  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR
IRON AND STEEL FOUNDRIES AREA SOURCES

 

PART A

1.0  Identification of the Information Collection

(a) Title and Number of the Information Collection.

	“NESHAP for Iron and Steel Foundries Area Sources.”  This is a new
information collection request (ICR) and the EPA tracking number is
2267.02. 

 (b) Short Characterization.

	This ICR covers information collection requirements in the final area
source NESHAP for iron and steel foundries (40 CFR Part 63, Subpart
ZZZZZ).  Potential respondents are owners or operators of any existing
or new iron or steel foundry that is an area source of hazardous air
pollutants (HAP) emissions.  Research and development facilities are not
covered by the rule.  Foundries covered by the rule would not be
required to obtain a Title V operating permit.

	The final rule establishes different requirements for foundries based
on size.  Small iron and steel foundries are required to comply with
pollution prevention management practices for scrap materials, the
removal of mercury switches, and binder formulations.  Large iron and
steel foundries are required to comply with the same pollution
prevention management practices as small foundries in addition to
emissions limitations for melting furnaces and foundry operations. 
Existing foundries with an annual metal melt production greater than
20,000 tons and new foundries with an annual metal melt capacity greater
than 10,000 tons are classified as large foundries.  Existing foundries
with an annual metal melt production of 20,000 tons or less and new
foundries with an annual metal melt capacity of 10,000 tons or less are
classified as small foundries.

For metallic scrap, the pollution prevention management practices
require foundries to operate according to written specifications for the
use of only certain types of materials that do not generate HAP or that
have been depleted (to the extent possible) of organics and HAP metals. 
The final  standards for mercury require foundries that melt scrap from
motor vehicles either to purchase (or otherwise obtain) the motor
vehicle scrap only from scrap providers participating in an EPA-approved
program for the removal of mercury switches or to comply with
alternative provisions.  The requirements for binder formulations
require foundries to use on one type of production line chemical
formulations that do not contain methanol as a specific ingredient of
the catalyst formulation.  The management practices also include a
pollution prevention initiative to encourage foundries to investigate
and switch to nonHAP binders and coating materials by requiring records
of the annual quantity and composition of each HAP-containing chemical
binder or coating material used to make molds and cores.  The NESHAP
allows foundries 2 years after promulgation to comply with the
management practices for mercury, 1 year to comply with the opacity
limit for melt shops, and 6 months for other requirements.

Small foundries would submit two types of one-time notifications
required by the NESHAP general provisions and keep records of specific
information to demonstrate compliance with the rule requirements.  The
final rule also requires small foundries to calculate for each calendar
month their 12-month rolling average production rate to ensure that the
facility continues to meet the size criteria that defines a small iron
and steel foundry.  Records of the monthly production rate and monthly
rolling average calculations are required.  A small foundry must report
any deviation from these requirements within 30 days.  

	Large area source foundries are required to comply with the pollution
prevention management practices in addition to emissions standards for
metal melting furnaces and foundry operations.  The owner or operator
may elect to comply with emissions limits for particulate matter (PM) or
total metal HAP.  The final rule contains provisions for demonstrating
compliance with the limits using emissions averaging.  The owner or
operator of an existing affected source is required to conduct initial
and periodic visual inspections of PM control devices (baghouses, wet
scrubbers, electrostatic precipitators).  Foundries using a baghouse to
comply with the PM emission limit may choose to install and operate a
bag leak detection system instead of conducting the initial and periodic
inspections.  Bag leak detection systems are required at new foundries. 
New source foundries must use a  continuous parameter monitoring system
(CPMS) to measure and record pressure drop and scrubber water flow rate
for a wet scrubber and/or a CPMS to measure and record the hourly
average voltage and secondary current (or total power input) to an
electrostatic precipitator.  Monthly inspections of capture systems are
also be required.  An operation and maintenance plan for control devices
also is required.  Foundries also must conduct an opacity test at least
every 6 months to demonstrate compliance with an opacity limit for
fugitive emissions from buildings or structures housing foundry
operations.  Alternatively, foundries may conduct semiannual visible
emissions observations by Method 22.  The Method 22 test is considered
successful if no visible emissions are observed for 90 percent of a
1-hour test.  A Method 9 opacity test is required if the Method 22 test
is not successful. 

