SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
part
63,
subpart
XXX)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX).

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
regulations
published
at
regulatory
citation
was
proposed
on
August
4,
1998,
promulgated
on
May
20,
1999,
and
amended
most
recently
on
March
22,
2001.
The
promulgated
rule
applies
to
new
and
existing
ferroalloy
production
facilities
that
manufacture
ferromanganese
and
silicomanganese,
and
that
are
major
sources
of
hazardous
air
pollutants
(
HAPs)
emissions,
or
are
co­
located
at
major
sources
of
HAPs.
The
following
affected
facilities
at
ferroalloy
production
plants
are
subject
to
this
NESHAP
rule:
submerged
arc
furnaces;
metal
oxygen
refining
(
MOR)
process;
crushing
and
screening
operations;
and
fugitive
dust
sources.
New
sources
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
XXX.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners/
operators
of
the
affected
facilities.
They
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.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
affected
facilities
subject
to
NESHAP.

Any
owner/
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

In
the
development
of
this
Information
Collection
Request
(
ICR),
we
reviewed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
(
TOC)
section
on
the
active
ICR
which
are
as
follows:

OMB
notes
that
EPA
has
not
requested
any
(
non­
labor)
cost
burden
for
this
collection.
EPA
should
assess
whether
there
are
any
2
non­
labor
costs
associated
with
this
collection,
including
monitoring
equipment
or
record
storage,
and
submit
an
information
change
worksheet
if
appropriate
to
correct
the
cost
burden
of
the
collection.
OMB
notes
that
under
the
terms
of
the
Government
Paperwork
Elimination
Act,
EPA
should
provide
a
means
for
the
respondent
to
report
electronically
by
October
2003,
to
the
extent
practicable.

There
are
approximately
16
facilities
listed
in
EPA's
database
systems
that
are
potentially
subject
to
this
regulation.
However,
we
have
determined
that
there
is
only
one
ferroalloy
production
plant
currently
subject
to
the
standard
because
the
remaining
plants
are
minor
sources
of
hazardous
air
pollutants
not
subject
to
the
standard.
We
have
assumed
that
no
additional
respondents
will
become
subject
to
this
regulation
in
the
next
three
years
since
the
production
of
ferroalloys
has
continued
to
decrease
in
this
nation
over
the
last
decade.
The
estimates
and
assumptions
are
based
on
recent
information
gathered
from
industry
by
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS);
the
EPA's
Air
Facility
System
(
AFS)
database
through
the
Online
Tracking
Information
System
(
OTIS);
review
of
information
available
on
the
active
ICR;
and
consultation
with
the
Ohio
Environmental
Protection
Agency.

The
facility
subject
to
this
rule
has
the
ability
to
comply
with
the
reporting
requirements
electronically.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner/
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
3
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
particulate
matter
and
metallic
HAP
emissions
from
ferroalloy
production
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
XXX.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standards
ensure
compliance
with
the
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
for
air
pollution
devices
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standards.
Continuous
emission
monitors
are
used
to
ensure
that
the
control
equipment
is
operating
properly
and
therefore,
ensure
compliance
with
the
standards
at
all
times.
During
the
performance
test,
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
compliance
in
place
of
a
continuous
emission
monitor.

The
notifications
required
in
the
standards
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;
leaks
are
being
detected
and
repaired;
and
the
standards
are
being
met.
The
performance
test
may
also
be
observed.

The
required
semiannual
compliance
status
reports
and
quarterly
excess
emissions
reports
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation/
maintenance
procedures
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
XXX.

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
its
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
4
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,
69
FR
29718
on
May
25,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
several
sources
were
used
to
obtain
updated
information
on
the
number
of
sources
and
on
the
assumptions
made
to
determine
the
industry
burden.
As
discussed
in
Section
1(
b),
the
number
of
sources
was
estimated
by
consulting
Conrad
Chin,
the
OAQPS
rule
lead,
who
had
recent
information
on
this
source
category.
We
also
consulted
Kay
Gilmer
at
the
Ohio
EPA
(
704­
380­
5257)
to
review
the
assumptions
made
in
this
ICR.
In
addition,
queries
were
conducted
on
the
EPA's
AFS
database
through
the
MACT
Tool
under
OTIS.

