SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart
ZZZZZ) (Renewal) 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart
ZZZZZ) (Renewal), EPA ICR Number 2267.03, OMB Control Number 2060-0605

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ)
with the final rule published on January 2, 2008 (73 FR 225).  Potential
respondents are owners or operators of any existing or new iron or steel
foundry that is an area source of hazardous air pollutants (HAP)
emissions.  Research and development facilities are not covered by the
rule.  Foundries covered by the rule would not be required to obtain a
Title V operating permit.

There are different requirements for foundries based on size.  Small
iron and steel foundries are required to comply with pollution
prevention management practices for scrap materials, the removal of
mercury switches, and binder formulations.  Large iron and steel
foundries are required to comply with the same pollution prevention
management practices as small foundries in addition to emissions
limitations for melting furnaces and foundry operations.  Existing
foundries with an annual metal melt production greater than 20,000 tons
and new foundries with an annual metal melt capacity greater than 10,000
tons are classified as large foundries.  Existing foundries with an
annual metal melt production of 20,000 tons or less and new foundries
with an annual metal melt capacity of 10,000 tons or less are
classified.

For metallic scrap, the pollution prevention management practices
require foundries to purchase (or otherwise obtain) the motor vehicle
scrap only from scrap providers participating in an EPA-approved program
for the removal of mercury switches or to comply with alternative
provisions.  The requirements for binder formulations require foundries
to use on one type of production line chemical formulations that do not
contain methanol as a specific ingredient of the catalyst formulation. 
The management practices also include a pollution prevention initiative
to encourage foundries to investigate and switch to non-HAP binders and
coating materials by requiring records of the annual quantity and
composition of each HAP-containing chemical binder or coating material
used to make molds and cores.  The NESHAP allows foundries 2 years after
promulgation to comply with the management practices for mercury, 1 year
to comply with the opacity limit for melt shops, and 6 months for other
requirements.

Small foundries would submit two types of one-time notifications
required by the NESHAP general provisions and keep records of specific
information to demonstrate compliance with the rule requirements.  The
final rule also requires small foundries to calculate for each calendar
month their 12-month rolling average production rate to ensure that the
facility continues to meet the size criteria that defines a small iron
and steel foundry.  Records of the monthly production rate and monthly
rolling average calculations are required.  A small foundry must report
any deviation from these requirements within 30 days.  

	Large area source foundries are required to comply with the pollution
prevention management practices in addition to emissions standards for
metal melting furnaces and foundry operations.  The owner or operator
may elect to comply with emissions limits for particulate matter (PM) or
total metal HAP.  The final rule contains provisions for demonstrating
compliance with the limits using emissions averaging.  The owner or
operator of an existing affected source is required to conduct initial
and periodic visual inspections of PM control devices (baghouses, wet
scrubbers, electrostatic precipitators).  Foundries using a baghouse to
comply with the PM emission limit may choose to install and operate a
bag leak detection system instead of conducting the initial and periodic
inspections.  Bag leak detection systems are required at new foundries. 
New source foundries must use a  continuous parameter monitoring system
(CPMS) to measure and record pressure drop and scrubber water flow rate
for a wet scrubber and/or a CPMS to measure and record the hourly
average voltage and secondary current (or total power input) to an
electrostatic precipitator.  Monthly inspections of capture systems are
also be required.  An operation and maintenance plan for control devices
also is required.  Foundries also must conduct an opacity test at least
every 6 months to demonstrate compliance with an opacity limit for
fugitive emissions from buildings or structures housing foundry
operations.  Alternatively, foundries may conduct semiannual visible
emissions observations by Method 22.  The Method 22 test is considered
successful if no visible emissions are observed for 90 percent of a
1-hour test.  A Method 9 opacity test is required if the Method 22 test
is not successful.

Large foundries will demonstrate initial compliance with emissions
limits through performance tests.  The owner or operator of an existing
area source may certify initial compliance based on the results of a
previous performance test that meets the rule requirements.  Subsequent
performance tests for furnaces are to be performed every 5 years. 
Provisions also are included for demonstrating compliance through
emissions averaging.  A facility that uses emissions averaging must
conduct monthly compliance determinations by calculating the weighted
average emissions for furnaces in the emissions averaging group. 
Consistent with the NESHAP General Provisions, large foundries are
required to submit one-time notifications; comply with requirements for
startup, shutdown, and malfunction (SSM) plans and reports;  submit
semiannual excess emissions and monitoring system performance reports;
and maintain records of specific information to ensure that the rule
requirements are being achieved and maintained.  

