SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Iron
and
Steel
Plants:
Basic
Oxygen
Process
Furnaces
(
40
CFR
Part
60,
Subparts
N
and
Na)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Iron
and
Steel
Plants:
Basic
Oxygen
Process
Furnaces
(
40
CFR
Part
60,
Subparts
N
and
Na)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Primary
Emissions
from
Basic
Oxygen
Process
Furnaces
(
Subpart
N)
were
proposed
on
June
11,
1973,
and
promulgated
on
March
8,
1974.
These
standards
apply
to
each
basic
oxygen
process
furnace
(
BOPF)
in
an
iron
and
steel
plant
commencing
construction,
modification
or
reconstruction
after
the
date
of
a
proposal.
An
opacity
limit
was
promulgated
on
April
13,
1978,
as
a
supplement
to
the
mass
standard.
On
January
20,
1983,
amendments
to
the
Standards
of
Performance
for
Primary
Emissions
from
Basic
Oxygen
Process
Furnaces,
merged
with
Standards
of
Performance
for
Secondary
Emissions
from
Basic
Oxygen
Process
Steelmaking
Facilities
(
Subpart
Na).
Subpart
Na
is
applicable
to
any
top­
blown
BOPF,
hot
metal
transfer
station
or
skimming
station
for
which
construction,
reconstruction,
or
modification
commenced
after
January
20,
1983.
These
amendments
were
promulgated
on
January
2,
1986.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subparts
N
and
Na.

In
general,
all
NSPS
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
In
addition,
all
sources
subject
to
this
standard
are
required
to
submit
semiannual
reports
of
measurements
that
average
10
percent
below
the
average
measurements
obtained
during
the
most
recent
performance
tests.
Monitoring
requirements
specific
to
NSPS
for
Primary
and
Secondary
Emissions
from
Basic
Oxygen
Process
Furnaces
at
steelmaking
facilities
provide
information
on
the
operation
of
the
emissions
control
device
and
compliance
with
the
mass
and
visible
emission
standards.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
NSPS.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
Environmental
Protection
Agency
(
EPA)
Regional
Office.
2
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

For
the
renewal
of
this
Information
Collection
Request
(
ICR),
we
have
determined
that
the
number
of
sources
has
decreased
within
the
past
three
years.
There
are
only
three
BOPF
shops,
out
of
19
BOPF
shops
at
17
facilities
operating
in
the
United
States,
which
are
subject
to
NSPS
Subparts
N
and
Na.
We
have
also
assumed
that
one
of
two
BOPF
shops
that
closed
within
the
past
three
years,
which
has
a
vessel
subject
to
NSPS
Subpart
Na,
will
reopen
within
the
next
few
months
(
approximately
6
months
from
July
2002)
based
on
information
that
we
have
gathered
on
the
source.
Therefore,
the
burden
estimate
for
the
renewal
of
this
ICR
was
calculated
with
the
assumption
that
there
are
4
operating
BOPF
shops.
We
have
also
determined
that
there
is
an
average
of
2.2
vessels
per
BOPF
shop.
In
addition,
we
have
assumed
that
one
existing
BOPF
shop
over
the
next
three
years
will
become
subject
to
NSPS
Subpart
Na
due
to
modifications/
reconstruction
related
to
its
furnaces,
skimming
stations
and/
or
hot
metal
transfer
stations.

In
the
development
of
this
ICR,
we
have
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
on
the
active
ICR.
Specifically,
we
revised
the
current
number
of
sources
affected
by
the
rule
and
revised
the
assumptions
that
were
made
on
the
active
ICR.
We
have
also
revised
the
estimate
for
capital
and
operation
and
maintenance
costs
for
the
three­
year
period
of
this
ICR.
The
total
number
of
sources
was
based
on
an
analysis
of
the
BOPF
shops
operated
by
iron
and
steel
facilities
listed
on
the
Sector
Facility
Indexing
Project
(
SFIP).
We
revised
the
list
based
with
the
technical
support
of
Edward
Wojciechowski,
the
Agency
Iron
and
Steel
Liaison,
who
has
extensive
knowledge
on
the
industry
sector,
and
information
gathered
on
BOPF
shops
by
the
United
Steel
Workers
of
America,
and
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
and
by
contacting
the
sources'
environmental
affairs
contact
to
confirm
its
status.