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
part
1320,
section
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
5
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
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
the
owners
or
operators
of
all
new
and
existing
ferroalloys
production
facilities
that
are
major
sources
or
are
colocated
at
major
sources.
The
affected
facilities
produce
either
ferromanganese
or
silicomanganese.
The
United
States
Standard
Industrial
Classification
(
SIC)
code
for
the
respondents
affected
by
the
standards
is
3313,
"
Electrometallurgical
Products,
Except
Steel"
which
corresponds
to
The
North
American
Industry
Classification
System
(
NAICS)
code
331112,
"
Electrometallurgical
Ferroalloy
Product
Manufacturing".

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
part
63,
subpart
XXX).

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
applicability
if
an
area
source
becomes
subject
to
the
rule
63.9
(
b)(
1)(
ii);
63.1658(
a)

Notification/
application
for
approval
of
construction/
reconstruction
63.5(
a,
b,
d
and
e);
63.9(
b)(
1)(
iii);
63.1658(
a)
6
Notification
Reports
Request
for
an
extension
of
compliance
status
63(
d);
63.1658(
b)

Notification
that
source
is
subject
to
special
compliance
requirements
63.10(
d);
63.1658(
c)

Notification
of
performance
test
63.9(
e);
63.1658(
d)

Notification
of
opacity
and
visible
emission
observations
63.1658(
e)

Reschedule
of
initial
performance
test
63.7(
b)(
2)

Notification
of
compliance
status
63.9(
h);
63.1658(
f)

Reports
Results
of
performance
tests
63.10(
d)(
2);
63.1659(
a)(
2)

Results
of
opacity
or
visible
emission
observations
63.10(
d)(
3)

Progress
reports
if
source
has
received
an
extension
for
compliance
63.10(
d)(
4)

Immediate
and
periodic
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
i­
ii);
63.1659(
a)(
4)

Continuous
monitoring
systems
(
CMS)
performance
evaluations
reports
63.10(
e)(
2)

Quarterly
excess
emissions
reports
and
CMS
performance
report,
unless
a
semiannual
frequency
has
been
approved
63.10(
e)(
3)(
i);
63.1659(
b)(
6)

Request
to
reduce
frequency
of
reporting
to
semiannual
63.10(
e)(
3)(
ii)

Waiver
of
recordkeeping
and
reporting
63.10(
f)

A
source
must
keep
the
following
records:

Recordkeeping
Maintain
records
of
all
information
necessary
to
demonstrate
compliance
with
standard
including
the
occurrence
and
duration
of
startup,
shutdown,
or
malfunction
of
operations
63.10(
a­
c);
63.1660(
a)(
2)
7
Recordkeeping
Specific
requirements
include
maintaining
records
of
process
or
control
device
(
e.
g.,
capture
system
and
venturi
scrubbers)
parameters;
bag
leak
detention
systems;
certification
that
monitoring
devices
are
accurate;
and
records
of
the
implementation
and
corrective
actions
associated
with
the
startup,
and
shutdown
and
malfunction
plan
63.1660(
b)

Maintain
records
for
a
total
of
five
years
with
the
most
recent
two
years
being
kept
on
site
63.10(
b)(
2);
63.1660(
a)(
2)

Electronic
Reporting
Currently,
one
respondent
is
using
monitoring
equipment
that
automatically
records
parameter
data,
e.
g.,
pressure
drop
across
the
venturi
scrubber,
monitoring
parameter
data
for
the
capture
systems,
and
bag
leak
detection
systems
alarms.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.
In
addition,
the
respondent
is
able
to
meet
the
reporting
requirements
of
the
rule
by
transmitting
data
including
reports
electronically
to
the
regulatory
agencies.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Monitor
shop
opacity
through
one
of
the
monitoring
options
including:
1)
monitor
control
system
fan
motor
amperes
and
capture
system
damper
positions
once
per
shift;
2)
install,
calibrate,
maintain,
and
operate
CMS
for
volumetric
flow
rate
through
each
separately
ducted
hood;
and
3)
install,
calibrate,
maintain,
and
operate
for
volumetric
flow
rate
at
the
inlet
of
the
air
pollution
control
device
and
capture
system
damper
positions
once
per
shift.