Any owner or operator subject to the provisions of this part will
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.

Approximately 427 respondents are currently subject to the regulation,
and it is estimated that no additional respondents per year will become
subject to the regulation in the next three years.  Therefore, the
average number of total respondents per year is 142.33.

In the United States, there are approximately 427 iron and steel
foundries that are owned and operated by the iron and steel foundry
industry.  None of these 427 facilities are owned by state, local,
tribal, or the Federal government.  They are owned and operated by
privately owned for-profit businesses.  You can find the burden to the
“Affected Public” listed below in Table 1: Annual Respondent Burden
and Cost - NESHAP for Iron and Steel Foundry (40 CFR Part 63, Subpart
ZZZZZ).  The Federal government burden does not include work performed
by Federal employees.  The burden refers only to work performed by
contractors, which could be found listed below in Table 2: Average
Annual EPA Burden - NESHAP for Iron and Steel Foundry (40 CFR Part 63,
Subpart ZZZZZ).

The Office of Management and Budget (OMB) approved the currently active
Information Collection Request (ICR) without any “Terms of Clearance
(TOC).”

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 (HAP). 
These standards are applicable to new or existing sources of HAP and
shall require the maximum degree of emission reduction.  In addition,
section 114(a) states that the Administrator may require any owner or
operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from cellulose products
manufacturing cause or contribute to air pollution that may reasonably
be anticipated to endanger public health or welfare.  Therefore, the
NESHAP for this source category was promulgated at 40 CFR part 63,
subpart ZZZZZ.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where 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 standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance tests, 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 standard 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, that leaks are being detected and repaired, and that the
standards are being met.  The performance test may also be observed.

The information generated by the monitoring, recordkeeping, and
reporting requirements described in this ICR is used by the Agency to
ensure that facilities affected by the NESHAP continue to operate the
control equipment in compliance with the regulation.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart ZZZZZ.

3(a)  Nonduplication

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

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (76 FR 26900) on May 9, 2011.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by the EPA Office of Compliance.
 OTIS is the EPA database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts.  

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.  

After a thorough review of comments, it is our policy to respond to
those received since the last ICR renewal, as well as to those submitted
in response to the First Federal Register Notice.

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 that 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

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 notification 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
nonexistence of essential 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 (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

	

The respondents to the recordkeeping and reporting requirements are iron
foundries and steel foundries.  The North American Industry
Classification System (NAICS) codes for the respondents affected by the
standards are 331511, 331512, and 331513.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

In this ICR, all the data recorded or reported is required by National
Emission Standards for Hazardous Air Pollutants for Iron and Steel
Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ).

Source Data and Information Requirements, summarize the data items,
including recordkeeping and reporting requirements are found in
Attachment 1.

Electronic Reporting

Some of the respondents are using 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 a plant site.

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 zero percent of the respondents use
electronic reporting.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CEMS for opacity, or for
pressure drop and liquid supply pressure for control device.

Perform initial performance test, and repeat performance tests if
necessary.

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.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., continuous parameter
monitoring system.  Although personnel at the source still need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.

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 Online Tracking Information
System (OTIS).



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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.

Information contained in the reports is entered into OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is the
EPA database for the collection, maintenance, and retrieval of
compliance data for approximately 125,000 industrial and
government-owned facilities.  EPA uses OTIS for tracking air pollution
compliance and enforcement by local and state regulatory agencies, EPA
regional offices, and EPA headquarters.  EPA delegated Authorities can
edit, store, retrieve, and analyze the data.