The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
25,794.
The
average
annual
burden
to
industry
over
the
next
three
years
for
recordkeeping
and
reporting
requirements
is
estimated
at
1,012
person­
hours
2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:
3
.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
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,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
particulate
matter
emissions
from
primary
and
secondary
emissions
from
basic
oxygen
process
furnaces
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60,
Subparts
N
and
Na.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
particulate
matter
emissions
from
primary
and
secondary
emissions
from
basic
oxygen
process
furnaces
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulate
matter
from
basic
oxygen
process
furnace
shops
are
the
result
of
operation
of
furnaces,
skimming
stations
and/
or
hot
metal
transfer
stations.
The
subject
standards
are
achieved
by
the
capture
and
collection
of
primary
and
secondary
particulate
matter
emissions
by
use
of
primary
emission
control
systems
such
as
the
combination
of
open
or
closed
hood
capture
systems
in
conjunction
with
electrostatic
precipitators
or
venturi
scrubbers,
and
the
use
of
secondary
emission
control
systems
such
as
a
combination
of
open
or
closed
hood
capture
systems
in
4
conjunction
with
baghouses
or
venturi
scrubbers.

The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
opacity
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
records
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
A
source
is
required
to
monitor
the
operating
conditions
of
each
steel
production
cycle
including
time
and
duration
of
process,
exhaust
ventilation
rates
of
gases,
the
pressure
loss
through
a
venturi
scrubber,
water
supply
pressure
to
the
control
equipment;
and
opacity
through
the
shop
roof
or
other
building
openings.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60,
Subparts
N
and
Na.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
local
agency.
If
a
State
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
October
29,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
5
For
this
information
collection,
the
originator
conducted
a
query
on
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
database
maintained
by
OAQPS,
and
the
Applicability
Determination
Index
(
ADI)
web
site
and
the
SFIP
maintained
by
the
Office
of
Compliance.
The
originator
requested
the
support
of
Edward
Wojciechowski
in
Region
V,
who
is
the
Agency
Iron
and
Steel
Liaison.
He
provided
technical
support
to
develop
a
report
of
the
status
of
the
BOPF
shops
operating
in
the
United
States
and
determined
the
applicability
with
NSPS
Subparts
N
and
Na.
Specifically,
we
developed
a
list
of
steel
facilities
based
on
the
SFIP
which
we
used
to
develop
a
list
of
BOPF
shops.
Subsequently,
a
report
containing
the
status
of
the
BOPF
shops
was
developed
based
on
their
knowledge
of
the
sector,
the
review
of
data
from
the
United
Steel
Workers
of
America
and
OAQPS,
and
further
consultation
by
Mr.
Wojciechowski
with
some
facilities
to
confirm
data
when
needed.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
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
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
iron
and
steel
plants
with
BOPFs
that
commenced
construction,
modification,
or
reconstruction
after
June
11,
1973,
6
and
with
top­
blown
BOPFs
and
hot
metal
transfer
stations
and
skimming
stations
used
with
bottom­
blown
or
top­
blown
BOPFs
for
which
construction
was
commenced
after
January
20,
1983.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
3312,
Steel
Works,
Blast
Furnaces
(
including
coke
ovens),
and
Rolling
Mills
(
hot
rolling
purchase
steel),
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
331111,
Iron
and
Steel
Mills.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60,
Subparts
N
and
Na.

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
60,
Subparts
N
and
Na
Notification
of
construction/
reconstruction
60.7(
a)(
1)

Notification
of
anticipated
startup
60.7(
a)(
2)

Notification
of
actual
startup
60.7(
a)(
3)

Notification
of
physical
or
operational
change
60.7(
4)

Notification
of
monitoring
system
performance
commencement
60.7(
5)

Performance
test
results
60.8
(
a)

Notification
of
performance
test
60.8(
d)

Demonstration
of
continuous
monitoring
system
60.7(
a)(
5)