Monitor
baghouse
operations
on
a
regular
basis,
for
example,
observe
on
a
daily
basis
for
the
presence
of
visible
emissions
at
baghouses,
bag
leak
detection
system,
and
conduct
periodic
visual
inspections
to
ensure
it
is
working
properly
Monitor
pressure
drop
and
liquid
supply
pressure
across
the
venturi
scrubber
Perform
initial
performance
test,
Reference
Method
9
of
40
CFR
part
60
for
opacity
observations,
Reference
Method
5
to
determine
particulate
matter
concentration
and
volumetric
flow
rate
for
baghouses
without
stack,
and
repeat
performance
tests
if
necessary.
8
Respondent
Activities
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.

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
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
9
for
use
in
compliance
and
enforcement
programs.
The
quarterly
excess
emissions
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
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.

The
records
required
by
this
regulation
must
be
retained
by
the
owner/
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
The
NESHAP
for
ferroalloys
production
facilities
is
applicable
to
only
major
sources.
There
are
no
small
businesses
affected
by
this
regulation
at
this
time.
In
addition,
during
the
rule
development
process,
the
EPA
closely
reviewed
the
existing
permit
conditions
at
each
of
the
two
existing
facilities,
where
feasible,
incorporated
similar,
if
not
identical,
requirements
in
the
final
rule.
The
Agency
considers
the
final
rule
requirements
the
minimum
needed
to
ensure
compliance
with
the
standards.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost:
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
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
10
and
reporting
requirements
is
estimated
to
be
584
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge,
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
information
collection
activities
required
by
the
subject
standard(
s)
are
labor
costs.
There
are
no
capital
and
startup
costs
for
this
ICR
since
we
have
assumed
that
the
only
source
subject
to
this
regulation
has
already
purchased
the
necessary
equipment
to
comply
with
this
rule.
In
addition,
we
have
assumed
that
there
are
no
operation
and
maintenance
costs
for
use
of
continuous
monitoring
systems
since
the
monitors
required
by
the
rule
are
typically
used
by
the
source
as
part
its
normal
operations
to
ensure
that
the
control
devices
are
functioning
properly.
Any
other
costs
associated
with
photocopying
and
postage
are
assumed
to
be
negligible.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
costs.
There
are
no
capital
or
startup
costs,
and
operation
and
maintenance
(
O&
M)
costs
for
this
ICR.
This
is
reflected
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs,
and
in
block
14(
b),
Total
annual
costs
(
O&
M),
respectively.

Therefore,
the
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
zero.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
11
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
1,638.
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
and
Cost
for
The
Federal
Government:
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX),
attached.
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
only
one
existing
ferroalloy
production
facility
is
currently
subject
to
the
standard,
and
no
new
or
existing
facility
is
expected
to
become
subject
to
this
regulation
in
the
next
three
years.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
1
0
0
1
2
0
1
0
0
1
3
0
1
0
0
1
Average
0
1
0
0
1
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

.
To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
there
is
an
average
of
one
respondent
over
the
three­
year
period
of
this
ICR.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.
12
Total
Annual
Responses
(
A)
Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Initial
Notifications
0
5
N/
A
0
Notification
of
Performance
Test
0
1
N/
A
0
Notification
of
Compliance
Status
1
1
N/
A
1
Quarterly
Reports
1
4
N/
A
4
Semiannual
Reports
1
2
N/
A
2
Total
7
*
Initial
Notifications
include:
applicability;
initial
performance
test,
extension
of
compliance;
the
source
is
subject
to
special
compliance
requirements;
and
opacity
and
visible
emission
observations.

