Table
1:
Annual
Agency
Burden
and
Cost,
NSPS
for
Iron
and
Steel
Plants:

Basic
Oxygen
Process
Furnaces
(
40
CFR
Part
60,
Subparts
N
and
Na)

(
A)
(
B)
(
C)
(
D)
(
E)

Code
EPA
hours/
Occurrences/
EPA
hours/
Plants/
Hrs/

Activity
Occurrence
plant/
year
plant
year
year
a
year
b
Initial
Requirements:
c,
d
Performance
test
24
1
24
0.33
7.92
Notification
requirements
4
1
4
0.33
1.32
Review
performance
test
results
8
1
8
0.33
2.64
Regular
Requirements:

Semiannual
reports
e
5
2
10
4.33
43.30
TOTAL
ANNUAL
HOURS
55.18
Travel
Expenses
(
1
person
*
0.66
plants/
year
f
*
3
days/
plant
*
$
75
per
diem)
+
($
150
round
trip/
plant
*
.66
plants/
year)
=
$
247.50/
year
Salary
(
1
person
*
55.18
hours/
year
*
$
38.30/
hour)
g

$
2,113.39/
year
TOTAL
ANNUAL
COST
=
$
2,360.89
ASSUMPTIONS
a
There
are
only
3
BOFs
shops
out
of
19
BOFs
shops
at
17
facilities
operating
in
the
United
States,
subject
to
NSPS
Subpart
N
and
Na.
A
source
is
subject
to
NSPS
Subpart
N
if
constructed,
reconstructed
or
modified
after
June
11,
1973,
but
on
or
before
January
20,
1983.
A
source
is
subject
to
NSPS
Subpart
Na
if
constructed,
reconstructed
or
modified,
including
furnaces,
skimming
stations
and
hot
metal
transfer
stations,
after
January
20,
1983.
There
is
an
average
of
2.2
vessels
per
BOPF
shop.

b
E
=
C*
D
c
Assume
that
one
basic
oxygen
process
furnace
(
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
and
will
submit
initial
notifications
and
conduct
performance
test.

d
Assume
that
the
BOPF
shop
that
was
closed
during
the
period
of
the
active
ICR,
which
has
a
vessel
subject
to
NSPS
Subpart
Na
that
will
reopen
within
the
next
six
months
and
will
have
to
submit
an
initial
notification
and
conduct
a
performance
test.

e
Assume
that
all
four
existing
BOF
shops
(
including
the
shop
that
will
reopen
within
the
first
year
of
this
ICR)
subject
to
this
rule
will
submit
semiannual
reports
with
all
measurements
over
any
three
hour
period
(
e.
g.,
of
low
pressure)
that
average
more
than
10
percent
below
the
averages
during
the
most
recent
performance
test.

f
Asume
that
regulators
will
oversee
the
initial
performance
test
of
the
BOF
shop
that
becomes
subject
to
this
rule
due
to
modifications
and
of
the
BOF
shop
that
has
a
vessel
subject
to
this
rule
and
will
reopen
during
the
first
year
of
this
ICR
(
a
total
of
two
tests
or
0.66
tests/
year).

g
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
($
23.94
x
1.6)
which
accounts
for
government
overhead
expenses.
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)

Occurrences/
Hours/
Cost
Codes
Hours
per
respondent/
respondent/
Respondents
Hours
per
occurrence
year
year
per
year
per
year
year
b
(
A)
(
B)
(
C
=
A
*
B)
(
D)
a
(
E
=
C
*
D)
(
F=
E*$
57.12)

1.
APPLICATIONS
_____________________________
Not
Applicable___________________________________

2.
SURVEY
AND
STUDIES
_________________________
___
Not
Applicable____________________________________

3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
1
1
1
0.33
0.33
18.85
B.
Required
Activities
Initial
performance
test
c
194
1
194
0.33
64.02
3,656.82
Performance
test
d
194
1
194
0.33
64.02
3,656.82
Daily
monitoring
of
operations
Included
in
4E
Monitoring
Device
annual
checkups
/
recalibration
Included
in
4E
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
requirements
c
2
2
4
0.66
2.64
150.80
Report
of
performance
test
c,
d
32
1
32
0.66
21.12
1,206.37
Semiannual
reports
e
10
2
20
4.33
86.60
4,946.59
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
_____________________________
Not
Applicable___________________________________