	Large foundries will demonstrate initial compliance with emissions
limits through performance tests.  The owner or operator of an existing
area source may certify initial compliance based on the results of a
previous performance test that meets the rule requirements.  Subsequent
performance tests for furnaces are to be performed every 5 years. 
Provisions also are included for demonstrating compliance through
emissions averaging.  A facility that uses emissions averaging must
conduct monthly compliance determinations by calculating the weighted
average emissions for furnaces in the emissions averaging group. 
Consistent with the NESHAP General Provisions, large foundries are
required to submit one-time notifications; comply with requirements for
startup, shutdown, and malfunction (SSM) plans and reports;  submit
semiannual excess emissions and monitoring system performance reports;
and maintain records of specific information to ensure that the rule
requirements are being achieved and maintained.  The information
requirements for foundries are listed in Attachment 1.  

2.  Need For and Use of the Collection

(a)	Need/Authority for the Collection.

	Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP
for both major and area sources of HAP that are listed for regulation
under CAA section 112(c).  An area source is a stationary source that is
not a major source (i.e., an area source does not emit and does not have
the potential to emit more than 10 tons per year of any single HAP or
more than 25 tons per year of any combination of HAP).  Requirements for
area sources in CAA sections 112(c)(3) and 112(k) direct EPA to (1) 
identify at least 30 air toxics that present the greatest potential
health threat in the largest number of urban areas and (2) to identify
sufficient area source categories to ensure that sources representing 90
percent or more of the of the emissions of the 30 “listed” HAP are
subject to regulation.  EPA implements these requirements through the
Integrated Urban Air Toxics Strategy (64 FR 38715, July 19, 1999).  Both
iron foundries and steel foundries were added to the Integrated Urban
Air Toxics Strategy Area Source Category List in 2002 (67 FR 43113)
based on emissions of HAP metals (chromium, lead, manganese, and
nickel).  We are issuing this standard in response to a court-ordered
deadline that requires EPA to issue standards for 10 source categories
listed pursuant to section 112(c)(3) and (k) by December 15, 2007
(Sierra Club v. U.S. Environmental Protection Agency, no. 01-1537,
D.D.C).

Under  CAA section 112(d)(5), we may elect to promulgate HAP standards
for area sources based on the use of generally available control
technology (GACT) or management practices used by the sources.  We can
consider costs and economic impacts in determining GACT, which is
particularly important when developing regulations for source categories
that may have few establishments and many small businesses, or when
determining whether additional control is needed for sources that are
already well-controlled as a result of other air emissions standards. 
Facilities in these two source categories are either minimally
controlled as a result of State and local requirements for PM or
uncontrolled, and many of the 427 area source facilities are small
entities.  We have developed the final NESHAP based on GACT.  

	Foundries also emit small quantities of mercury, dioxins, and HAP
organics from furnaces that melt scrap that contain tramp materials such
as mercury-containing switches and chlorinated plastics.  Organic HAP
emissions also result from the use of binder and coating formulations. 
As required by the Pollution Prevention Act of 1990, we reviewed the
rule prior to proposal to identify opportunities to apply pollution
prevention measures which “reduce the volume of, or eliminate
emissions of, such emissions through process changes, substitution of
materials, or other modifications.”  As a result, we are establishing
pollution prevention management practices for the control of HAP
(organics, metals, and mercury) in the charge materials used by
foundries.  We are also requiring the use of non-methanol binder
formulations in certain applications and a recordkeeping requirement for
information on the quantity and composition of each HAP-containing
binder or coating material used to make molds and cores.      