The
number
of
Total
Annual
Responses
is
seven.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
Note
that
two
respondents
have
been
double­
counted
in
the
above
table
because
they
have
both
existing
affected
facilities
and
new
affected
facilities.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
37,261.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX),
attached.

There
are
no
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

The
average
annual
Agency
burden
and
cost
over
next
three
years
are
estimated
to
be
91
labor
hours
at
a
cost
of
$
1,638.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX),
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.
13
(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
37,214.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX),
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
83
hours
per
response.

There
are
no
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
subject
to
the
NESHAP
for
Ferroalloys
Production.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
91
labor
hours
at
a
cost
of
$
1,638.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX),
attached.
6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
burden
hours
for
industry
has
decreased
from
746
to
584
hours.
For
the
renewal
of
this
ICR,
there
is
no
burden
associated
with
the
initial
notifications
and
initial
compliance
demonstrations
required
for
the
NESHAP
for
ferroalloys
production
since
the
compliance
date
for
this
rule
has
passed.
In
addition,
there
is
no
burden
associated
with
the
development
of
the
source
record
system
including
the
startup,
shutdown
and
malfunction
plan;
the
fugitive
dust
plan;
and
the
control
equipment/
maintenance
plan.
However,
the
total
cost
has
increased
from
$
20,761
to
$
37,261
due
to
an
increase
in
the
labor
rates.
The
Federal
government's
burden
is
also
lower
due
to
not
needing
to
review
initial
compliance
reports.

As
in
the
active
ICR,
there
are
no
annualized
capital
and
startup
costs
and
no
operation
and
maintenance
cost
associated
with
continuous
monitoring
equipment.
We
have
assumed
that
any
monitoring
equipment
required
to
comply
with
the
NESHAP
has
been
purchased
prior
to
the
rule
compliance
date.
In
addition,
the
monitors
required
by
the
rule
are
typically
used
by
the
source
as
part
its
normal
operations
to
ensure
that
the
control
devices
are
functioning
properly.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
83
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
14
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
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0004,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0004
and
OMB
Control
Number
2060­
0391
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1.
Annual
Respondent
Burden
and
Cost:

NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Silicomanganese
(
40
CFR
Part
63,
Subpart
XXX)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
c
A.
Read
instructions
Included
in
5C
B.
Required
activities
Included
in
5C
C.
Create
Information
Included
in
5C
D.
Gather
Existing
Information
Included
in
5C
E.
Write
report
c,
d
i.
Initial
notifications
N/
A
ii.
Notification
of
reconstruction/
modification
N/
A
16
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
iii.
Notification
of
annual
performance
test
2
1
2
1
2.0
0.10
0.20
$
146.75
iv.
Notification
of
opacity
and
visible
observations
2
1
2
1
2.0
0.10
0.20
$
146.75
v.
Report
of
performance
test
results/
opacity
observations
5
1
5
1
5.0
0.25
0.50
$
367.28
vi.
Periodic
start/
shutdown/
malfunction
reports
10
2
20
1
20.0
1.00
2.00
$
1,467.50
vii.
Capture
hood
inspection
report
4
2
8
1
8.0
0.40
0.80
$
587.00
viii.
Summary
report
of
maintenance
records
4
2
8
1
8.0
0.40
0.80
$
587.00
ix.
Fugitive
dust
operations
report
4
2
8
1
8.0
0.40
0.80
$
587.00
x.
Quarterly
excess
emissions
reports
4
4
16
1
16.0
0.80
1.60
$
1,174.00
xi.
Annual
compliance
status
certification
2
1
2
1
2.0
0.10
0.20
$
146.75
5.
Recordkeeping
Requirements
17
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
A.
Read
instructions
Included
in
5C
B.
Plan
activities
10
1
10
1
10.0
0.5
1
$
733.75
C.
Implement
activities:
e
i.
Control
devices:

Annual
Performance
tests
for
the
control
devices
associated
with
submerged
arc
furnaces
50
1
50
1
50.0
2.50
5.00
$
3,668.75
Baghouse
monitoring
include:

daily
Weekly
Monthly
Quarterly
Semiannualy
0.5
350
175
1
175.0
8.75
17.5
$
12,840.63
0.1
50
5
1
5.0
0.25
0.50
$
367.28
0.1
12
1.2
1
1.2
0.06
0.12
$
88.05
0.1
4
0.4
1
0.4
0.02
0.04
$
29.41
0.1
2
0.2
1
0.2
0.01
0.02
$
14.68
­
Parameter
monitoring:
fan
motor
amperes,
damper
positions
and
pressure
drop
0.1
1050
105
1
105.0
5.25
10.5
$
7,704.38
18
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
ii.
Monthly
capture
system
inspection
2
12
24
1
24.0
1.2
2.4
$
1761.00
iii.
Opacity
violation/
scrubber
2
1
2
1
2.0
0.01
0.02
$
14.68
iv.
Opacity
violation/
baghouse
2
20
40
1
40.0
2.0
4.00
$
2,935.00
v.
Monitoring
violation/
capture
system
2
12
24
1
24.0
1.2
2.4
$
1761.00
D.
Develop
record
system
c,
g
N/
A
E.
Time
to
enter
and
transmit
information
Included
in
5C
F.
Time
to
train
personnel
N/
A
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
N/
A
H.
Time
to
disclose
information
N/
A
I.
Time
for
audits
N/
A
Labor
hours
and
cost
507.80
25.39
50.78
$
37,260.71
TOTAL
LABOR
BURDEN
AND
COST
(
Rounded)
583.97
$
37,261
19
Assumptions:

a
There
is
only
one
ferroalloy
production
facility
currently
subject
to
the
standard.
We
have
assumed
that
no
additional
respondents
will
become
subject
to
this
regulation
since
no
industry
growth
is
expected
in
the
next
three
years.

b
This
ICR
uses
the
following
labor
rates:
$
95.32
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.60
per
hour
for
Technical
labor,
and
$
40.09
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
are
from
column
1,
"
Total
compensation."

These
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c
We
have
assumed
that
the
source
has
complied
with
the
initial
notification
requirements
and
the
initial
compliance
demonstration
requirements
since
the
effective
date
of
the
rule
has
passed.
In
addition,
we
have
assumed
that
the
source
has
already
developed
its
record
system
including
the
startup,
shutdown
and
malfunction
plan;
the
fugitive
dust
plan;
and
the
control
equipment/
maintenance
plan.

d
Periodic
reports
include
quarterly
emissions
reports
and
semiannual
reports
that
addresses
the
requirements
for
opacity­
related
reports;
performance
test
results
reports;
startup/
shutsdown/
malfunction
reports;
capture
hood
inspection
reports;
and
fugitive
dust
operations
reports.

e
The
types
of
monitoring
activities
required
by
this
NESHAP
regulation
includes:
1)
monitoring
of
baghouses
systems
on
a
daily
(
visible
observations
and
pressure
drop
accross
baghouse),
weekly
(
inspection
of
dust
hoppers),
monthly
(
inspection
of
bags
cleaning
mechanism),
quarterly
(
inspection
of
baghouse
integrity
and
bags
tension)
and
semiannual
(
inspection
of
fans
for
wear)
basis,
and
the
implementation
of
a
bag
leak
detection
system;
average
hourly
scrubber
pressure
drop
(
automatic
device
is
used)
monitoring
for
venturi
scrubbers;
and
either
monitoring
of
control
system
fan
motor
ampares
and
capture
system
damper
positions
once
per
shift,
or
monitoring
of
volumetric
flow
rate
through
each
separately
ducted
hood
or
at
the
inlet
of
the
air
pollution
control
device
using
a
continuous
monitoring
system
and
of
the
capture
system
damper
positions
once
per
shift,
if
the
source
is
subject
to
the
shop
opacity
standard.