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

5(c)  Small Entity Flexibility

	A small entity for this industry is defined by the Small Business
Administration as a firm having no more than 500 employees.  A total of
319 of the 427 iron and steel foundries are small entities. 
Approximately 45 percent (37 of 83) of the large iron and steel
foundries (annual metal melt production greater than 20,000 tons) are
owned by small entities while 85 percent (292 of 344) of the small iron
and steel iron and steel foundries are owned by small entities.  The
final  rule includes a specific compliance option for small foundries
that provides a maximum degree of operational flexibility, and the ICR
requirements are the minimum necessary to demonstrate compliance.  Since
proposal, we have further reduced the impacts on small entities by
increasing the threshold definition for a small foundry from an annual
melt production of 10,000 tons to 20,000 tons.  Our analyses show that
the final NESHAP will not result in a significant economic impact on a
substantial number of small entities.  No small entities are expected to
incur an economic impact that is greater than 3 percent of its revenue. 
The number of foundries that may incur an economic impact greater than 1
percent of their revenues ranges from an average of 9 to a maximum (at
the 98th percentile) of 13.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 2A and 2B: Annual Respondent Burden and
Cost, NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63,
Subpart ZZZZZ) (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 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.  Wherever 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 6,024
(Total Labor Hours from Table 2A, and 2B).  These hours are based on
Agency studies and background documents from the development of the
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

This ICR uses the following labor rates:

Managerial	$97.99 ($46.66 + 110%)   

Technical	$72.09 ($34.33 + 110%)

Clerical	$33.16 ($15.79 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, May 2006, "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

As shown in Table 2B, the estimate of capital costs for large foundries
is $59,620 with no O&M costs.  This cost does not include the cost of
any monitoring equipment because the final rule requires visual
inspections instead of automated monitoring equipment at existing
affected sources. This cost does include the cost of a file cabinet for
data storage.  

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

The estimate of capital/startup costs versus O&M costs is shown in Table
2B.  No O&M costs would occur over the 3-year period of this ICR.

		(iv)  Annualizing Capital Costs

Table 2B shows an estimate of the annualized cost of capital to be
$8,490 per year.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $32,917.

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

		Managerial	$58.18 (GS-13, Step 5, $36.36 + 60%) 

		Technical	$47.97 (GS-12, Step 1, $26.98 + 60%)

		Clerical	$22.66 (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) “2007
General Schedule” which excludes locality rates of pay.  The rates
have been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear in Table 2: Average Annual EPA Burden, NESHAP for Iron and
Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

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

There are 427 existing iron and steel foundries.  No new sources are
expected during the next 3 years.  Consequently, the average annual
number of respondents during the 3 year period of this ICR is 142.33.  A
total of 344 of the 427 facilities are foundries with a metal melting
rate of 20,000 tpy or less and 83 have metal melting rates greater than
20,000 tpy.  Consequently, the average annual number of small foundries
during the 3-year period of this ICR is 114.67 and the average annual
number of large foundries is 27.67.

The only components of the total annual responses for small foundries
attributable to this ICR are two one-time initial notifications for each
facility.  Large foundries are required to submit two one-time initial
notifications; prepare an operation and maintenance plan and a startup,
shutdown, and malfunction plan, and submit semiannual compliance
reports.  The number of total annual responses for Subpart ZZZZZ is
estimated as:  (114.67 annual average respondents × 1 notification) +
(114.67 annual average respondents × 1 notification) + (27.67 annual
average respondents x 1 deviations report) + (27.67 annual average
respondents × 2 written plans) + (27.67 annual average respondents x 2
semiannual reports).   Therefore, the number of total annual responses
for Subpart ZZZZZ is 367.7.

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 2A, 2B, and 3,
respectively, and summarized below. 

(i)  Respondent Tally

The bottom line respondent burden hours and costs, presented in Table 2
are calculated by adding person-hours per year down each column for
technical, managerial, and clerical staff, and by adding down the cost
column.

The average annual burden for the monitoring, recordkeeping, and
reporting requirements in Subpart ZZZZZ for small foundries is 3,555
person hours with an annual average cost of $248,288 with no capital and
O&M costs.  The average annual burden for the monitoring, recordkeeping,
and reporting requirements in Subpart ZZZZZ for large foundries is 2,469
person hours with an annual average cost of $172,430; the annualized
capital cost is $8,490 with no operation and maintenance costs.  The
average annual burden for the monitoring, recordkeeping, and reporting
requirements in Subpart ZZZZZ for all iron and steel foundry area
sources is 6,024 person hours with an annual average cost of $420,718
with annualized capital costs of $8,490 and no O&M costs. 

