1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
"
NSPS
Subparts
AA
and
AAa:
Steel
Plants:
Electric
Arc
furnaces
and
Decarburization
Vessels"
This
is
an
amendment
to
the
existing
information
collection
request
(
ICR
No.
1060.10).

The
Environmental
Protection
Agency
(
EPA)
has
assigned
this
revision
to
the
ICR
the
tracking
number
1060.11.

1(
b)
Short
Characterization
The
EPA
is
amending
the
national
standards
of
performance
for
new
stationary
sources
(
NSPS)
for
electric
arc
furnaces
(
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).
Changes
to
both
rules
are
being
made
to
add
alternative
requirements
for
the
monitoring
of
EAF
emissions
control
systems
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
will
not
remove
any
of
the
rules'
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.

These
amendments
will
add
bag
leak
detection
coupled
with
daily
shop
opacity
observations
as
an
alternative
to
continuous
opacity
monitoring.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2
2(
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
(
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.
3
The
control
of
emissions
of
particulate
matter
from
steel
plants
subject
to
NSPS
Subparts
AA
and
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
electric
arc
furnaces,
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.

2(
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
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
4
3(
a)
Nonduplication
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
luie
of,
or
as
a
part
of,
the
report
required
by
the
standards.

3(
b)
Public
Notice
required
prior
to
ICR
Submission
to
OMB
A
public
review
and
comment
period
will
occur
after
publication
of
the
amendment
to
the
NSPS
for
EAF.

3(
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
being
proposed
today.

3(
d)
Effects
of
Less
Frequent
Collection
The
reports
are
being
required
on
a
semi­
annual
basis.
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.

3(
e)
General
Guidelines
5
None
of
the
general
information
collection
guidelines
in
5
CFR
1230.5(
d)(
2)
of
the
OMB
regulations
implementing
the
Paperwork
Reduction
Act
is
being
exceeded.

3(
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
8,

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

1979).

3(
g)
Sensitive
Questions
This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.
6
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
codes
The
respondents
are
owners
or
operators
of
steel
electric
arc
furnaces
built
after
October
21,
1974.
Steel
electric
arc
furnaces
are
included
under
two
digit
SIC
Code
33
­
Primary
Metal
Industries.
Other
industries
listed
in
this
SIC
code
are
not
respondents
to
the
ICR.

4(
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
amendment.

(
ii)
Respondent
activities
Additional
respondent
activities
for
sources
affected
by
the
NSPS
are
shown
for
each
of
the
first
three
years
following
promulgation
of
the
amendment
in
the
first
column
of
Table
1.
It
was
estimated
that
one
additional
source
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
only
activities
that
the
Federal
government
will
be
required
to
perform
are
associated
with
the
review
of
reported
7
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.

5(
b)
Collection
Methodology
and
Management
Information
contained
in
the
periodic
reports
submitted
to
the
EPA
will
be
reviewed
for
accuracy
and
completeness.
Data
obtained
during
periodic
visits
by
EPA
personnel
form
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

5(
c)
Small
Entity
Flexibility
Steel
plants
with
electric
arc
furnaces
are
not
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
new
information
collection
activity
within
this
request
is
shown
in
Attachment
1.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
the
additional
recordkeeping
and
reporting
requirements
are
presented
in
Table
1.
For
consistency,
the
number
of
affected
sources
(
90)
and
the
number
of
new
sources
(
1/
year)
used
in
estimating
burden
for
the
current
ICR
(
ICR
No.
1060.10)
were
used
in
estimating
the
burden
for
the
additional
requirements.

The
amended
NSPS
adds
new
alternative
monitoring
requirements
to
the
existing
monitoring
requirements.
If
an
8
owner
or
operator
chooses
to
use
the
alternative
monitoring
requirements,
they
will
incur
additional
recordkeeping
and
reporting
burden.
This
request
identifies
the
net
increase
in
recordkeeping
and
reporting
burden
to
the
industry
assuming
30
percent
of
affected
sources
will
choose
to
implement
the
alternative
monitoring
requirements.

The
option
being
added
would
allow
owners
and
operators
to
perform
bag
leak
detection
coupled
with
daily
visible
emission
observations
of
shop
opacity
in
lieu
of
installing
and
operating
a
COMS.
If
an
owner
or
operator
selects
this
option,
they
will
incur
additional
recordkeeping
and
reporting
burden.
This
increase
would
be
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.
The
net
average
annual
burden
to
industry
over
the
next
three
years
from
these
new
recordkeeping
and
reporting
requirements
is
estimated
at
1,750
person­
hours.
The
respondent
costs
have
been
calculated
on
the
basis
of
$
16.67
per
hour
plus
110
percent
overhead.
The
increased
average
annual
burden
to
industry
over
the
next
three
years
due
to
the
new
requirements
is
estimated
to
be
$
61,267.50.

