	SF-83 SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Integrated Iron and Steel Manufacturing 

(40 CFR part 63, subpart FFFFF) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Integrated Iron and Steel Manufacturing (40 CFR part 63,
subpart FFFFF) (Renewal)

1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Integrated Iron and Steel Manufacturing were proposed on   SEQ
CHAPTER \h \r 1 July 13, 2001 (66 FR 36835), and promulgated on May 20,
2003 (68 FR 27645).  The proposed amendments were published August 30,
2005 (70 FR 51306).  These standards apply to new and existing sinter
plants, blast furnaces, and basic oxygen process furnace (BOPF) shops at
integrated iron and steel manufacturing facilities that are major
sources of hazardous air pollutants (HAPs), or are collocated at major
sources.  This information is being collected to assure compliance with
40 CFR part 63, subpart FFFFF. 

Owners and operators of affected sources are subject to the monitoring,
recordkeeping and reporting requirements of 40 CFR part 63, subpart A,
the General Provisions, unless specified otherwise in the regulation. 
This rule requires sources to submit initial notifications, conduct
performance tests if the source is using an add-on control device, and
submit periodic compliance reports.  In addition, sources are required
to maintain records of the occurrence and duration of any start-up,
shutdown, or malfunction in the operation if using an add-on control
device; any period during which the monitoring system is inoperative;
parametric monitoring data; system maintenance and calibration; and work
practices to demonstrate initial and ongoing compliance with the
regulation.  

In the development of this Information Collection Request (ICR), we
reviewed the Office of Management and Budget (OMB) “Terms of
Clearance” (TOC) section of the active ICR. There are no TOC.

There is an average of 18 iron and steel manufacturing facilities in 10
States operating in the United States that we believe are major sources
that would be subject to the rule requirements.  In addition, we have
assumed that no new facilities will become subject to this regulation. 
This information was confirmed with the rule lead addressing this source
category at the Office of Air Quality Planning and Standards (OAQPS),
information available in the active ICR, EPA database for the Clean Air
Program, and existing background information on the industry gathered
during rule development.  

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The Clean Air Act (CAA) provides authority to the Agency to establish
standards to control air pollution and to ensure compliance with
promulgated regulations through adequate recordkeeping and reporting by
the affected industries (i.e., respondents).  The regulations include
the New Source Performance Standards (NSPS) under section 111 of the
Act, the National Emission Standards for Hazardous Air Pollutants (
NESHAP) which includes the original NESHAP standards and the more recent
Maximum Achievable Control Technology (MACT) or NESHAP-MACT standards
under section 112 of the Act, and emission guidelines for the designated
types incinerators under section 129 of the CAA.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards are used
by regulatory agencies, the public and the regulated community for a
variety of reasons including the determination of the respondent’s
compliance status, analytical studies to demonstrate compliance trends,
and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting are also used to: 1) certify
compliance with the regulations; 2) determine the respondent’s
compliance with the designated emission limitations; 

3) notify regulatory agencies when a standard is violated; 4) evaluate
continuous compliance through the use of emission or operational
parameter monitors; and 5) ensure that plant personnel are following the
required procedures and are periodically trained, as indicated.

3.  Nonduplication, Consultations, and Other Collection Criteria

3(a)  Nonduplication

The standards do not require duplication in the collection and reporting
of information.  If the subject standards have not been delegated, the
information is sent directly to the appropriate Environmental Protection
Agency (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.

 

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 (70 FR55368) on September 21,
2005.  No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

It is our policy to carefully review any comments received since the
last ICR renewal including those submitted in response to the first
federal register notice and respond appropriately.  In this case, no
comments were received.  The Agency’s internal industry experts have
been consulted.  The Agency’s internal data sources and any
projections of industry growth over the next three years have also been
considered.

The primary source of information as reported by industry, in compliance
with the recordkeeping and reporting provisions in the standard, is the
AFS (Air Facility Subsystem) which is operated and maintained by EPA's
Office of Compliance.  AFS is EPA’s database for the collection,
maintenance, and retrieval of all compliance data.  Approximately 18
respondents are currently subject to the regulation, and our
consultations with Agency industry experts regarding the growth rate for
the industry indicated that no additional respondents will become
subject to the regulation over the next three years.

It should be noted that the respondents, the industry trade
associations, and other interested parties were provided an opportunity
to comment on the burden associated with the standard as it was being
developed and the standard has been previously reviewed to determine the
minimum information needed for compliance purposes. 

