	SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces 

(40 CFR part 60, subparts N and Na) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces (40
CFR Part 60, Subparts N and Na) (Renewal), EPA ICR Number 1069.09, OMB
Control Number 2060-0029

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subparts N and Na were proposed on June 11,
1973, and promulgated on March 8, 1974. These regulations 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.

The monitoring, recordkeeping, and reporting requirements outlined in
these rules are similar to those required for other NSPS regulations. 
Consistent with the NSPS General Provisions (40 CFR part 60, subpart A),
respondents would submit initial notifications, conduct performance
tests and report test results for the primary emission control devices,
and submit periodic reports.  Sources also must develop and implement a
Startup, Shutdown, and Malfunction Plan (SSMP) and submit semiannual
reports of any event where the procedures in the plan were not followed.
 These notifications, reports, and records are essential in determining
compliance, and are required of all sources subject to NSPS. 

Any owner/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 United States Environmental
Protection Agency (EPA) regional office.

 We have determined that there are approximately five respondents which
are currently subject to NSPS, subparts N and Na.  Furthermore, we have
assumed that one existing BOPF shop, which is not currently a
respondent, becomes a respondent over the next three years due to
modification/reconstruction related to its furnaces, skimming stations
and/or hot metal transfer stations.  This information was confirmed with
the rule lead addressing this source category at the Office of Air
Quality Planning and Standards (OAQPS).

For the renewal of this Information Collection Request (ICR), OMB did
not request that EPA address any “Terms of Clearance.”

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost of the NSPS for Primary and Secondary
Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na)
(Renewal).  The burden to the “Federal Government” is attributed
entirely to work performed by federal employees or government
contractors, and may be found in Table 2: Annual Burden and Cost to the
Federal/State Government of the NSPS for Primary and Secondary Emissions
from Basic Oxygen Furnaces  (40 CFR Part 60, Subparts N and Na)
(Renewal).

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: 

. . . 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/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 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 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 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 ensure that the pollution control devices are
properly installed and operated and that the standards are being met. 
The performance test may also be observed.

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

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, subparts N and Na.

3(a)  Non-duplication

 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
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 (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

After reviewing our internal data sources and discussing the industry
growth rate with the Agency industry experts in the previous renewal, we
have determined that additional consultations with industry are
inappropriate for this ICR renewal.

 

These standards were developed with the participation and/or
consultation with industry representatives.  In addition, the Agency
performed additional reviews to determine additional burden reduction
opportunities and as a result of recent rule-making (40 CFR part 60,
subpart FFFFF) affecting this source category.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.  In this case, no comments were received.

 

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.  The retention of records for five
years allows EPA to establish the compliance history of a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond the five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
non-existence of essentials records.     

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 (CBI) (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
basic oxygen process furnace shops at iron and steel plants with
furnaces, skimming stations and/or hot metal transfer stations.  The
United States Standard Industrial Classification (SIC) codes for the
respondents affected by 40 CFR part 60, subparts N and Na and the
corresponding North American Industry Classification System (NAICS)
codes are listed below:

  

SIC Code and Description	

Corresponding NAICS Code and Description



3312 - Steel Works, Blast Furnaces (Including Coke Ovens), and Rolling
Mills (except coke ovens not integrated with steel mills	

331111 - Iron and Steel Mills; 31221 – Rolled Steel Shape
Manufacturing 



3315 - Steel Wiredrawing and Steel Nails and Spikes (steel, wire
drawing)	

331222 - Steel Wire Drawing 



3316 - Cold-Rolled Steel Sheet, Strip and Bars	

331221 - Rolled Steel Shape Manufacturing 



3317 - Steel Pipe and Tubes	

33121 - Iron and Steel Pipe and Tube Manufacturing from Purchased Steel 



4(b)  Information Requested

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces (40
CFR part 60, subparts N and Na) (Renewal).