E.
Time
to
Enter
Information
Records
of
operating
parameters
of
CMS
­
Exhaust
ventilation
rate
f,
g
0.25
365
91.25
4.33
395.11
22,568.68
­
Pressure
drop
and
pressure
flow
(
venturi
scrubbers)
f,
h
0.25
365
91.25
3.00
273.75
15,636.60
Recalibrate
and
check
monitoring
devices
i
8
1
8
4.33
34.64
1,978.64
F.
Train
Personnel
Certification
of
opacity
observer
j,
k
8
2
16
4.33
69.28
3,957.27
G.
Audits
______________________________
Not
Applicable
_________________________________

5.
TOTAL
ANNUAL
BURDEN
1,011.51
57,777.44
continuation
.
.
.

ASSUMPTIONS
a
There
are
only
3
BOFs
shops
out
of
19
BOFs
shops
at
17
facilities
currently
operating
in
the
United
States,
subject
to
NSPS
Subparts
N
and
Na.
A
source
is
subject
to
NSPS
Subpart
N
if
constructed,
reconstructed
or
modified
after
June
11,
1973
but
on
or
before
January
20,
1983.
A
source
is
subject
to
NSPS
Subpart
Na
if
constructed,
reconstructed
or
modified,
including
furnaces,
skimming
stations
and
hot
metal
transfer
stations,
after
January
20,
1983.
We
have
assumed
that
there
is
an
average
of
2.2
vessels
per
BOF
shop.

b
Assume
a
technical
labor
rate
of
$
57.12
per
hour.
This
rate
is
from
the
United
States
Department
of
Labor,
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
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

c
Assume
that
one
BOF
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
and
will
submit
initial
notifications
and
conduct
performance
test..

d
Assume
that
one
of
the
two
BOFs
shops
that
have
been
closed
within
the
past
three
years
and
will
reopen
within
the
first
year
of
this
ICR
which
has
a
vessel
subject
to
NSPS
Subpart
Na
will
be
require
to
submit
initial
notifications
and
conduct
a
performance
test
.

e
Assume
that
all
four
existing
BOFshops
(
including
the
one
that
will
reopen
within
the
first
year
of
this
ICR)
subject
to
this
rule
will
submit
semiannual
reports
with
all
measurements
over
any
three
hour
period
(
e.
g.,
of
low
pressure)
that
average
more
than
10
percent
below
the
averages
during
the
most
recent
performance
test.

f
Assume
operation
365
days
per
year
as
specified
in
the
NSPS
review
document.
In
addition,
we
have
assume
that
the
BOPF
shop
that
will
become
subject
to
this
rule
uses
a
venturi
scrubber
for
primary
emission
control.

g
Assume
that
all
four
BOFP
shops
and
the
BOF
that
will
become
subject
to
this
rule
would
need
to
meet
the
monitoring
requirements.

h
Assume
that
two
operating
BOF
shops
subject
to
this
rule
and
one
shop
that
will
reopen
during
the
first
year
of
this
ICR
rule
use
venturi
scrubbers
as
primary
emission
control
systems
and
have
reportable
low
pressure.
The
other
operating
BOF
shop
subject
to
this
rules
uses
a
electrostatic
precipitator
as
the
primary
emission
control.

i
Assume
that
BOFs
shops
subject
to
this
rule
will
have
to
recalibrate
monitoring
devices
on
an
average
of
twice
a
year
to
keep
them
functioning
well.
Sources
are
required
to
recalibrate
and
check
monitoring
devices
at
least
annually,
as
required
by
NSPS,
Subpart
N
and
Na
and
at
other
times,
if
required.

j
Assume
that
all
BOFP
shops
subject
to
this
rule
will
have
one
certified
opacity
observer.
Certification
of
opacity
observers
is
valid
for
a
six
month
period
according
to
Method
k.
Only
qualify
observers
are
allowed
to
do
opacity
observations
during
performance
tests.