  

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

Neither the reporting nor recordkeeping requirements violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR part 1320, section 1320.5.  However, most NESHAP standards and a few
NSPS standards require records to be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the permit
program at 40 CFR part 70, and the five-year statute of limitations on
which the permit program is based.  

The retention of records for five years allows EPA to establish the
compliance history of the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. If
records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance.

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

The recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The Standard Industrial Classification (SIC) code(s) and corresponding
North American Industry Classification System (NAICS) code(s) for the
respondents are listed below. 



Category	SIC 

code	NAICS code	Examples of regulated entities

Iron and Steel Mills	3312	331111	Integrated iron and steel mills, steel
companies, sinter plants, blast furnaces, basic oxygen process furnace
(BOPF) shops





This table is not meant to be exhaustive, but rather provides a guide
for readers regarding the entities likely to be regulated by this
standard.  To determine whether the standard applies to a particular
entity, review the applicability provisions in the standard.

4(b)  Information Requested

(i)  Data Items

Notification Reports



Applicability	

63.9(b), 63.7840(a)



Commencement of construction or reconstruction	

63.9(b)(4) ), 63.7840(a)



Actual startup	

63.9(b)(4) ), 63.7840(a)



Intention to construct/reconstruct	

63.9(b)(4)-(5) ), 63.7840(a)



Compliance dates/extension 	

63.9(c) ), 63.7840(a)



Performance test/opacity observations	

63.9(e) ), 63.7840(a)



Compliance status	

63.9(g) ), 63.7840(a)



Reports

Application for approval of the construction or reconstruction of a new
major affected source, or reconstruction of a major affected source
63.5(6)(d)

Performance test results	63.10(d)(2),

63.5755

Operation and maintenance plan	63.7800(b)

Startup, shutdown and malfunction plan	63.6(e)(3), 63.7841(c)

Periodic startup, shutdown and malfunction reports	63.10(d)(5)(i),
63.7841(c)

Progress reports for compliance extension (if applicable)	63.6(i)  SEQ
CHAPTER \h \r 1 

Semiannual compliance reports 	63.7841(b)



	A source must keep the following records:

Recordkeeping



Notifications and reports	

63.7842(a)(1), 63.10(b)(2)(xiv)



Startup, shutdown, and malfunction plan/events	

63.7842(a)(2), 

63.6(e)(3)(iii)-(v)



Performance tests and opacity observations	

63.10(b)(2)(viii), 63.7842(a)(3)



Continuous monitoring systems

	

63.10(b)(2)(vi)-(xi),

63.6(h)(7)(i)-(ii),

63.8(d)(3),

63.10(b)(2)(i)-(ii),

63.7842(b)   





Visual observations	

63.6(h)(6), 63.7842(c)



Records required to demonstrate continuous compliance

	

63.10(b)(2)(vii), 63.7842(d)



	Electronic Reporting

Some respondents use monitoring equipment that automatically records
parameter data.  Although personnel at the affected facility must
evaluate the data, internal automation has significantly reduced the
burden associated with monitoring and recordkeeping at the plant site.

Also, regulatory agencies, in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities	

Respondent Activities

Read instructions.

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.



Regulatory agencies, to the extent possible, are relying more on
automated techniques such as electronic submissions of reports, and are
improving their tracking systems and database systems to enhance the use
of these techniques.  However, electronic reporting systems are still
not widely used.  At this time, it is estimated that approximately 10
percent of the respondents use electronic reporting.

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

5(a)  Agency Activities 

EPA conducts one or more of 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

The required data and reports can be evaluated on-site by conducting a
partial compliance evaluation, full compliance evaluation or inspection,
or thru an off-site review of compliance monitoring records and reports.
 Evaluation reports and inspection results are maintained by the Agency
or delegated authority.

The results of these evaluations are entered into the Air Facility
Subsystem (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 delegated
authorities can retrieve and analyze the data.

5(c)  Small Entity Flexibility

A small entity for this industry is defined as a firm having no more
than 1,000 employees.  None of the 18 integrated iron and steel
facilities are small entities.  However, the Agency has minimized the
information collection burden by reducing the recordkeeping and
reporting requirements to include only the information needed to
determine compliance with the rule.  The rule also provides maximum
degree of operational flexibility and none of the facilities were at
risk of closure as a result of this rule.  

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1, attached.