A source must make the following reports:

Notification Reports for 40 CFR Part 60, Subparts N and Na



Notification of construction/reconstruction	

60.7(a)(1)



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)



Reports for 40 CFR Part 60, Subparts N and Na



Report of performance test results	

60.8 (a)



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)



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)



Electronic Reporting

Currently, respondents are using monitoring equipment that automatically
records parameter data (e.g., flow rate and pressure drop).  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.

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.



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.



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 EPA to discern a source’s initial capability to comply with the
emission standard.  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.

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 two years.

5(c)  Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this
regulation since basic oxygen process furnaces are located at iron and
steel facilities which are large and very complex facilities.

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:
NSPS for Primary and Secondary Emissions from Basic Oxygen Furnaces (40
CFR Part 60, Subparts N and Na) (Renewal).

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 sources subject
to NSPS, subparts N and Na, which are 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 1,896
(Total Labor Hours from Table 1).  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 the following labor rates: 

Managerial	$97.46   ($46.41 + 110%)

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 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 type of industry costs associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance (O&M) costs are the ongoing costs to maintain the monitor(s)
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)

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)



Flow meters to measure exhaust gas flow rate 	

$18,000	

1	

$18,000	

$900	

5.33	

$4,797



Flow meters to measure pressure flow rate 	

0	

0	

0	

$900	

4.00	

$3,600



Total 	

	

	

$18,000	

	

	

$8,397



The total capital/startup costs for this ICR are $18,000.  This cost is
based on one BOPF shop incurring a 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.  This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are
$8,397.  This cost is based on the O&M costs being 5 percent of the flow
monitor cost.  We have also assumed that three operating BOF shops
subject to this rule use venturi scrubbers as primary emission control
systems and have reportable low pressure.  The other operating BOF shops
subject to this rule use an electrostatic precipitator as the primary
emission control.  This is the total of column G.

The total respondent costs in block 14 have been calculated as the
addition of the 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 $26,397.

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 $2,755.

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 are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: (use the complete title
of the table), below.

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

Based on our research for this ICR, on average over the next three
years, approximately   5 existing respondents (i.e., BOPF shops) will be
subject to the standard.  It is estimated that an additional BOPF shop
will become subject to these rules due to modification of its operations
over the three-year period of this ICR.  The overall average number of
respondents, as shown in the table below is 5.3 per year.

The 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 Respondents1	

(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	

0.33	

5	

NA	

0	

5.33



2	

0.33	

5	

NA	

0	

5.33



3	

0.33	

5	

NA	

0	

5.33



Average	

0.33	

5	

NA	

0	

5.33

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

.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 5 (rounded).

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 modification/reconstruction	

0.33	

1	

NA	

0.33



Notification of Performance Test	

0.33	

1	

NA	

0.33



Report results of performance test	

0.33	

1	

NA	

0.33



Semiannual reports	

5.33	

2	

10.66	

10.66



	

	

	

Total	

11.65



The number of Total Annual Responses is 12 (rounded).  The total annual
labor is 1,896 hours (rounded).  Details regarding these estimates may
be found in Table 1: Annual Respondent Burden and Cost: NSPS for Primary
and Secondary Emissions from Basic Oxygen Furnaces (40 CFR Part 60,
Subparts N and Na) (Renewal), attached.

The total annual capital/startup and O&M costs to the regulated entities
are $26,397.  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 the next three years is
estimated to be 68 labor hours at a cost of $2,755 (rounded).  See Table
2: Annual Agency Burden and Cost, NSPS for Primary and Secondary
Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na)
(Renewal), 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.

(i) Respondent Tally

The Total Hours Requested is 1,896 hours.  The total annual labor costs
are $153,043.  Details regarding these estimates may be found in Table
1.  Annual Respondent Burden and Cost: NSPS for Primary and Secondary
Emissions from Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na)
(Renewal), attached.  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 158 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $26,397.  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 68 labor hours at a cost of $2,755.  See Table 2: Annual
Agency Burden and Cost: NSPS for Primary and Secondary Emissions from
Basic Oxygen Furnaces (40 CFR Part 60, Subparts N and Na (Renewal)),
attached.