6(
b)
Estimating
Respondent
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
operating
and
maintenance
costs
for
emission
monitoring.

6(
c)
Estimating
Agency
Burden
and
Cost
9
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
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.

6(
d)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables
(
i)
Respondent
Tally
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Table
1,
are
calculated
by
adding
person­
hours
per
year
down
each
column,
and
by
summing
down
the
labor
cost
column.
For
the
industry
as
a
whole,
assuming
that
30
percent
of
facilities
choose
the
alternative
monitoring
requirements,
the
increase
in
hours
are
1,750
and
cost
is
$
61,267.50.
The
total
burden,

including
existing
requirements,
is
estimated
at
50,163
hours
at
a
cost
of
$
1,755,705.

Total
estimated
annualized
costs
for
the
reporting
and
recordkeeping
burden
and
total
annualized
capital/
startup
costs
are
reported
on
the
OMB
83­
I
form.
There
is
no
increase
to
the
total
estimated
annualized
costs
for
the
reporting
and
recordkeeping
burden
as
a
result
of
the
new
alternative
10
monitoring
requirements.
Total
annualized
capital/
startup
costs
(
including
existing
requirements)
are
estimated
at
$
28,000.

Annual
operation
and
maintenance
costs
were
estimated
at
$
67,000
nationwide,
or
$
744
per
facility.

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

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

6(
e)
Reason
for
Change
in
Burden
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
rules'
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
chooses
to
use
the
alternative
monitoring
requirements,
they
will
incur
additional
recordkeeping
and
reporting
burden.

6(
g)
Burden
Statement
The
annual
increase
to
monitoring,
recordkeeping,
and
reporting
burden
for
this
collection
is
estimated
at
1,750
labor
hours
at
a
total
cost
of
$
61,267.50
nationwide
(
assuming
10
sources
select
the
alternative
monitoring
requirements),
and
the
annual
average
increase
in
burden
is
175
labor
hours
and
11
$
6,126.75
per
source.
This
estimate
includes
the
costs
of
operating
the
bag
leak
detection
system,
performing
daily
shop
opacity
observations.
This
estimate
also
includes
offsetting
burden
associated
with
no
longer
being
required
to
operate
the
COMS.
The
total
annual
monitoring,
recordkeeping,
and
reporting
burden
(
including
the
existing
requirements)
is
estimated
at
is
estimated
at
50,163
hours
at
a
total
cost
of
$
1,755,705
nationwide.
The
annual
average
burden
is
557
labor
hours
and
$
19,507
per
source.

There
will
be
no
increase
in
annualized
capital/
startup
costs
as
a
result
of
the
new
alternative
monitoring
requirements.

Total
annualized
capital/
startup
costs
(
including
existing
requirements)
are
estimated
at
$
28,000.
Annual
operation
and
maintenance
costs
were
estimated
at
$
67,000
nationwide,
or
$
744
per
facility.

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.
12
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OIC
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822T),
1200
Pennsylvania
Avenue
NW,

Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1060.11
and
OMB
control
number
2060­
0038
in
any
correspondence.
13
TABLE
1.
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
14
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
10
10
10
1,750
­
1,750
1,750
61,267.5
­
61,267.5
61,267.5
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
1,750
61,267.50
a
Assume
an
average
of
1
new
plant
per
year
or
3
new
plants
over
the
next
3
years;
yielding
an
average
total
of
65
potential
respondents
per
year.
Assume
1/
2
are
currently
using
COM,
and
30%
of
those
respondents
will
choose
to
use
alternative
monitoring
options;
yielding
10
respondents
per
year.

b
Assume
an
hourly
wage
of
$
16.67
plus
110%
overhead
costs
which
equals
$
35.01.

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
maintainence
of
the
bag
leak
detection
system
(
BLDS)
including
the
time
required
to
respond
to
alarms.
The
time
required
to
repaid
any
leaks
found
is
included
in
the
existing
ICR.
16
ATTACHMENT
1
ADDITIONAL
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Requirements
Regulation
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
bagleak
detection
system
alarms
60.276(
e)
and
60.276a(
e)