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 712 labor hours at a cost of $32,917.  See Table 3.
Annual Agency Burden and Cost: NESHAP for Iron and Steel Foundry Area
Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost 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
according to the industry sources is very low, negative or non-existent,
so there is no significant change in the overall burden.  There are no
new facilities expected to be constructed over the next three years of
this ICR.  Therefore, the labor hours and cost figures in the previous
ICR reflect the current burden on the respondents and are reiterated in
this ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 16 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 the EPA 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-2011-0229.  An electronic version of the public docket is
available at   HYPERLINK "http://www.regulations.gov/" 
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 content of the docket, and to access those
documents in the public docket that are available electronically.  When
in the system, select “search” than 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 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) 566-1752. 
Also, you can 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-2011-0229 and OMB Control Number
2060-0605 in any correspondence.

Part B of the Supporting Statement

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

ATTACHMENT 1.  INFORMATION REQUIREMENTS 

 Requirement for new and existing sources 	Citation for small
foundries	Citation for large foundries	Citation for NESHAP general
provisions 

Initial and periodic inspections for baghouses, wet scrubber, and
electrostatic precipitator at existing source;  	NA	§63.10897(a)	NA

CPMS for wet scrubber at new source	NA	§63.10897(b)	NA

CPMS for electrostatic precipitator at new source	NA	§63.10897(c)	NA

BLDS or inspections for baghouse at existing source; BLDS for baghouse
at new source.	NA	§63.10897(d)	NA

Monthly capture system inspections	NA	§63.10897(e)	NA

Semiannual opacity tests	NA	§63.10898(i)	NA

CMS performance evaluation	NA	NA

	Metal melting furnaces and fugitive emissions 	NA	§63.10898	40 CFR
63.7

CMS performance evaluation	NA	NA	40 CFR 63.8(e)(3)

Notification of applicability	§63.10890(b)	§63.10900(a), Table 3	40
CFR 63.9(b)(2)

Notification of construction/ reconstruction 1	§63.10890(f)
§63.10900(a), Table 3	40 CFR 63.9(b)(5)

Notification of special compliance requirements  1	§63.10890(f)
§63.10900(a), Table 3	40 CFR 63.9(d)

Notification of performance test	NA	§63.10900(a), Table 3	40 CFR
63.9(c)

Notification of opacity/VE observations	NA	§63.10900(a), Table 3	40 CFR
63.9(f)

Additional CMS notifications	NA	NA	40 CFR 63.9(g)

Notification of compliance status	§63.10890(c)	§63.10900(a), Table 3
40 CFR 63.9(h)(1)

Notification of changes in information  1	§63.10890(f)	§63.10900(a),
Table 3	40 CFR 63.9(j)

Scrap management material specifications 	§63.10885(b),(c)

NA

Operation and maintenance plan	NA	§63.10896(a)	NA

Startup, shutdown, and malfunction plan	NA	§63.10900(a), Table 3	40 CFR
63.6(e)(3)

Performance test plan	NA	§63.10900(a), Table 3	40 CFR 63.7(c)(2)

CMS quality control plan	NA	§63.10900(a), Table 3	40 CFR 63.8(d)

CMS performance evaluation test plan	NA	NA	40 CFR 63.8(e)(3)

Information to support notifications	§63.10890(e)(1)	§63.10900(a),
Table 3	40 CFR 63.10(b)(2)

Material specifications	§63.10890(e)(2)	§63.10899(b)(1)	NA

Mercury	§63.10890(e)(3)-(4)	§63.10899(b)(2)-(3)	NA

Nonmethanol binder chemical formulations	§63.10890(e)(5)
§63.10899(b)(4)	NA

Annual quantity and composition of each HAP-containing chemical binder
or coating material 	§63.10890(e)(6)	§63.10899(b)(5)	NA

Metal melt production	§63.10890(e)(7)	§63.10899(b)(6)