	Certain records and reports are necessary for the Administrator to
confirm the compliance status of area sources, identify any new or
reconstructed sources subject to the standards, and confirm that the
standards are being achieved on a continuous basis.  These recordkeeping
and reporting requirements are specifically authorized by section 114 of
the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP
General Provisions.  Under part 63, the owner or operator must keep each
record for 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record.    

 (b)	Use/Users of the Data.

	The information will be used by the delegated authority (State agency
or Regional Administrator if there is no delegated State agency) to
ensure that the emissions limits and other requirements are being
achieved.  Based on review of the recorded information at the site and
the reported information, the delegated permitting authority can
identify facilities that may not be in compliance and decide which
plants, records, or processes may need inspection.      

3.	Nonduplication, Consultations, and Other Collection Criteria

(a)	Nonduplication.

A computer search of EPA's ongoing ICR's revealed no duplication of
information-gathering efforts.  The information collection requirements
in 40 CFR part 63, Subpart EEEEE apply only to iron and steel foundries
that are major sources of HAP. 

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

	This section is not applicable because this is a rule-related ICR.

(c)	Consultations.

The final rules were developed in consultation with individual plants
and trade associations.  The non-EPA persons consulted on the
information collection activities are identified in Table 1.

TABLE 1.  PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact	Organization	Telephone Number

Amy Blankenbiller	American Foundry Society	(202) 842-4849

Raymond Monroe	Steel Founders’ Society of America	(847) 382-8240



(d)	Effects of Less Frequent Collection.

	If the relevant information were collected less frequently, the
delegated authority (State or 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/NAICS Codes.

	Potential respondents under Subpart ZZZZZ are owners or operators of
any existing or new iron foundry or steel foundry that is an area source
of HAP emissions.  The North American Industry Classification System
(NAICS) codes for iron and steel foundries are 331511, 331512, and
331513.  We estimate that a total of 427 area source foundries will be
subject to the NESHAP; no new area sources are projected during the 3
year period of this ICR.  

 (b) Information Requested.

	(i)  Data Items, Including Recordkeeping Requirements.  Attachment 1,
Source Data and Information Requirements, summarizes the data items,
including recordkeeping and reporting requirements.

	(ii)  Respondent Activities.  The respondent activities required by the
final rule are identified in Tables 2A (for small foundries) and 2B (for
large foundries) and are introduced in section 6(a).

5.	The Information Collected–Agency Activities, Collection
Methodology, and Information Management

(a)	Agency Activities.

	The Agency activities are provided in Table 3 and are introduced in
section 6(c).

(b)	Collection Methodology and Management.

	Data and records maintained by the respondents are tabulated and
published for use in compliance and enforcement programs of the
delegated authority.  The monitoring reports submitted to the delegated
authority are used for problem identification, as a check on source
operation and maintenance, and for compliance determinations.  EPA is
the delegated authority until the State agency is delegated authority to
implement the final rule.  Therefore, information contained in the
reports submitted to the Regional Administrator will be entered into the
Air Facility System (AFS), which is operated and maintained by EPA's
Office of Compliance.  AFS is EPA’s database for the collection,
maintenance, and retrieval of compliance data for approximately 125,000
industrial and government-owned facilities.  EPA uses the AFS for
tracking air pollution compliance and enforcement by local and state
regulatory agencies, EPA regional offices and EPA headquarters.  EPA and
its delegated authorities can edit, store, retrieve and analyze the
data.

(c)  Small Entity Flexibility.