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. 
The individual burdens are expressed under standardized headings
believed to be consistent with the concept of burden under the Paperwork
Reduction Act.  Where appropriate, the specific tasks and major
assumptions have been identified when calculating the burden.  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 respondent burden is shown in Table 1.  The labor hours in Table 1
are based on Agency studies and background documents from the
development of the regulation, Agency knowledge and experience with the
standard, 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	$100.99 ($48.09 + 110%)   

Technical	$87.97   ($41.89 + 110%)

Clerical	$43.81   ($20.86 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December, 2005, “Table 2. Civilian Workers, 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 annual burden for respondent activities includes labor costs,
capital/start up costs and operating and maintenance (O&M) costs.   The
capital/startup costs are one-time costs when a facility becomes subject
to the regulation.  We have assumed that existing respondents have
already purchased leak detectors for baghouses and continuous opacity
monitors for electrostatic precipitators, as required by the rule.  The
capital cost for bag leak detection systems is $9,000 each and for COMs
is $37,000 each.  However, there are no capital costs associated with
this rule since we have assumed that there will be no new sources
becoming subject to this rule.  The annual operation and maintenance
cost for this ICR is $67,000.  This is based on the impact analysis for
the rule which includes the ongoing costs to maintain 86 bag leaks
detectors at a cost of $500/year each or a total of $43,000/year and 3
continuous opacity monitors at a cost of $8,000 each year each or a
total of $24,000/year.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs



(A)

Continuous Monitoring Device	

(B)

Capital/

Startup Cost for One Respondent	

(C)

Number of New Respondents 	

(D)

Total Capital/ Startup Cost

 (B X C)	

(E)

Annual O&M Costs for One Respondent	

(F)

Number of Respondents with O&M	

(G)

Total O&M,

(E X F)

Leak detectors	$9,000	0	$0.00	$2,389	18	$43,000.00



Continuous Opacity Monitors	

$37,000	

0	

$0.00	

$8,000	

3	

$24,000.00



Total 

	

$0.00

	

$67,000.00



As discussed in Section 6(b)(iii), there are no total capital/startup
costs for this ICR, as shown on the OMB 83-I form in block 14(a), Total
annualized capital/startup costs.  The total operation and maintenance
(O&M) costs for this ICR is $67,000 (rounded) which is shown on the OMB
83-I form in block 14(b), Total annual costs (O&M).  The total
annualized respondent costs over the next three years of the ICR is
shown in block 14 (c), Total annualized cost requested.  This has been
calculated as the addition of the capital/startup costs and the annual
operation and maintenance costs.  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 Costs

The only costs to the Agency are those 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 and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
$20,327 (rounded), which is shown in Table 2, attached.

This cost is based on the average hourly labor rate as follows:

Managerial	$56.02  (GS-13, Step 5, $35.01 x 1.6)

Technical	$41.57  (GS-12, Step 1, $25.98 x 1.6)

Clerical	$22.50  (GS-6, Step 3, $14.06 x 1.6)

These rates from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.

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

Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.



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	

18	

0	

0	

18



2	

0	

18	

0	

0	

18



3	

0	

18	

0	

0	

18



Average	

0	

18	

0	

0	

18

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.  

To avoid double-counting respondents column D is subtracted.  The
average Number of Respondents over the three-year period of this ICR is
shown in column E.  This number appears on the OMB 83-I form in block
13(a), Number of respondents. 

The total number of annual responses per year is calculated using the
following table:



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



Notification of compliance status	

0	

1	

0	

0



Notification/application  of  construction	

0	

1	

0	

0



Notification of actual startup 	

0	

1	

0	

0



Notification of performance test and test plan	

0	

1	

0	

0



Report of performance test results 	

18	

0.4	

0	

7.2



Report of semiannual compliance reports   	

18	

2	

0	

36



Report of startup, shutdown, malfunction 	

1	

1	

0	

1



Total	

	

	

	

44.2



The number of Total Annual Responses, 44 (rounded), is shown in column
E.  This number is shown on the OMB 83-I form in block 13(b), Total
annual responses.

The Total Hours Requested, 18,421 (rounded), is shown on the OMB 83-I
form in block 13(c).  The total annual labor cost may be found in Table
1.  Annual Respondent Burden and Cost:  NESHAP for Integrated Iron and
Steel Manufacturing (40 CFR part 63, subpart FFFFF).

The average annual Agency burden and cost over next three years is shown
in Table 2.  Annual Burden and Cost for the Federal Government: NESHAP
for Integrated Iron and Steel Manufacturing (40 CFR part 63, subpart
FFFFF).