	Operation and maintenance plan	NA	§63.10899(b)(7)	NA

If applicable, emissions averaging plan	NA	§63.10899(b)(8)	NA

Bag leak detection system (new sources)	NA	§63.10899(b)(9)	NA

Capture system inspections	NA	§63.10899(b)(10)	NA

CPMS specifications	NA	§63.10899(b)(11)	NA

Corrective action	NA	§63.10899(b)(12)	NA

PM control device log of inspections/maintenance	NA	§63.10899(b)(13)	NA

Semiannual excess emissions/deviation reports	§63.10890(f)
§63.10899(c), Table 3	40 CFR 63.10(e)(3)

Initial performance test report	NA	§63.10900(a), Table 3	40 CFR
63.7(e)(1)

CMS performance evaluation report	NA	NA	40 CFR 63.8(e)(5)

SSM reports	NA	§63.10900(a), Table 3	40 CFR 63.6(e)(3)

1 Requirement is not expected to occur during the 3-year term of this
ICR

Table 2A:  Annual Respondent Burden and Cost for Small Foundries –
NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart
ZZZZZ) (Renewal)

Burden item	(A) 

Person-hours per occurrence	(B)  

No. of occurrences per respondent	(C)

 Person-hours per respondent (C=A*B)	(D) Respondents per yeara	(E) 

Technical person-hours per year (E=C*D)	(F) 

Management person-hours per year

 (E*0.05)	(G) 

Clerical person-hours per year (E*0.1)	(H) 

Costb, $ 

1.  Applications	N/A





	  

2.  Surveys and Studies	N/A





	  

3.  Acquisition, Installation, and Utilization of Technology and Systems
N/A





	  

4.  Reporting Requirements





	  

A.  Read instructions	4	1	4	114.67	458.68	22.934	45.868	 $36,836 

B.  Required activities





	  

     Scrap specifications	4	1	4	114.67	458.68	22.934	45.868	 $36,836 

Monthly rolling average calculation	0.25	12	3	114.67	344.01	17.2005
34.401	 $27,627 

     No methanol binder formulation c 	0	0	0	0	0	0	0	 $-   

C.  Create information	See 4B





	  

D.  Gather existing information	See 4B





	  

E.  Write report	See 4B





	  

     Initial notification of applicability	2	1	2	101	202	10.1	20.2	
$16,222 

     Notification of compliance status	4	1	4	114.67	458.68	22.934	45.868
 $36,836 

Deviations report	1	1	1	57.34	57.34	2.867	5.734	 $4,605 

     Notification of construction/reconstruction	N/A





	  

     Notification of anticipated startup	N/A





	  

     Notification of actual startup	N/A





	  

     Notification of special compliance requirements	N/A





	  

     Request for compliance extension	N/A





	  

     Notification of performance test	N/A





	  

     Site specific test plan	N/A





	  

     Notification of performance evaluation	N/A





	  

     Quality assurance plan for CEMS/COMS	N/A





	  

     NESHAP waiver request	N/A





	  

     Startup, shutdown, and malfunction plan/reports	N/A





	  

     Semiannual excess emissions reports	N/A





	  

Subtotal for Reporting Requirements





2,276.4185



5.  Recordkeeping Requirements 





  

A.  Read instructions	See 4A





	  

B.  Plan activities	See 4A





	  

C.  Implement activities	See 4A





	  

D   Develop record system 	2	1	2	114.67	229.34	11.467	22.934	 $18,418 

E.  Time to enter information d	0.1	52	5.2	114.67	596.284	29.8142
59.6284	 $47,886 

F.  Time to transmit or disclose information	0.25	2	0.5	114.67	57.335
2.86675	5.7335	 $4,604 

G.  Time to adjust existing ways	2	1	2	114.67	229.34	11.467	22.934	
$18,418 

F.  Time to train personnel e	N/A





	  

G.  Time for audits	N/A





	  

Subtotal for Recordkeeping Requirements





1,279.14385



TOTAL LABOR BURDEN AND COST

	 3,555 	 $248,288 

     Annualized cost of capital





$0

     Operation and maintenance (O&M)





$0

     Total (capital recovery plus O&M)   





$0



N/A = not applicable.