	A small entity for this industry is defined by the Small Business
Administration as a firm having no more than 500 employees.  A total of
319 of the 427 iron and steel foundries are small entities. 
Approximately 45 percent (37 of 83) of the large iron and steel
foundries (annual metal melt production greater than 20,000 tons) are
owned by small entities while 85 percent (292 of 344) of the small iron
and steel iron and steel foundries are owned by small entities.  The
final  rule includes a specific compliance option for small foundries
that provides a maximum degree of operational flexibility, and the ICR
requirements are the minimum necessary to demonstrate compliance.  Since
proposal, we have further reduced the impacts on small entities by
increasing the threshold definition for a small foundry from an annual
melt production of 10,000 tons to 20,000 tons.  Our analyses show that
the final NESHAP will not result in a significant economic impact on a
substantial number of small entities.  No small entities are expected to
incur an economic impact that is greater than 3 percent of its revenue. 
The number of foundries that may incur an economic impact greater than 1
percent of their revenues ranges from an average of 9 to a maximum (at
the 98th percentile) of 13.

 (d)  Collection Schedule.

	The specific frequency for each information collection activity within
this request is shown in Tables 2A and 2B.

6.   Estimating the Burden and Cost of the Collection

(a)  Estimating Respondent Burden.

	The annual burden estimates for the final NESHAP are shown in Tables 2A
and 2B.  These numbers were derived from estimates based on EPA’s
experience with other standards.  No burden estimates are provided for
new area sources because no new facilities are expected during the
3-year period of this ICR.  These estimates represent the maximum burden
that would be imposed by the final rule based on a size threshold of
20,000 tons per year of metal melted.  

(b)  Estimating Respondent Costs.

	The information collection activities for the final NESHAP are
presented in Tables 2A and 2B.  

(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 in the
foundry industry (NAICS 331500) were taken from the United States
Department of Labor, Bureau of Labor Statistics, May 2006 available at
http://www.bls.gov.  Wages for occupational groups are used as the basis
for the labor rates with a total compensation of $34.33/hour for
technical, $46.66/hour for managerial, and $15.79/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 $72.09, management
at $97.99, and clerical at $33.16.

	(ii)  Estimating Capital and Operations and Maintenance (O&M) Costs.  
As shown in Table 2B, the estimate of capital costs for large foundries
is $59,620 with no O&M costs.  This cost does not include the cost of
any monitoring equipment because the final rule requires visual
inspections instead of automated monitoring equipment at existing
affected sources. This cost does include the cost of a file cabinet for
data storage.  

	(iii) Capital/Startup vs. O&M Costs.  The estimate of capital/startup
costs versus O&M costs is shown in Table 2B.  No O&M costs would occur
over the 3-year period of this ICR.

	(iv) Annualizing Capital Costs.  Table 2B shows an estimate of the
annualized cost of capital to be $8,490 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 part 63 NESHAP General Provisions, no operational
costs would 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) 2007 General Schedule which excludes locality rates of pay.  These
rates can be obtained from Salary Table 2007-GS available on the OPM
website,   HYPERLINK "http://www.opm.gov/oca/06tables/html/gs_h.asp" 
http://www.opm.gov/oca/06tables/html/gs_h.asp . The government employee
labor rates are $14.60/hour for clerical (GS-6, Step 3), $26.98 for
technical (GS-12, Step 1), and $36.36/hr for management (GS-13, Step 5).
 These rates were increased by 60 percent to include fringe benefits and
overhead.  The fully-burdened wage rates used to represent Agency labor
costs are:  clerical at $ $22.66; technical at $47.97, and management at
$58.18. 

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

There are 427 existing iron and steel foundries.  No new sources are
expected during the next 3 years.  Consequently, the average number of
respondents during the 3 year period of this ICR is 142.33.  A total of
344 of the 427 facilities are foundries with a metal melting rate of
20,000 tpy or less and 83 have metal melting rates greater than 20,000
tpy.  Consequently, the average number of small foundries during the
3-year period of this ICR is 114.67 and the average number of large
foundries is 27.67.

The only components of the total annual responses for small foundries
attributable to this ICR are two one-time initial notifications for each
facility.  Large foundries are required to submit two one-time initial
notifications; prepare an operation and maintenance plan and a startup,
shutdown, and malfunction plan, and submit semiannual compliance
reports.  The number of total annual responses for Subpart ZZZZZ is
estimated as:  (114.67 annual average respondents × 1 notification) +
(114.67 annual average respondents × 1 notification) + (27.67 annual
average respondents x 1 deviations report) + (27.67 annual average
respondents × 2 written plans) + (27.67 annual average respondents x 2
semiannual reports).   Therefore, the number of total annual responses
for Subpart ZZZZZ is 367.7.