Semiannual
compliance
reports
of
all
measurements
over
any
3­
hour
period
that
average
more
than
10%
below
the
average
level
maintained
during
the
most
recent
performance
test
in
which
the
facility
demonstrated
compliance
with
the
standard
60.7(
c),
60.143(
c­
e)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
60,
Subparts
N
and
Na
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)
7
Recordkeeping
for
40
CFR
Part
60,
Subparts
N
and
Na
Emission
test
results,
continuous
monitoring
system
data,
performance
test
results
and
other
data
needed
to
determine
compliance
with
mass
and
visible
emission
limits.
60.7(
f),
60.145a
Time
and
duration
of
each
steel
production
cycle.
60.143(
a)

Record
the
time
and
duration
of
the
rates
or
levels
of
any
diversion
of
exhaust
gases
from
the
main
stack
servicing
the
BOPF.
60.143(
a)

Record
the
various
rates
or
levels
of
exhaust
ventilation
at
each
phase
of
the
cycle
through
each
duct
of
the
secondary
emission
capture
system.
60.143a(
a)

Record
the
time
and
duration
of
the
visible
emission
data
sets.
60.145a(
d)

Record
the
particulate
matter
concentration
(
i.
e.,
opacity
levels)
exiting
the
control
device
and
discharge
into
the
atmosphere.
60.142(
a­
b)

Record
the
pressure
loss
through
the
venturi
constriction
of
the
scrubber
continuously.
60.143(
a)(
1)

Record
the
water
supply
pressure
to
the
venturi
scrubber
control
equipment
continuously.
60.143(
a)(
2)

Records
are
required
to
be
retained
for
2
of
years.
60.7(
f)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.
8
Respondent
Activities
Install,
calibrate,
maintain,
and
operate
a
continuous
monitoring
system
for
pressure
loss
through
the
constriction
of
the
venturi
scrubber
and
the
water
supply
pressure
to
the
venturi
scrubber.

Perform
an
initial
performance
test,
Reference
Method
5
for
determination
of
particulate
matter
concentration,
Method
9
determination
of
opacity,
Method
2
for
determination
of
the
various
rates
of
exhaust
ventilation,
and
repeat
performance
tests.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
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.

Transmit,
or
otherwise
disclose
the
information.

The
information
on
BOPF
shops
gathered
by
EPA
and
the
States
is
through
inspections
and
reports
submitted
by
industry.
Presently,
several
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
enable
facilities
to
report
electronically,
which
will
further
reduce
labor
costs.
9
5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
semiannual
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database
and
the
Sector
Facility
Indexing
Project
(
SFIP).

5(
b)
Collection
Methodology
and
Management
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard
and
the
operating
conditions
of
each
steel
production
cycle
including
time
and
duration
of
process,
exhaust
ventilation
rates
of
gases,
the
pressure
loss
through
a
venturi
scrubber,
and
the
water
supply
pressure
to
the
control
equipment
and
monitor
opacity
through
the
shop
roof
or
other
building
openings
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.

Information
contained
in
the
reports
is
entered
into
AFS
which
is
operated
and
maintained
by
EPA's
OAQPS.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
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.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
10
This
rule
addresses
basic
oxygen
process
furnaces
at
iron
and
steel
facilities.
Iron
and
steel
facilities
are
large
and
very
complex
facilities.
Therefore,
there
are
no
small
businesses
affected
by
this
regulation.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Iron
and
Steel
Plants:
Basic
Oxygen
Process
Furnaces
(
40
CFR
Part
60,
Subparts
N
and
Na).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
of
the
Subparts
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
1,012
(
Total
Labor
Hours
from
Table
2).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
57.12
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2001,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
and
the
Continuing
Emission
Monitoring
System
(
CEMS).
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
11
1
One
BOPF
shop
will
become
subject
to
this
rule
and
will
incur
in
startup
cost
to
monitor
the
exhaust
gas
flow
rate
at
the
secondary
emission
control
system,
as
a
result
of
modifications
to
the
BOPF
hot
metal
transfer
system.
Startup
cost
is
based
on
the
Continuous
Emission
Monitoring
System
Cost
Model,
Version
3.0.