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.  

Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The annual labor costs are not shown on the OMB 83-I form.  Details
regarding these estimates may be found in Table 1.  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 419 hours per response.  

The total annual capital/startup and O&M costs to the regulated entity
are 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) Cost.

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years is
shown in Table 2.

6(f)  Reasons for Change in Burden

The increase from 4,772 hours to 18,421 hours in the annual labor burden
to industry from the most recently approved ICR is due to adjustments. 
The increase in burden from the most recently approved ICR is due to the
assumption that respondents are in full compliance with the rule
periodic requirements since the compliance date of the rule passed.  The
active ICR burden calculation was based on the assumption that a subset
of the respondents (i.e., 6 of a total of 18 sources each year) would be
implementing the initial rule requirements over the three year period of
the ICR, and would not have to comply with the rule on-going
requirements since the compliance date for the rule was not due until 3
years after rule promulgation. 

The increase from $64,000 to $67,000 in the total annualized capital and
operations and maintenance (O&M) costs is due to the assumption that
respondents are in full compliance with the rule on-going requirements,
as mentioned above.  Even when there are no capital and startup costs
for this ICR, the costs for operation and maintenance for baghouses and
continuous opacity monitors increased significantly since we are
accounting such costs for all three years of this ICR. 

	The Federal government burden hours increased from 73 to 501 hours due
to the increase number of periodic reports required to be reviewed since
respondents will be in full compliance with rule requirements.  The
costs associated with the review of reports offset the cost associated
with inspections (i.e., labor and travel costs associated with observing
performance tests) which we deleted since these are exempt under the
Paperwork Reduction Act.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 419 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, disclose, or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; to 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; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
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
EPA-HQ-OECA-2005- 0080, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Enforcement and Compliance Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Avenue, N.W., 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) 566-1927.  An
electronic version of the public docket is available online at  
HYPERLINK "http://www.regulations.gov"  http://www.regulations.gov . 
This site can be used to submit or view public comments, to 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.  You can also send comments 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.  Please include the EPA Docket ID Number EPA-HQ-OECA-2005-0080 and
OMB Control Number 2060-0517 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

Table 1.  Annual Respondent Burden and Cost:  NESHAP for Integrated
Iron and Steel Manufacturing (40 CFR part 63, subpart FFFFF)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours 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	

40	

1	

40	

0	

0.0	

0.0	

0.0	

$0.00



4.  Reporting Requirements











  A.  Read instructions:	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



  B.  Required activities: c, d











  i.  Method 5 performance test  e  	40	7.6	304	

18	5,472	

273.6	

547.2	

$532,975.53



  ii.  Method 9 performance test  e	

8	

3.6	

28.8	

18	

518.4	

25.9	

51.8	

$50,488.65



 iii.  Method 6071B performance   test	

2	

365	

730	

7	

5,110	

255.5	

511	

$497,716.56



     iv.  Startup, shutdown,                     malfunction plan	

40	

1	

40	

0	

0.0	

0.0	

0.0	

$0.00

  

     v.  Inspection and maintenance       of  capture systems and
control        devices   f	

2	

12	

24	

18	

432.0	

21.6	

43.2	

$42,077.02



  C.  Gather Existing Information	

Included in 5D, 5E









  D.  Write report  c, d 









   

    i.  Notification of applicability  	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



    ii.  Notification of compliance         status  	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00

  

    ii.  Notification of intent to               construct a major
source and           review application	

4	

1	

4	

.0	

0.0	

0.0	

0.0	

$0.00



    iii.  Notification of initial                  construction/
reconstruction  a	

4	

1	

4	

0.0	

0.0	

0.0	

0.0	

$0.00



    iv.  Notification of actual                  startup	

4	

1	

4	

0.0	

0.0	

0.0	

0.0	

$0.00



    v.  Notification of performance        test 	

4	

1	

4	

0.0	

0.0	

0.0	

0.0	

$0.00



    vi.  Reports of performance             test results	

Included in 4B, 5E









    vii.  Semiannual compliance            reports  c    	

40	

2	

80	

18	

1,440.0	

72.0	

144	

$140,256.72



    viii.  Startup, shutdown,           

    malfunction report  f	

4	

1	

4	

1	

4	

0.2	

0.4	

$389.60



5.  Recordkeeping Requirements











  A.  Read instructions	

Included in 4A









  B.  Plan activities	

10	

1	

10	

0.0	

0.0	

0.0	

0.0	

$0.00



  C.  Implement activities	

Included in 4B







  