6(f)  Reasons for Change in Burden

There is no change in the labor hours to the respondents in this ICR
compared to the previous ICR.  This is due to two considerations: 1) the
regulations have not changed over the past three years and are not
anticipated to change over the next three years; and 2) the growth rate
for respondents is very low, negative, or non-existent.  Therefore, the
labor hours in the previous ICR reflect the current burden to the
respondents and are reiterated in this ICR.  There is a minor change to
the cost figures, since the previous ICR rounded to the nearest $1,000;
this ICR presents cost figures which differ by $397` from the previous
ICR due to using exact figures instead of rounding.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 158 hours per response.  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 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-2008-0374.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  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
docket center is (202) 566-1927.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2008-0374 and OMB Control Number 2060-0029 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: NSPS for Primary and
Secondary Emissions from Basic Oxygen Furnaces 

(40 CFR Part 60, Subparts N and Na) (Renewal)

	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	

N/A	

	

	

	

	

	

	





4.  Reporting Requirements	

	

	

	

	

	

	

	





  A.  Read Instructions	

1	

1	

1	

0.33	

0.33	

0.02	

0.03	

$30.85



  B.  Required Activities	

	

	

	

	

	

	

	





       Performance Test c	

194	

1	

194	

0.33	

64.02	

3.20	

6.40	

$5,943.30



       Repeat of Performance 

        Test c	

194	

1	

194	

0	

0.00	

0.00	

0.00	

$0.00



       Daily monitoring of 

       emissions and operations	

Included in 5E	

	

	

	

	

	





  C.  Create Information		

Included in 4B and 5E	

	

	

	

	

	





  D.  Gather Existing                              Information	

Included in 4B and 5E	

	

	

	

	

	





  E.  Write report	

	

	

	

	

	

	

	





       Notification of modification          or reconstruction   c  	

2	

1	

2	

0.33	

0.66	

0.03	

0.07	

$61.14



       Notification of  Performance         Test a, c	

2	

1	

2	

0.33	

0.66	

0.03	

0.07	

$61.14



       Performance Test  Results c	

32	

1	

32	

0.33	

10.56	

0.53	

1.10	

$982.44



       Semiannual Reports of                  Excess Emissions and      
            Monitoring Systems                      Performance d	

10	

2	

20	

5.33	

106.60	

5.33	

10.66	

$9,896.53



	SUBTOTAL Reporting



	

182.83	

9.14	

18.33	

$16,975.40



5.  Recordkeeping Requirements	

	

	

	

	

	

	

	





  A.  Read Instructions	

Included in 4A	

	

	

	

	

	





  B.  Plan Activities	

Included in 4B	

	

	

	

	

	





  C.  Implement Activities	

Included in 4B	

	

	

	

	

	





  D.  Develop Record System	

N/A	

	

	

	

	

	

	





  E.  Time to Enter and                         Transmit Information:  e


	

	

	

	

	

	

	





       Records of CMS operating

       parameters:          

       -  Exhaust ventilation rate f

       -  Across the venturi                      scrubber (i.e.,
pressure drop          and water supply pressure) g 	

	

	

	

	

	

	

	



	

0.25	

365	

91.25	

5.33	

486.36	

24.32	

48.64	

$45,153.06

	

0.25	

365	

91.25	

4.00	

365.00	

18.25	

36.50	

$33,885.88



      Records of performance Test	

Included in 4B	

	

	

	

	

	





      Records of duration of each

      steel production cycle, and            time and duration of any   
           diversion of exhaust gases             from the main stack
serving          the BOPF	