(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 average annual burden for the monitoring, recordkeeping, and
reporting requirements in Subpart ZZZZZ for small foundries is 3,555
person hours with an annual average cost of $248,288 with no capital and
O&M costs.  The average annual burden for the monitoring, recordkeeping,
and reporting requirements in Subpart ZZZZZ for large foundries is 2,469
person hours with an annual average cost of $172,430; the annualized
capital cost is $8,490 with no operation and maintenance costs.  The
average annual burden for the monitoring, recordkeeping, and reporting
requirements in Subpart ZZZZZ for all iron and steel foundry area
sources is 6,064 person hours with an annual average cost of $420,718
with annualized capital costs of $8,490 and no O&M costs. 

	(ii)  The Agency tally.  The total annual Federal Government cost is
$32,675 for 657.2 total annual hours.  The bottom line Agency burden
hours and costs presented in Tables 3 are calculated by adding
person-hours per year down each column for technical, managerial, and
clerical staff, and by adding down the cost column. 

	(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 for the final NESHAP for iron and
steel foundry area sources is estimated at 14 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
in 40 CFR part 63 are listed in 40 CFR part 9.

PART B

	This section is not applicable because statistical methods are not used
in data collection associated with the final rules.TABLE 2A.  ANNUAL
RESPONDENT BURDEN AND COSTS FOR SMALL FOUNDRIES

Burden item	(A) Person-hours per occurrence	(B)  No. of occurrences per
respondent	(C) Person-hours per respondent (C=A*B)	(D) Respondents per
yeara	(E) Technical person-hours per year (E=C*D)	(F) Management
person-hours per year

 (E*0.05)	(G) Clerical person-hours per year (E*0.1)	(H) Costb, $ 

1.  Applications	N/A





	  

2.  Surveys and Studies	N/A





	  

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





	  

4.  Reporting Requirements





	  

A.  Read instructions	4	1	4	114.67	458.68	22.934	45.868	 $36,836 

B.  Required activities





	  

     Scrap specifications	4	1	4	114.67	458.68	22.934	45.868	 $36,836 

Monthly rolling average calculation	0.25	12	3	114.67	344.01	17.2005
34.401	 $27,627 

     No methanol binder formulationc 	0	0	0	0	0	0	0	 $-   

C.  Create information	See 4B





	  

D.  Gather existing information	See 4B





	  

E.  Write report	See 4B





	  

     Initial notification of applicability	2	1	2	101	202	10.1	20.2	
$16,222 

     Notification of compliance status	4	1	4	114.67	458.68	22.934	45.868
 $36,836 

Deviations report	1	1	1	57.34	57.34	2.867	5.734	 $4,605 

     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





	  

     Request for compliance extension	N/A





	  

     Notification of performance test	N/A





	  

     Site specific test plan	N/A





	  

     Notification of performance evaluation	N/A





	  

     Quality assurance plan for CEMS/COMS	N/A





	  

     NESHAP waiver request	N/A





	  

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





	  

     Semiannual excess emissions reports	N/A





	  

5.  Recordkeeping Requirements 





  

A.  Read instructions	See 4A





	  

B.  Plan activities	See 4A





	  

C.  Implement activities	See 4A





	  

D   Develop record system 	2	1	2	114.67	229.34	11.467	22.934	 $18,418 

E.  Time to enter information d	0.1	52	5.2	114.67	596.284	29.8142
59.6284	 $47,886 

F.  Time to transmit or disclose information	0.25	2	0.5	114.67	57.335
2.86675	5.7335	 $4,604 

G.  Time to adjust existing ways	2	1	2	114.67	229.34	11.467	22.934	
$18,418 

F.  Time to train personnele	NA





	  