  D.  Develop record system  	NA









  E.  Time to enter and transmit all     information into record system 
 g 	

3.25	

52	

169	

18	

3,042.0	

152.1	

304.2	

$296,292.32

 

  F.  Time to train personnel	3	1	3	0	0.0	0.0	0.0	

$0.00



  G. Time for audits	

N/A	

	











TOTAL LABOR  BURDEN AND COST  	

	

	

	

	

16,018.4	

800.9	

1601.8	

$1,560,196.40



TOTAL LABOR HOURS (Rounded)	

	

	

	

	

18,421	

$1,560,196

Assumptions:

a   There is an average of 18 respondents (i.e., integrated iron and
steel manufacturing plants) and  per year.  We have assumed that there
will be no new sources subject to this regulation.  

b  This ICR uses the following labor rates: $100.99 per hour for
Executive, Administrative, and Managerial labor; $87.97 per hour for
Technical labor, and $43.81 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December, 2005, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c    SEQ CHAPTER \h \r 1 We have assumed that existing respondents have
already complied with initial rule requirements and are in full
compliance with periodic requirements including semiannual reports.  New
respondents would have to comply with the initial rule requirements
including notifications and performance tests for add-on control
devices.   

d   Monitoring and recordkeeping of operations for respondents include:
monthly inspection of capture and control systems; daily testing of oil
content for the sinter plant feed (7 plants (from the composite of three
samples taken at 8-hour intervals)) to compute the 30-day rolling
average oil content for each operating day; and every 2.5 years, each
emission point must be sample by Method 5 for particulate matter and
Method 9 for opacity observations to determine the opacity of fugitive
emissions.  

e  Based on the average for the 18 respondents, we have assumed that
there is an average of 7.6 emission points per respondent that need to
be sample using Method 5 and 3.6 emission points per respondent that
need to be sample using Method 9.

f  We have assumed that one respondent per year will have at least one
startup, shutdown or malfunction (SSM) that is not managed according to
the SSM plan.

g  We have assumed that it takes respondents approximately 3 hours per
week to record and transmit the recorded information.



Table 2.  Annual Burden and Cost for The Federal Government:

NESHAP for Integrated Iron and Steel Manufacturing (40 CFR part 63,
subpart FFFFF)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year  a

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



New Respondents:  c











  i.  Notification of compliance status	

4	

1	

4	0	0.0	0.0	0.0	

$0.00



  ii.  Notification of intent to construct a   major source and review
application	

4	

1	

4	0	0.0	0.0	0.0	

$0.00



  iii.  Notification of start of construction	

2	

1	

2	0	0.0	0.0	0.0	

$0.00



   iv.  Notification of actual startup 	

2	

1	

2	0	0.0	0.0	0.0	

$0.00



  v.  Notification of initial performance     test and test plan	

4	

1	

4	

0	

0.0	

0.0	

0.0	

$0.00



Existing Respondents











  i.  Performance test report: Method 5     and Method 9  d	

20	

0.4	

8	

18	

144.0	

7.2	

14.4	

$6,713.42



  ii.  Review of semiannual compliance    reports  e	

8	

2	

16	

18	

288.0	

14.4	

28.8	

$13,426.85



  iii.  Review of startup, shutdown,           malfunction reports  e 	

4	

1	

4	

1	

4.0	

0.2	

0.4	

$186.48



Subtotal Burden and Cost



	

436.0	

21.8	

43.6	

$20,326.75



TOTAL ANNUAL BURDEN AND COST (rounded)



	

501	

$20,327



Assumptions:

a   There is an average of 18 respondents (i.e., integrated iron and
steel manufacturing plants) and  per year.  We have assumed that there
will be no new sources subject to this regulation.  .

b   This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.  

c   We have assumed that existing sources have comply with the initial
rule requirements.  New respondents are required to conduct performance
test for add-on control equipments, submit initial notifications and
prepare startup, shutdown and malfunction (SSM) plans.  

d   Every 2.5 years (or about 0.4 times per year, if average over the
three year period of ICR), respondents must sample each emission point
using Method 5 for particulate matter and Method 9 for opacity
observations, and submit a report of results. 

 e  Sources are required to submit semiannual compliance reports and
startup, shutdown and malfunction (SSM) reports if there is an
occurrence that is not managed according to the SSM plan.