2
We
have
assumed
that
the
annual
operation
and
maintenance
cost
is
at
5
percent
of
the
flow
monitor
cost.

3
Pressure
flow
rate
monitors
are
necessary
to
continuously
measure
the
pressure
loss
through
the
venturi
constriction
and
the
water
supply
pressure
to
the
control
equipment,
if
a
source
uses
a
venturi
scrubber
as
the
control
equipment.
We
have
assumed
that
the
BOPF
shop
that
will
become
subject
to
this
rule
due
to
modification
will
use
venturi
scrubbers
as
the
primary
emission
control
system
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
($)
per
BOPF
shop
(
C)
Number
of
BOPF
shops
that
will
with
startup
cost
1
(
D)
Total
Startup
Cost
($)
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
per
BOPF
shop
2
(
F)
Number
of
BOPF
shops
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

Flow
meters
to
measure
exhaust
gas
flow
rate
18,000
1
18,000
$
900
4.33
$
3,897
Flow
meters
to
measure
pressure
flow
rate
3
0
0
0
$
900
4.33
$
3,897
Total
Cost
$
18,000
$
7,794
The
total
capital/
startup
costs
for
this
ICR
are
$
18,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
7,794.
This
is
the
total
of
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.
The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
12
1
One
existing
modified
BOPF
shop
will
become
subject
to
Subpart
Na.
In
addition,
we
have
assumed
for
the
burden
calculation
that
a
BOPF
shop
that
has
an
older
vessel
subject
to
Na
and
closed
within
the
past
three
years
will
reopen
and,
therefore,
will
have
to
meet
initial
requirements
(
notification
of
startup
and
performance
test).
This
is
an
average
of
0.66
new
sources
per
year.
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
25,794.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
2,361
[
see
Table
1
associated
with
Section
6(
e)].
This
cost
is
based
on
the
average
hourly
labor
rates
of
a
GS­
12
in
the
technical
category,
as
specified
by
the
Office
of
Personnel
Management
"
2002
General
Schedule"
(
excludes
locality
rates
of
pay)
times
a
1.6
benefits
multiplication
factor
for
a
total
of
$
38.30
(
GS­
12,
Step
1:
$
23.94
x
1.6)
which
accounts
for
government
overhead
expenses.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
(
A)
Number
of
BOPF
shops
per
year
to
have
initial
requirements
(
B)
Number
of
Initial
Reports
for
BOPF
shops
(
C)
Number
of
existing
BOPF
shops
subject
to
the
rule
(
D)
Number
of
regular
reports/
year
for
BOPF
shops
subject
to
this
rule
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)

NSPS
Subpart
Na
0.66
3
2
2
5.98
NSPS
Subpart
N
0
0
2
2
4
Total
0.66
1
4
9.98
The
number
of
total
respondents
is
4.33.
This
number
is
usually
the
sum
of
Column
A
and
13
Column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
9.98.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
are
$
57,777.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Respondent
Burden
and
Cost,
NSPS
for
Iron
and
Steel
Plants:
Basic
Oxygen
Process
Furnaces
(
40
CFR
Part
60,
Subparts
N
and
Na).

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
25,794.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.

6(
f)
Reasons
for
Change
in
Burden
The
change
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
decrease
in
labor
hours
from
the
most
recently
approved
ICR
is
due
to
a
decrease
in
the
number
of
basic
oxygen
process
furnace
(
BOPF)
shops
operating
in
the
United
States
and
more
accurate
information
on
the
status
of
the
BOPF
shops.
The
industry
labor
rate
used
in
the
previous,
active
ICR
did
not
account
for
employees
benefits
that
would
increment
the
labor
rate
by
110
percent,
as
was
used
for
this
renewal
of
the
ICR.
In
calculating
the
number
and
status
of
the
BOPF
shops,
the
originator
used
an
initial
list
on
the
iron
and
steel
sector
from
the
Sector
Facility
Indexing
Project
(
SFIP)
web
site.
Subsequently,
the
originator
developed
a
table
on
the
status
of
the
BOPF
shops
with
the
technical
support
of
Edward
Wojciechowski,
the
Agency
Iron
and
Steel
Liaison,
who
reviewed
the
table
and
provided
comments
based
on
his
knowledge
of
the
sector,
existing
data
on
BOPFs
developed
by
the
United
Steelworkers
of
America
and
the
Office
of
Air
Quality
Planning
and
Standards,
and
through
his
consultation
with
a
source's
environmental
affairs
when
there
were
any
questions
on
the
available
data
or
any
data
gaps
for
the
source.

6(
g)
Burden
Statement
14
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
standards
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

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
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