f
Sources
are
required
to
conduct
annual
performance
test
for
the
air
pollution
control
devices
and
vent
stacks
to
determine
particulate
matter
concentration
and
volumetric
flow
rate
to
demonstrate
compliance
with
the
emission
standard.
Reference
Method
5
is
used
to
determine
particulate
matter
concentration
and
volumetric
flow
rate
for
baghouses
without
stack.
Sources
are
also
required
to
conduct
initial
opacity
observations
of
the
shop
building
using
Reference
Method
9
to
demonstrate
compliance
with
the
opacity
standards.

h
Sources
are
required
to
maintain
records
of:
1)
process
or
control
device
parameters;
2)
bag
leak
detention
systems;
3)
maintenance
plan
for
air
pollution
control
devices
(
e.
g.,
capture
system
and
venturi
scrubbers);
4)
certification
that
monitoring
devices
are
accurate;
and
5)
the
implementation
and
corrective
actions
taken
related
to
the
startup,
and
shutdown
and
malfunction
plan
and
the
fugitive
dust
control
plan.
20
Table
2.
Annual
Burden
and
Cost
for
The
Federal
Government:

NESHAP
for
Ferroalloys
Production:
Ferromanganese
and
Siliconmanganese
(
40
CFR
Part
63,
Subpart
XXX)

Activity
(
A)
EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,
$
a
A.
Review
reports:
c&
d
i.
Initial
Notifications
N/
A
ii.
Notification
of
reconstruction/
modification
N/
A
iii.
Notification
of
Performance
Test
1
1
1
1
1.0
.05
0.10
$
45.49
iv.
Report
of
performance
test
results/
opacity
observations
5
1
5
1
5.0
0.25
0.50
$
227.44
v.
Semiannual
summary
reports
including
periodic
start/
shutdown/
malfunction
reports;
capture
hood
inspection
report;
summary
report
of
maintenance
records;
and
fugitive
dust
operations
report
10
2
20
1
20.0
1.00
2.00
$
909.76
21
Activity
(
A)
EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,
$
a
vi.
Quarterly
excess
emissions
reports
2
4
8
1
8.0
0.4
0.8
$
363.90
xi.
Annual
compliance
status
certification
2
1
2
1
2.0
0.1
0.2
$
90.98
B.
Attend
performance
tests/
opacity
observations
e
25
1
25
0
0.0
0.0
0.0
$
0.00
Total
Annual
Cost
$
1,637.57
TOTAL
ANNUAL
COST
(
rounded)
$
1,638
Assumptions:

a
There
is
only
one
ferroalloy
production
facility
currently
subject
to
NESHAP,
subpart
XXX.
We
have
assumed
that
no
additional
respondents
will
become
subject
to
this
regulation.

b
Costs
are
based
on
the
following
hourly
rates:
Managerial
at
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6);
Technical
at
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6);

Clerical
at
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

c
We
have
assumed
that
the
source
has
comply
with
the
initial
notification
requirements
and
the
initial
compliance
demonstration
requirements
since
the
effective
date
of
the
rule
has
passed.
In
addition,
we
have
assumed
that
the
source
has
already
developed
its
record
system
including
the
startup,
shutdown
and
malfunction
plan;
the
fugitive
dust
plan;
and
the
control
equipment/
maintenance
plan.

d
Periodic
reports
include
quarterly
emissions
reports
and
semiannual
reports
that
addresses
the
requirements
for
opacity­
related
reports;
performance
test
results
reports;
startup/
shutsdown/
malfunction
reports;
capture
hood
inspection
reports;
and
fugitive
dust
operations
reports.

e
We
have
assumed
that
the
regulatory
agency
will
not
attend
performance
tests
or
opacity
observations.

N/
A
=
Not
applicable.