G.  Time for audits	N/A





	  

TOTAL LABOR BURDEN AND COST

	 3,555 	 $248,288 

     Annualized cost of capital





$0

     Operation and maintenance (O&M)





$0

     Total (capital recovery plus O&M)   





$0



N/A = not applicable.

a There are 427 existing iron and steel foundries that area sources.  No
new sources are projected during the 3-year term of this ICR. 
Therefore, the average number of total respondents per year is 142.33. 
A total of 344 of the 427 facilities are small foundries and 83 are
large foundries.  Consequently, the average number of small foundries
during the 3-year period of this ICR is 114.67 and the average number of
large foundries is 27.67.   No new sources are expected during the next
3 years.  For the purposed of deviation reports, 1 report per year is
estimated for one-half (50.5) of the 114.67 respondents per year.

b  This ICR uses the following labor rates: The fully-burdened hourly
wage rates used to represent respondent labor costs are:  technical at
$72.09, management at $97.99, and clerical at $33.16.  Technical,
management, and clerical average hourly rates for private industry
workers in the foundry industry (NAICS 331500) were taken from the
United States Department of Labor, Bureau of Labor Statistics, May 2006
available at http://www.bls.gov. The rates have been increased by 110%
to account for the benefit packages available to those employed by
private industry.

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

d  Small foundries must record information to demonstrate compliance
with pollution prevention management practices for metallic scrap and
binder formulations.

TABLE 2B.  ANNUAL RESPONDENT BURDEN AND COSTS FOR LARGE FOUNDRIES

Burden item	(A) Person-hours per occurrence	(B)  No. of occurrences per
respondent	(C) Person-hours per respondent (C=A*B)	(D) Respondents per
yeara	(E) Technical person-hours per year (E=C*D)	(F) Management
person-hours per year (E*0.05)	(G) Clerical person-hours per year
(E*0.1)	(H) Costb, $ 











1.  Applications	N/A







	2.  Surveys and Studies	N/A







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







	4.  Reporting Requirements







	A.  Read instructions	8	1	8	27.67	221.4	11.1	22.1	$17,777

B.  Required activities 









     Scrap material specifications	4	1	4	27.67	110.7	5.5	11.1	$8,889

     Prepare operation & maintenance plan	8	1	8	27.67	221.4	11.1	22.1
$17,777

     No methanol binder formulationc 	4	1	4	0.67	2.68	0.134	0.268	$215

Initial/subsequent performance testsd	0	0	0	0	0.0	0.0	0.0	$0

Initial and periodic inspections of PM control devices, monthly
inspection of capture systemsd	0	0	0	0	0.0	0.0	0.0	$0

 Monthly emissions averaging calculationsd	0	0	0	0	0.0	0.0	0.0	$0

C.  Create information	See 4B







	D.  Gather existing information	See 4B







	E.  Write report	See 4B







	     Initial notification of applicability	4	1	4	27.67	110.7	5.5	11.1
$8,889

     Notification of compliance status	8	1	8	27.67	221.4	11.1	22.1
$17,777

     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







	     Request for compliance extension	N/A







	     Notification of performance testd	1	1	1	27.67	27.7	1.4	2.8	$2,222

     Site specific test pland	0	0	0	0	0.0	0.0	0.0	$0

     Notification of performance evaluation	N/A







	     Quality assurance plan for CEMS/COMS	N/A







	     NESHAP waiver request	N/A







	     Startup, shutdown, and malfunction plan/reports	4	1	4	27.67	110.7
5.5	11.1	$8,889