0.25	

365	

91.25	

5.33	

486.36	

24.32	

48.64	

$45,153.06



       Recalibrate and check                   monitoring devices  h	

8	

1	

8	

5.33	

42.64	

2.13	

4.26	

$3,958.24



 F.  Time to Train Personnel:

      -  Certification of opacity              observer  i	

 8	

2	

16	

5.33	

85.28	

4.26	

8.53	

$7,916.92



G.  Time for Audits	

N/A	









 

       SUBTOTAL Recordkeeping



	

1,465.64	

73.28	

146.57	

$136,067.16



Subtotal Labor Burden	

	

	

	

	

1,648.47	

82.42	

164.85	

$153,042.56



TOTAL LABOR  BURDEN AND COST	

	

	

	

	

1,895.74

1,896 (rounded)	

$153,042.56



Assumptions:

a We have determined that there are five respondents (i.e., BOPF shops)
which are currently subject to NSPS Subparts N and Na.  Furthermore, we
have assumed that one existing respondent 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.

b  These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 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 which are technical at $83.71, management at $97.46, and
clerical at $42.55.

c We have assumed that the new respondent conducting modifications at
its furnaces, skimming stations and/or hot metal transfer stations will
comply with the notifications requirements of the rule and conduct a
successful performance test.

d We have assumed that all five existing respondents 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. 

e We have assumed that the respondents are operating 365 days per year,
as specified in the NSPS review document. 

f We have assumed that all five existing respondents and the new
respondent would need to meet the monitoring requirements.

g We have assumed that four existing respondents subject to this rule
use venturi scrubbers as primary emission control systems and have
reportable low pressure.   The other existing respondents and the new
respondent subject to these rules use an electrostatic precipitator as
the primary emission control.   

h We have assumed that respondents 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 and at other times, if required.  

i  This burden includes the indirect costs to respondents to provide
certification to one observer provided by the state enforcement agency
or its contractor.   Certification of opacity observers is valid for a
six month period according to Method K. 

TABLE 2:  Annual Burden and Cost to the Federal/State Government:  NSPS
for Primary and Secondary Emissions from 

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

	Burden Item	

(A)

Person

hours per

	occurrence	

(B)   

Number  of

occurrences

per plant

per year	

(C)

Person hours per plant  per

year

	(C=AxB)	

(D)

Plants per  year  a	

(E)

Technical hours 

per  year

	(E=CxD)	

(F)

Management   hours per year

(F=0.05xE)	

(G)

Clerical-person

hours per

year

(G=0.1xE)	

(H)

Cost, $  b





Report Review:  New Sources  c	

	

	

	

	

	

	

	





  Notification of performance          test  c	

2	

1	

2	

0.33	

0.66	

0.03	

0.07	

$30.70



  Report of performance test            results   c	

8	

1	

8	

0.33	

2.64	

0.13	

0.26	

$122.88



  Notification of modification/         reconstruction  c	

2	

1	

2	

0.33	

0.66	

0.03	

0.07	

$30.70



Report Review: Existing and       New Sources  d	

	

	

	

	

	

	

	





  Semiannual reports of excess        emissions and monitoring          
  systems performance  	

5	

2	

10	

5.33	

55.33	

2.77	

5.53	

$2,570.68



Subtotal 	

	

	

	

	

59.29	

2.96	

5.93	

$2,754.96



TOTAL ANNUAL COST 	

	

	

	

	

68.18	

$2,754.96



Assumptions:

a  We have determined that there are five respondents (i.e., BOPF shops)
which are currently subject to NSPS Subparts N and Na.  Furthermore, 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.

b  This cost is based on the average hourly labor rate as follows:
Managerial at $56.02  (GS-13, Step 5, $35.01 x 1.6), Technical at $41.57
 (GS-12, Step 1, $25.98 x 1.6), and Clerical at $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 a respondent conducting modifications at its
furnaces, skimming stations and/or hot metal transfer stations will
comply with the notifications requirements of the rule and conduct a
performance test. 

d  We have assumed that all five existing respondents and the new
respondent 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.

 PAGE  13 

