
240
12
24
$
16,350
Site­
specific
test
plan
40
1
40
6b
240
12
24
$
16,350
Notification
of
compliance
status
8
1
8
6b
48
2
5
$
3,242
NESHAP
waiver
application
N/
A
Report
of
performance
test
See
4B
Semiannual
compliance
reportsg
40
2g
80
0f
0
0
0
$
0
Emergency
startup,
shutdown,
or
malfunction
reports
4
1
4
0
f
0
0
0
$
0
5.
Recordkeeping
Requirements
A.
Read
instructions
See
4A
B.
Plan
activities
3
1
3
6b
18
1
2
$
1,243
C.
Implement
activities
12
1
12
6b
72
4
7
$
4,933
D.
Develop
record
system
3
1
3
6b
18
1
2
$
1,243
E.
Time
to
enter
information
TABLE
2.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
FINAL
STANDARD
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Number
of
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
15
Records
of
all
info.
required
by
standards
3h
52h
156
6b
936
47
94
$
63,800
F.
Time
to
train
personnel
3
1
3
6b
18
1
2
$
1,243
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
3
1
3
6
b
18
1
2
$
1,243
H.
Time
to
transmit
or
disclose
information
0.25i
2
0.5
6
b
3
0.15
0.30
$
204
I.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
4,148
210
414
$
282,815
Annualized
cost
of
capitalj
$
42,000
Operation
and
maintenance
(
O&
M)
k
$
22,300
Total
(
capital
recovery
plus
O&
M)
$
64,300
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
59.83,
management
at
$
88.62,
and
clerical
at
$
38.66.

b
One
time
event
for
18
respondents
over
3­
year
term
of
ICR
is
18/
3
=
6
respondents/
yr.

c
Method
5
performance
tests
are
required
for
137
control
devices,
which
is
137/
18
=
7.
6
per
respondent.

d
Method
9
performance
tests
are
required
for
65
sources
or
65/
18
=
3.6
per
respondent.

e
The
oil
content
of
the
sinter
feed
must
be
analyzed
each
day.

f
Compliance
is
required
3
years
after
the
effective
date;
consequently,
none
of
these
activities
will
occur
during
the
3­
year
period
of
this
ICR.

g
Semiannual
reports
are
required:
includes
startup,
shutdown,
and
malfunction
activities
consistent
with
the
plan
and
deviations
from
emission
or
operating
limits.

h
Assumes
3
hours
per
week
per
plant
to
enter
into
records.

i
Assumes
15
minutes
to
transmit
recorded
information.

j
Cost
includes
86
bag
leaks
detectors
and
3
continuous
opacity
monitors
(
COMS).
Capital
cost
is
$
885,000
for
continuous
opacity
monitors
and
bag
leak
detectors,
7
percent
interest,

and
5­
year
equipment
life
(
capital
recovery
factor
=
0.142).
Incurred
in
the
third
year
of
the
ICR
term
($
126,000/
3
=
$
42,000/
yr).

k
Operation
and
maintenance
cost
for
3
COMS
and
86
bag
leak
detectors.
Incurred
in
the
third
year
of
the
ICR
term
($
67,000/
3
=
$
22,300/
yr).

N/
A
=
Not
Applicable.
16
TABLE
3.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL/
STATE
GOVERNMENT
OF
THE
FINAL
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
1b
40
2.0
4.0
$
2,725
Repeat
performance
test­
Retesting
preparation
2
2
0c
0
0.0
0.0
$
0
Repeat
performance­
Retesting
40
40
0c
0
0
0
$
0
Litigation
2080
2080
0d
0
0
0
$
0
Excess
Emissions
Enforcement
Activities
120
120
0d
0
0
0
$
0
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
initial
performance
test
2
2
6e
12
0.6
1.2
$
818
Notification
of
compliance
status
2
2
6e
12
0.6
1.2
$
818
Review
of
repeat
performance
test
report
8
8
0f
0
0
0
$
0
Review
of
semi­
annual
compliance
reporte
8
16
e
0f
0
0
0
$
0
Review
of
NESHAP
waiver
application
4
4
0g
0
0
0
$
0
Review
of
emergency
startup,
shutdown,
and
malfunction
report
4
4
0f
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY)
64
3
6
$
4,360
Travel
Expenses
for
Tests
Attendedh
(
1
person
x
1
plant/
yr
x
1
day/
plant
x
$
100
per
diem)
+
($
400/
round
trip
x
1
round
trips/
yr)
=
$
500
TOTAL
ANNUAL
COST
$
4,360
+
$
500
=
$
4,860
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
59.83,
management
at
$
88.62,
and
clerical
at
$
38.66.

b
Assumes
EPA/
State
personnel
will
attend
3
performance
tests
over
3
years
(
3/
3
=
1).

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

d
Assumes
no
plants
will
be
involved
in
litigation
or
excess
emissions
enforcement
activities
over
the
3­
year
term
of
the
ICR.

e
For
18
plants
over
3­
year
term
of
the
ICR
(
18/
3
=
6).

f
Compliance
is
required
3
years
after
the
effective
date;
consequently,
none
of
these
activities
will
occur
during
the
3­
year
period
of
this
ICR.

g
Assumes
no
plants
ask
for
waivers.
17
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
citation
General
Provisions
citation
Record
retention1
NOTIFICATIONS
Applicability
63.7840(
a)
63.9(
b)
5
years
Anticipated
startup
63.7840(
a)
63.9(
b)(
4)
5
years
Commencement
of
construction
63.7840(
a)
63.9(
b)(
4)
5
years
Actual
startup
63.7840(
a)
63.9(
b)(
4)
5
years
Intention
to
construct/
reconstruct
63.7840(
a)
63.9(
b)(
4)­(
5)
5
years
Compliance
dates/
extension
63.7840(
a)
63.9(
c)
5
years
Performance
test/
opacity
observations
63.7840(
a)
63.9(
e)
5
years
Compliance
status
63.7840(
a)
63.9(
g)
5
years
PLANS
AND
REPORTS
Operation
and
maintenance
plan
63.7800(
b)
N/
A
Life
of
affected
source
Semiannual
compliance
report
63.7841(
b)
63.10(
d)(
2)
5
years
Emergency
startup,
shutdown,
malfunction
reports2
63.7841(
c)
63.6(
e)(
3),
63.10(
d)(
5)
5
years
RECORDKEEPING
Notifications
and
reports
63.7842(
a)(
1)
63.10(
b)(
2)(
xiv)
5
years
Startup,
shutdown,
and
malfunction
plan/
events
63.7842(
a)(
2)
63.6(
e)(
3)(
iii)­(
v)
5
years
Performance
tests
and
opacity
observations
63.7842(
a)(
3)
63.10(
b)(
2)(
viii)
5
years
Continuous
monitoring
systems
63.7842(
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
Visual
observations
63.7842(
c)
63.6(
h)(
6)
5
years
Records
required
to
demonstrate
continuous
compliance
63.7842(
d)
63.10(
b)(
2)(
vii)
5
years
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.