     Semiannual excess emissions reportsd	2	2	4	27.67	110.7	5.5	11.1
$8,889

5.  Recordkeeping Requirements 







	A.  Read instructions	See 4A







	B.  Plan activities	See 4A







	C.  Implement activities	See 4A







	D   Develop record system 	4	1	4	27.67	110.7	5.5	11.1	$8,889

E.  Time to enter information e	0.5	52	26	27.67	719.4	36.0	71.9	$57,775

F.  Time to transmit or disclose information	0.25	2	1	27.67	13.8	0.7	1.4
$1,111

G.  Time to adjust existing ways	2	1	2	27.67	55.3	2.8	5.5	$4,444

F.  Time to train personnelf	4	1	4	27.67	110.7	5.5	11.1	$8,889

G.  Time for audits	N/A







	TOTAL LABOR BURDEN AND COST

	  2,469 	$172,430

     Annualized cost of capitalg





	$8,490

     Operation and maintenance (O&M) h





$0

     Total (capital recovery plus O&M) g    





$8,490



N/A = not applicable.

a There are 427 existing iron and steel foundries that area sources.  No
new sources are projected during the 3-year term of this ICR. 
Therefore, the average number of respondents per year is 142.33.  A
total of 344 of the 427 facilities are small foundries and 83 are large
foundries.  Consequently, the average number of small foundries during
the 3-year period of this ICR is 114.67 and the average number of large
foundries is 27.67

 b  This ICR uses the following labor rates: The fully-burdened hourly
wage rates used to represent respondent labor costs are:  technical at
$72.09, management at $97.99, and clerical at $33.16.  Technical,
management, and clerical average hourly rates for private industry
workers in the foundry industry (NAICS 331500) were taken from the
United States Department of Labor, Bureau of Labor Statistics, May 2006
available at http://www.bls.gov. The rates have been increased by 110%
to account for the benefit packages available to those employed by
private industry.

c Two large area source foundries (2 foundries over 3 years = 0.67
foundries per year) are expected to have to change formulations to meet
the no methanol requirement.

d  These activities are not expected to occur during the first 3 years
of this ICR.

e   Large foundries must record information to demonstrate compliance
with pollution prevention management practices for metallic scrap and
binder formulations and information to demonstrate compliance with
monitoring; inspection; operation and maintenance; startups, shutdowns,
and malfunctions; and other requirements of the General Provisions (40
CFR part 63, subpart A). 

f   Large foundries are expected to monitor visible emissions using a
trained employee.

g  Based on capital cost of $59,620 for file storage cabinets,  7
percent interest, and 20-year equipment life (capital recovery factor =
0.142).  No costs for monitoring equipment are estimated because no
monitoring equipment is required for existing foundries.

TABLE 3.  ANNUAL BURDEN AND COST TO THE AGENCY

Burden Item	(A) Person hours per occurrence	(B) Occurrences per
respondent	(C) Plants per year a	(D) Technical hours/year (D=A*B*C)	(E)
Management   hours/year (E=0.05*D)	(F) Clerical-hours/year (F=0.1*D)	
(G) Costb, $

Report Review:







	  Initial notification of applicability 	1	1	142.33	142.3	7.1	14.2
$7,564

Deviation reports	1	1	50.1	50.1	2.5	5.0	$2,662

  Startup, shutdown, malfunction plan/report	2	1	142.33	142.3	7.1	14.2
$7,564

  Notification of compliance status	2	1	142.33	142.3	7.1	14.2	$7,564

  Semiannual excess emissions report	2	1	142.33	142.3	7.1	14.2	$7,564

TOTAL BURDEN AND COST

	712.3	$32,917



 a There are 427 existing iron and steel foundries that are area
sources.  No new sources are projected during the 3-year term of this
ICR.  Therefore, the average number of respondents per year is 142.33. 
No travel is expected.

b  This ICR uses the following average hourly labor rates: 58.18 for
managerial (GS-13, Step 5, $36.36 x 1.6), $43.14 (GS-12, Step 1, $29.98
x 1.6) for technical and $22.66 (GS-6, Step 3, $14.16 x 1.6) for
clerical.  These rates are from the Office of Personnel Management (OPM)
(2007 General Schedule( which excludes locality rates of pay.