a We have assumed that there are 427 existing iron and steel foundries
that area sources.  No new sources are projected during the 3-year term
of this ICR.  Therefore, the average number of total respondents per
year is 142.33.  A total of 344 of the 427 facilities are small
foundries and 83 are large foundries.  Consequently, the average number
of small foundries during the 3-year period of this ICR is 114.67 and
the average number of large foundries is 27.67.   No new sources are
expected during the next 3 years.  For the purposed of deviation
reports, 1 report per year is estimated for one-half (50.5) of the
114.67 respondents per year.

b  This ICR uses the following labor rates: The fully-burdened hourly
wage rates used to represent respondent labor costs are:  technical at
$72.09, management at $97.99, and clerical at $33.16.  Technical,
management, and clerical average hourly rates for private industry
workers in the foundry industry (NAICS 331500) were taken from the
United States Department of Labor, Bureau of Labor Statistics, May 2006
available at http://www.bls.gov. The rates have been increased by 110%
to account for the benefit packages available to those employed by
private industry.

c We have assumed that no burden would be incurred for this requirement
because all small area source foundries are already meeting the no
methanol requirement.

d  We have assumed that small foundries must record information to
demonstrate compliance with pollution prevention management practices
for metallic scrap and binder formulations.

e  We have assumed that no cost would be incurred to train personnel.



TABLE 2B.  Annual Respondent Burden and Cost for Large Foundries –
NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart
ZZZZZ) (Renewal)

Burden item	(A) 

Person-hours per occurrence	(B)  

No. of occurrences per respondent	(C) 

Person-hours per respondent (C=A*B)	(D) Respondents per yeara	(E) 

Technical person-hours per year (E=C*D)	(F) Management person-hours per
year (E*0.05)	(G) 

Clerical person-hours per year (E*0.1)	(H) Costb, $ 











1.  Applications	N/A







	2.  Surveys and Studies	N/A







	3.  Acquisition, Installation, and Utilization of Technology and
Systems 	N/A







	4.  Reporting Requirements







	A.  Read instructions	8	1	8	27.67	221.4	11.1	22.1	$17,777

B.  Required activities 









     Scrap material specifications	4	1	4	27.67	110.7	5.5	11.1	$8,889

     Prepare operation & maintenance plan	8	1	8	27.67	221.4	11.1	22.1
$17,777

     No methanol binder formulation c 	4	1	4	0.67	2.68	0.134	0.268	$215

Initial/subsequent performance tests d	0	0	0	0	0.0	0.0	0.0	$0

Initial and periodic inspections of PM control devices, monthly
inspection of capture systems d	0	0	0	0	0.0	0.0	0.0	$0

 Monthly emissions averaging calculations d	0	0	0	0	0.0	0.0	0.0	$0

C.  Create information	See 4B







	D.  Gather existing information	See 4B







	E.  Write report	See 4B







	     Initial notification of applicability	4	1	4	27.67	110.7	5.5	11.1
$8,889

     Notification of compliance status	8	1	8	27.67	221.4	11.1	22.1
$17,777

     Notification of construction/reconstruction	N/A







	     Notification of anticipated startup	N/A







	     Notification of actual startup	N/A







	     Notification of special compliance requirements	N/A







	     Request for compliance extension	N/A







	     Notification of performance test d	1	1	1	27.67	27.7	1.4	2.8	$2,222

     Site specific test plan d	0	0	0	0	0.0	0.0	0.0	$0

     Notification of performance evaluation	N/A







	     Quality assurance plan for CEMS/COMS	N/A







	     NESHAP waiver request	N/A







	     Startup, shutdown, and malfunction plan/reports	4	1	4	27.67	110.7
5.5	11.1	$8,889

     Semiannual excess emissions reports d	2	2	4	27.67	110.7	5.5	11.1
$8,889

Subtotal for Reporting Requirements





1,307.982



5.  Recordkeeping Requirements 







	A.  Read instructions	See 4A







	B.  Plan activities	See 4A







	C.  Implement activities	See 4A







	D   Develop record system 	4	1	4	27.67	110.7	5.5	11.1	$8,889

E.  Time to enter information e	0.5	52	26	27.67	719.4	36.0	71.9	$57,775

F.  Time to transmit or disclose information	0.25	2	1	27.67	13.8	0.7	1.4
$1,111

G.  Time to adjust existing ways	2	1	2	27.67	55.3	2.8	5.5	$4,444

F.  Time to train personnel f	4	1	4	27.67	110.7	5.5	11.1	$8,889

G.  Time for audits	N/A







	Subtotal for Recordkeeping Requirements





1,161.4



TOTAL LABOR BURDEN AND COST

	  2,469 	$172,430

     Annualized cost of capital g





	$8,490

     Operation and maintenance (O&M) h





$0

     Total (capital recovery plus O&M) g    





$8,490



N/A = not applicable.