ATTACHMENT 1.  INFORMATION REQUIREMENTS 

 Requirement for new and existing sources 	Citation for small
foundries	Citation for large foundries	Citation for NESHAP general
provisions 

Initial and periodic inspections for baghouses, wet scrubber, and
electrostatic precipitator at existing source;  	NA	§63.10897(a)	NA

CPMS for wet scrubber at new source	NA	§63.10897(b)	NA

CPMS for electrostatic precipitator at new source	NA	§63.10897(c)	NA

BLDS or inspections for baghouse at existing source; BLDS for baghouse
at new source.	NA	§63.10897(d)	NA

Monthly capture system inspections	NA	§63.10897(e)	NA

Semiannual opacity tests	NA	§63.10898(i)	NA

CMS performance evaluation	NA	NA

	Metal melting furnaces and fugitive emissions 	NA	§63.10898	40 CFR
63.7

CMS performance evaluation	NA	NA	40 CFR 63.8(e)(3)

Notification of applicability	§63.10890(b)	§63.10900(a), Table 3	40
CFR 63.9(b)(2)

Notification of construction/ reconstruction 1	§63.10890(f)
§63.10900(a), Table 3	40 CFR 63.9(b)(5)

Notification of special compliance requirements  1	§63.10890(f)
§63.10900(a), Table 3	40 CFR 63.9(d)

Notification of performance test	NA	§63.10900(a), Table 3	40 CFR
63.9(c)

Notification of opacity/VE observations	NA	§63.10900(a), Table 3	40 CFR
63.9(f)

Additional CMS notifications	NA	NA	40 CFR 63.9(g)

Notification of compliance status	§63.10890(c)	§63.10900(a), Table 3
40 CFR 63.9(h)(1)

Notification of changes in information  1	§63.10890(f)	§63.10900(a),
Table 3	40 CFR 63.9(j)

Scrap management material specifications 	§63.10885(b),(c)

NA

Operation and maintenance plan	NA	§63.10896(a)	NA

Startup, shutdown, and malfunction plan	NA	§63.10900(a), Table 3	40 CFR
63.6(e)(3)

Performance test plan	NA	§63.10900(a), Table 3	40 CFR 63.7(c)(2)

CMS quality control plan	NA	§63.10900(a), Table 3	40 CFR 63.8(d)

CMS performance evaluation test plan	NA	NA	40 CFR 63.8(e)(3)

Information to support notifications	§63.10890(e)(1)	§63.10900(a),
Table 3	40 CFR 63.10(b)(2)

Material specifications	§63.10890(e)(2)	§63.10899(b)(1)	NA

Mercury	§63.10890(e)(3)-(4)	§63.10899(b)(2)-(3)	NA

Nonmethanol binder chemical formulations	§63.10890(e)(5)
§63.10899(b)(4)	NA

Annual quantity and composition of each HAP-containing chemical binder
or coating material 	§63.10890(e)(6)	§63.10899(b)(5)	NA

Metal melt production	§63.10890(e)(7)	§63.10899(b)(6)

	Operation and maintenance plan	NA	§63.10899(b)(7)	NA

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

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

Capture system inspections	NA	§63.10899(b)(10)	NA

CPMS specifications	NA	§63.10899(b)(11)	NA

Corrective action	NA	§63.10899(b)(12)	NA

PM control device log of inspections/maintenance	NA	§63.10899(b)(13)	NA

Semiannual excess emissions/deviation reports	§63.10890(f)
§63.10899(c), Table 3	40 CFR 63.10(e)(3)

Initial performance test report	NA	§63.10900(a), Table 3	40 CFR
63.7(e)(1)

CMS performance evaluation report	NA	NA	40 CFR 63.8(e)(5)

SSM reports	NA	§63.10900(a), Table 3	40 CFR 63.6(e)(3)

1 Requirement is not expected to occur during the 3-year term of this
ICR

 PAGE   

 PAGE  4 

  PAGE  12 

  PAGE   19 