a We have assumed that there are 427 existing iron and steel foundries
that area sources.  No new sources are projected during the 3-year term
of this ICR.  Therefore, the average number of respondents per year is
142.33.  A total of 344 of the 427 facilities are small foundries and 83
are large foundries.  Consequently, the average number of small
foundries during the 3-year period of this ICR is 114.67 and the average
number of large foundries is 27.67

 b  This ICR uses the following labor rates: The fully-burdened hourly
wage rates used to represent respondent labor costs are:  technical at
$72.09, management at $97.99, and clerical at $33.16.  Technical,
management, and clerical average hourly rates for private industry
workers in the foundry industry (NAICS 331500) were taken from the
United States Department of Labor, Bureau of Labor Statistics, May 2006
available at http://www.bls.gov. The rates have been increased by 110%
to account for the benefit packages available to those employed by
private industry.

c We assumed that two large area source foundries (2 foundries over 3
years = 0.67 foundries per year) are expected to have to change
formulations to meet the no methanol requirement.

d  We have assumed that these activities are not expected to occur
during the first 3 years of this ICR.

e   We have assumed that large foundries must record information to
demonstrate compliance with pollution prevention management practices
for metallic scrap and binder formulations and information to
demonstrate compliance with monitoring; inspection; operation and
maintenance; startups, shutdowns, and malfunctions; and other
requirements of the General Provisions (40 CFR part 63, subpart A). 

f   We have assumed that large foundries are expected to monitor visible
emissions using a trained employee.

g  Based on capital cost of $59,620 for file storage cabinets, 7 percent
interest, and 20-year equipment life (capital recovery factor = 0.142). 
No costs for monitoring equipment are estimated because no monitoring
equipment is required for existing foundries.

Total Burden Hours, Costs and Annualized Cost of Capital From 2A and 2B:

Tables	Burden Hours	Burden Cost	Annualized Cost of Capital

2A	3,555	$248,288	$0

2B	2,469	$172,430	$8,490





	Totals	6,024	$420,718	$8,490



Table 3:  Average Annual EPA Burden - NESHAP for Iron and Steel Foundry
Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)

Burden Item	(A)

Person hours per occurrence	(B) 

Occurrences per respondent	(C) 

Plants per year a	(D) 

Technical 

hours/year (D=A*B*C)	(E) 

Management 

  hours/year (E=0.05*D)	(F) 

Clerical

  hours/year   (F=0.1*D)	(G)

Costb, $

Report Review:







	  Initial notification of applicability 	1	1	142.33	142.3	7.1	14.2
$7,564

Deviation reports	1	1	50.1	50.1	2.5	5.0	$2,662

  Startup, shutdown, malfunction plan/report	2	1	142.33	142.3	7.1	14.2
$7,564

  Notification of compliance status	2	1	142.33	142.3	7.1	14.2	$7,564

  Semiannual excess emissions report	2	1	142.33	142.3	7.1	14.2	$7,564

TOTAL BURDEN AND COST

	712.3	$32,917



 a There are 427 existing iron and steel foundries that are area
sources.  No new sources are projected during the 3-year term of this
ICR.  Therefore, the average number of respondents per year is 142.33. 
.

b  This ICR uses the following average hourly labor rates: 58.18 for
managerial (GS-13, Step 5, $36.36 x 1.6), $43.14 (GS-12, Step 1, $29.98
x 1.6) for technical and $22.66 (GS-6, Step 3, $14.16 x 1.6) for
clerical.  These rates are from the Office of Personnel Management (OPM)
(2007 General Schedule( which excludes locality rates of pay.

 PAGE   

 PAGE   6 

 PAGE   

